Ensure your Lockout/Tagout Program is Specific

The lockout/tagout (LOTO) standard (Title 8 CCR § 3314) continues to be one of the most frequently cited standards by Cal/OSHA.  In 2014, LOTO was the fourth most cited standard behind the Injury and Illness Prevention Program and Heat Illness Prevention.  Among the top 17 most cited standards, lockout/tagout by far had the highest serious citation rate at 34%.  This was an increase over 2013.  In addition, where lockout/tagout compliance is allegedly involved in an accident, it is often cited as serious-accident related, which significantly increases the potential fine and liability to the employer.  Not surprisingly, almost 64% of the violations are appealed.  The LOTO standard is a performance oriented standard allowing the employer to show that their safeguards provide adequate protection to the employees working on the equipment.

We have been involved in numerous LOTO citation appeals.  Often the basis for Cal/OSHA citations are incomplete or improper training; inadequate documentation of the procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy; and/or incomplete procedures for re-energizing equipment for minor servicing.

All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to be trained in recognition of applicable hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling the energy.  The training must be equipment specific.

Several recent appeals of lockout/tagout citations have ruled against the employer because their written procedures were too general to satisfy the specificity requirements.  The procedures must list the sequential steps necessary to shut down, isolate, block, and secure machines or equipment.  Sequential steps for placing, removing, and transferring lockout/tagout devices are also required.  If energy control procedures are the same for various pieces of equipment or machines, or if the equipment or machines can be grouped in another logical manner, then a single energy control procedure may be sufficient.

The standard does allow as an exception, re-energizing the equipment during minor servicing, which includes minor tool changes and servicing activities with the equipment running if the tasks occur during normal production operations and are routine, repetitive and integral to the use of the equipment.  With respect to minor servicing, including minor tool changes and adjustments, the work must be performed using devices such as extension tools (e.g., scrapers, brushes) and other methods or means to protect employees from injury that provide effective protection so that the worker is not at risk from inadvertent movement or release of stored energy.  An OSHA letter of interpretation states that the “employer bears the burden of demonstrating on a case-by-case basis, that the minor servicing exception applies.”  However, even with respect to minor servicing, including minor tool changes and adjustments, the work must be performed using alternative measures that provide effective protection.  These procedures too should be documented.

Your procedures should specifically list the steps and the locations to de-energize the energy sources.  As a general rule, ensure that any employee responsible for lockout, regardless of the amount of experience an individual may possess, is able to safely and effectively de-energize all of the energy sources on a particular piece of equipment.  The Cohen Group has prepared numerous LOTO programs and can assist in assessing your lockout/tagout needs.