Top 5 LOTO violations and how to avoid them

The numbers are in for fiscal year 2023, and once again the Control of Hazardous Energy, more commonly known as lockout/tagout (LOTO), is a top-violated general industry standard. The standard requires employers to establish a program for affixing lockout or tagout devices to energy-isolating devices on machines and equipment to prevent their unexpected energization, startup, or release of stored energy. This applies in all general industry workplaces where employees perform servicing or maintenance on machines or equipment that could expose them to the unexpected release of hazardous energy.

#1 – Energy control procedures, 1910.147(c)(4)(i)

Employers covered by the standard must establish an energy control program tailored to the machinery and equipment in each workplace to protect employees from the unexpected release of hazardous energy during servicing and maintenance activities. One of the main pieces of this program includes energy control procedures. These procedures specify the steps employees must take to isolate machines and equipment from their energy sources and to render them safe for employees to perform servicing and maintenance.

#2 - Periodic inspections, 1910.147(c)(6)(i)

Energy control procedures must be inspected at least annually to ensure that the procedures and the requirements of 1910.147 are being followed. Periodic inspections must be:

• Performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected, and
• Conducted to correct any deviations or inadequacies identified.

Where lockout is used for energy control, the periodic inspection must include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected.

Employers must document certification of these inspections. The certification must identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.

#3 - Energy control program, 1910.147(c)(1)

Employers must establish a program consisting of energy control procedures, employee training, and periodic inspections to ensure that before any employee performs servicing or maintenance on a machine or equipment where the unexpected energizing, start up, or release of stored energy could occur and cause injury, the machine or equipment must be isolated from the energy source, and rendered inoperative. Employee training is outlined in paragraph (c)(7).

#4 - Procedure elements, 1910.147(d)

Employers’ energy control procedures must address specific elements and actions, and these procedures must be done in the following sequence:

1. Preparation for shutdown,
2. Machine or equipment shutdown,
3. Lockout or tagout device application,
4. Stored energy, and
5. Verification of isolation.

#5 - Authorized employee training, 1910.147(c)(7)(i)(A)

Authorized employees must be trained in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.

An authorized employee is one who locks out or tags out machines or equipment to perform servicing or maintenance on those machines or that equipment. Any employee who performs one or more procedural elements of an employer’s energy-control program for the purpose of servicing or maintenance is considered an authorized employee.