NIOSH Reminds Employers of Annual Lockout Tagout Inspection

In FY 2021, lockout tagout ranked seventh on OSHA’S Top 10 list of most frequently cited standards with 1,670 total violations. Furthermore, within the standard, 1910.147(c)(6), the “periodic inspection” was the third most frequently cited section, with 255 violations. Subsequently, the fourth was standard 1910.147(c)(1), with 162 violations related to lockout tagout procedures, employee training, and periodic inspections. Thus, NIOSH reminds employers of required annual lockout tagout inspections on written hazardous energy control procedures.

The OSHA standard for The Control of Hazardous Energy (Lockout Tagout) (29 CFR 1910.147) addresses the practices and procedures to disable machinery or equipment. It is essential to prevent the release of hazardous energy while employees perform servicing and maintenance activities. In sum, the standard outlines measures for controlling hazardous energies, including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources.

Useful Tips and Reminders for Developing and Maintaining a Lockout Tagout Program

Compliance with the lockout tagout standard prevents an estimated 120 fatalities and 50,000 injuries each year. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation. NIOSH has offered tips and reminders for developing and maintaining a lockout/tagout program as below:

• The written procedures shall include the scope of procedures, intended purpose, names of authorized personnel, rules for shift change, transfer of locks, and specific methods used.
• A periodic inspection must include a demonstration of the procedures and be conducted while the authorized employee performs service/maintenance on a machine/equipment.
• Each energy control procedure must be separately inspected to ensure the procedure is adequate and properly implemented by the authorized employee.
• The inspector must be a knowledgeable lockout tagout authorized employee who isn’t currently performing lockout tagout on the energy control procedure under inspection.
• The inspector can’t implement any part of the procedure during the inspection but must observe the procedure implementation for the evaluated equipment or machine. Additionally, the inspector should speak with at least one authorized employee who implements the procedure to ensure a thorough understanding of the procedure.
• Lastly, the employer must retrain the employee if the inspection reveals deviations from the written procedures or inadequacies in the knowledge of procedures.

Key Takeaways

In summary, performing annual lockout audits can be a daunting task without the right knowledge and right tools. Industry subject matter experts with Martin Technical can help organizations identify and fill gaps in their current lockout tagout program. Typically, the evaluations cover ten topics and over 100 investigation points through observation of work processes, documentation, and administration of the program. Upon completion, a report containing compliance status, code references for the deficiencies, corrective actions, and best practices will be provided. There are three Annual Lockout Program Audits as below:

1. On-Site Audits It is performed by a subject matter lockout expert typically taking two days.
2. Rapid LOTO Audit App
   The Rapid LOTO app is an award-winning self-auditing tool for periodic lockout inspections.  The app takes users through each step of their program and provides a variety of reports and tools to improve their lockout program.
3. Customize Auditing Programs
   This inspection program offers various hybrid programs, including software, apps, live inspections, training, and online information. This option is best to create an audit program that best meets any organization’s needs.

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Resources and Helpful Information

• A NIOSH guidance document features recent case studies that detail separate workplace fatalities related to improper lockout tagout processes.
• OSHA Lockout Tagout Fact Sheet.
• OSHA’s general requirements for controlling hazardous energy during service or maintenance of machines or equipment.