Lockout/Tagout Frequently Asked Questions
Does the lockout procedure have to be in writing?
In general, yes. OSHA says you have to document your lockout/tagout procedures. This makes sense because they’re instructions the mechanics have to follow when they do repairs.
OSHA only allows you to not have a written lockout procedure when the machine only has one energy supply that’s easy to identify and lock out. The machine can’t have any potential for stored energy. Locking that one energy isolating device completely de-energizes the machine. The authorized employee has to lock out the energy supply, and he has to be the only person in control of the lock. Aside from this, the work being done can’t create any hazards for other employees in the area, and you can’t have had any accidents involving repairs to that machine.
Our process equipment has so much inter-relationship between systems, and a lot of the service work we do is for unique situations. Are we supposed to have just one lockout procedure that covers everything?
Your lockout procedures would need to be specific to the job rather than to the machine itself if that’s what’s necessary to address the hazards. For example, if it would be absolutely safe for one part of process equipment to still have power while employees are doing repairs to another part of the equipment, you would only need to lock out the part of the equipment where the employees are working. You wouldn’t have to completely lock out the entire process if locking out part of it completely protects everyone. The extent of your lockout has to match the hazards, but you should be very careful about considering the potential for hazards to develop when you decide to only lock out part of the equipment.
Do authorized employees have to be trained to do all of the machine-specific procedures for all the machines in a facility, or can they just be trained on the procedures they do for the job?
OSHA’s lockout/tagout standard includes no requirement for authorized employees to know how to perform all of the facility’s machine-specific lock out/tag out procedures.
The training program under this standard will need to cover at least four areas: The employer's energy control program, the elements of the energy control procedures which are relevant to the employee's duties, the restrictions of the program applicable to each employee, and the requirements of the standard. The details will necessarily vary from workplace to workplace, and even from employee to employee within a single workplace, depending upon the complexity of the equipment and the procedure, as well as the employee's duties and their responsibilities under the energy control program.
We do all our repairs on first shift. Do we have to have second and third shift employees lock out the machine on their shifts even if they aren’t working on the machine?
If no one else will be working on the machine during a second or third shift, you can leave it locked out by the first shift employee until the first shift employee finishes the repairs.
If a first shift employee leaves and a second shift employee will continue working on it, then you have to transfer the lockout to the second shift employee. Usually the second shift worker will apply his lock as the first shift worker removes his.
If a second shift worker is leaving, and there isn’t a third shift, but the repairs are going to be finished by someone on the first shift, you don’t want to leave the second shift employee’s lock on the machine. In this case, OSHA says the second shift worker can replace the lock with a tag when he leaves. The machine will be tagged out when the first shift employee starts work. He can then replace the tag with his lock.
Are contractors supposed to use their own lockout procedures?
The rule says that you and the contractor have to inform one another of your respective lock out tag out procedures. Both of you have responsibilities for protecting your employees so you want to make sure everyone has enough information about the repair job to keep everyone safe. You probably know the most about how the equipment operates, but the contractor may know more about what’s going to be done during the repairs. Make sure you both have identified all the sources of hazardous energy and the contractor uses lockout procedures that control them all.
Aside from making sure the right procedures are followed, you (the host employer) have to make sure your employees comply with any restrictions from the contractor’s procedures. For example, your employees should be able to recognize the contractor’s lockout equipment and know to stay clear of the area where the work is being done.
Are we supposed to lock out a machine that we aren’t going to use anymore?
The lockout/tagout standard doesn’t apply when you "decommission" equipment or put machines "out of service." The main concern is probably that someone would try to start a machine that you don’t want to run anymore, for whatever reasons.
The lockout/tagout standard says that you can’t use lockout/tagout equipment for any other purpose, so if you aren’t actually doing repairs or servicing work on this equipment, you shouldn’t use lock out/tag out equipment on it.
To keep out-of-service machinery from being used, you might consider physically disconnecting it from it’s energy supplies. Dismantle it so that is isn’t hooked up to any energy anymore and it’s completely unable to be operated.
You could attach a tag such as "Do not use without authorization" or something similar onto the machine’s controls to show that you don’t want employees to operate that machine. This isn’t the same as following a tagout procedure – the tag is on the controls and not the energy isolating devices, and the tag doesn’t include a tagout warning statement. This method gives employees an instruction, and to be most effective you should inform your workers that this is how you’re going to identify equipment that isn’t supposed to be used.
You could also use padlocks to keep "off limit" equipment from being used, but make sure the locks you use can’t be mistaken as lockout locks. And again, inform employees about what the locks are for.
What does OSHA want us to do to "verify" lockout?
"Verification" is the final step in a lockout/tagout procedure. One way to do this is to try to start and run the machine using the operating controls. Part of this step could also be checking to be sure you have the locks and tags attached where they belong and that the energy isolating devices are in the "off" position. You might also have to check gauges or use test equipment to check temperatures, pressures, or to check for the presence of gases, vapors, or liquid. Remember that if there’s more than one person working on the machine, each authorized employee should verify the lockout.
Does equipment connected with a pneumatic quick disconnect require a LOTO procedure?
The lockout/tagout standard doesn’t apply to electrical equipment that’s completely shut off from all its energy supplies by unplugging the power cord. This exception for cord and plug equipment doesn’t apply to pneumatic energy supplies – it only applies to electrical energy. A machine supplied by pneumatic energy would need to have a lock out/tag out procedure.
Is it required to use plug covers to lock out power cord equipment?
The standard doesn’t apply to electrically powered machines that are completely disconnected by unplugging the cord – if the cord is under the exclusive control of the person doing the repairs. If this is the case, then no, you don’t need to lock a plug cover onto the plug.
If the machine has other energy supplies, or if the person doing the repairs won’t have exclusive control of the plug, then the standard would apply. You could use a plug cover to lock out the machine.
Do we have to lock out our forklifts when we do repairs?
Yes. OSHA’s compliance directive clarifies that the rules apply to vehicles such as forklifts, cars, trucks, and other vehicles.
Whether they’re powered by gas, propane, or electricity, vehicles have several types of hazardous energy that you need to disconnect and lock out during repairs. For example, batteries can cause electrical shocks and arcs, fuel systems can cause chemical exposures and fires, and mechanical energy from moving parts can cause crushing injuries.
If you want guidance on how to lock out vehicles, there’s a whole section on vehicle lockout in OSHA’s compliance directive. In some cases, the person doing the repairs is completely protected by removing the ignition key – if he’s the only person who has the key. Depending on the work being done, you might have to take other steps such as disconnecting the battery or inserting blocks to keep parts in place. OSHA says you should follow the vehicle manufacturer’s recommendations for how to do service and maintenance work.
We have large ovens. Do we have to account for the heat in the lockout procedure?
Yes, OSHA lists examples of energy sources in the rule’s definitions. They include: electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other types of energy.
Your procedures could treat the heat as stored energy and include a step for allowing the ovens to cool to a safe temperature before employees work on them.
We have process equipment. Does using bolted blinds and blank flanges count as lockout?
Blinds and blank flanges control hazardous energy in piping. The blinds and flanges are bolted in place, and this doesn’t involve an actual lock.
According to OSHA guidance, this method is just as difficult to defeat or bypass as is a lock. So, if you use bolted blank flanges and bolted slip blinds, it’s equivalent to using lockout.
If you do use this method, be sure to identify the persons who applied the controls. You can attach a tag to meet this requirement.