Is Your Lockout/Tagout Program Effective? Three Tips to Developing a Compliant Program

By Chris Frendahl

Your facility’s Lockout/Tagout program is essential in ensuring employee safety while performing maintenance on energized equipment. Countless workplace fatalities and severe injuries have resulted from improper Lockout/Tagout procedures. OSHA regulations listed in 29 CFR 1910.147 requires all industrial facilities to develop and maintain a written Lockout/Tagout program that lists procedures for safely isolating equipment from all energy sources prior to servicing the equipment.  Here are 3 tips for ensuring that your Lockout/Tagout program is effective and compliant with OSHA regulations.

1)    Develop written Lockout/Tagout procedures for each piece of equipment
There is no “one size fits all” method for developing an effective Lockout/Tagout program. Machine-specific procedures should be written and maintained in the program. These procedures should identify all energy sources. It is often assumed that electricity is the only power source for equipment; however, your Lockout/Tagout procedures should include all energy sources, including: steam, pneumatic, hydraulic lines, gravitational forces, chemical energy, mechanical energy, etc.   These machine-specific procedures should list the specific steps for properly locking out the equipment at each isolation source as well as requirements for determining the procedures’ effectiveness in isolating the equipment from these power sources.

2)    Ensure that equipment being locked out reaches a “zero energy state”
Once a piece of equipment has been locked out, it is crucial to verify that the equipment reaches a “zero energy state.” This means that there is no residual or stored energy left in the machine after it has been isolated. If equipment is not in a zero energy state, it is possible for the machine to briefly activate while maintenance is being conducted, putting employees in danger. To verify that the equipment has reached a zero energy state, the authorized employees should ensure that no one is in the machine’s danger zone and attempt to operate the equipment at the on/off switch after applying all lockout devices. This will release all stored energy that may be left in the machine. Once complete, the controls should be returned to the “off” position and maintenance can begin. In the past, OSHA has cited facilities for lacking the wording specific to bringing the equipment to a “zero energy state” in the Lockout/Tagout procedures.

3)    Conduct annual procedure reviews
It is not enough to simply have a written Lockout/Tagout program filed on site, the program should be reviewed and you must physically validate the procedures on at least an annual basis. In order to evaluate how effective the machine-specific procedures are, an authorized employee must observe other employees performing the procedures, as written, at least annually. This will help to ensure that the procedures list steps to completely isolate the equipment from all energy sources and will allow employers to verify that employees are properly following the procedures. Additionally, you should conduct annual lockout/training for all employees, not just the authorized employees who will be servicing the equipment. Affected employees, those employees who operate machinery that is subject to Lockout/Tagout procedures, must also be trained. This training should include basic information of the Lockout/Tagout procedures so that they can understand why the procedures are being conducted and will know not to remove lockout devices and attempt to re-energize machinery that is locked out.

Following these three tips can help you to develop Lockout/Tagout procedures that comply with OSHA regulations and effectively protect employees from unexpected equipment startup while conducting maintenance.

If you would like help in developing a written Lockout/Tagout program or machine-specific procedures, please contact CTI.

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