When outside contractors perform maintenance or servicing at a facility, coordination between the contractor and the host employer becomes critical for worker safety. The Occupational Safety and Health Administration (OSHA) Control of Hazardous Energy standard (29 CFR 1910.147) requires employers to implement procedures that prevent the unexpected release of hazardous energy during equipment servicing. When multiple employers are involved, OSHA expects both parties to coordinate their Lockout Tagout (LOTO) programs to ensure that no employee is exposed to dangerous energy sources.
Under OSHA regulations, both the host employer and the contractor maintain independent responsibilities for protecting their employees. These responsibilities cannot be transferred from one employer to the other. Instead, both parties must communicate and align their LOTO procedures so that workers clearly understand how hazardous energy will be controlled during the job.
OSHA Expectations
One of the first expectations under OSHA’s LOTO requirements is the mutual exchange of energy control procedures. Before work begins, contractors and host employers must inform each other of their respective Lockout/Tagout programs. This allows both organizations to understand how equipment will be shut down, isolated, and secured before maintenance activities begin. It also ensures that employees can recognize lockout devices, tags, and communication practices used by the other employer.
Lockout Tagout Procedures
Host employers must also ensure that their employees understand and follow the contractor’s LOTO procedures when applicable. For example, employees working near equipment under maintenance must recognize that machinery secured with Lockout/Tagout devices cannot be restarted or interfered with. Proper communication helps prevent accidental startup of equipment while workers are performing servicing activities.
When both contractor and host employees are working on the same piece of equipment, OSHA typically requires the use of group Lockout/Tagout procedures. In these situations, each authorized worker must place their own lock on a group lockbox or lockout device. This ensures that every worker maintains direct control over their safety. A designated primary authorized employee may oversee the process to verify that all workers are clear before equipment is re-energized.
Facilities should also be aware of OSHA’s Multi-Employer Citation Policy, which allows the agency to cite more than one employer for the same hazard. Even if a contractor creates a hazardous condition, the host employer may still be cited if their employees are exposed to the risk. Because of this shared responsibility, proper LOTO coordination is essential.
How To Evaluate Your LOTO Procedures
Developing clear procedures, training employees, and communicating expectations with contractors can significantly reduce the risk of hazardous energy incidents. Conversion Technology, Inc. (CTI) has extensive experience helping facilities evaluate their LOTO programs, develop compliant procedures, and ensure coordination between contractors and host employers. With the right processes in place, organizations can protect workers while meeting OSHA’s hazardous energy control requirements.