How To Write Lockout Tagout Procedure And Implement LOTO Program

lockout tagout (LOTO)

It is hard to be productive if you’re constantly on the lookout for things that can hurt you. Workers in the industrial space have surely felt like that at some point in their career as accidents and injuries are an everyday occurrence.

To ensure worker safety, organizations rely on strong safety programs. An integral part of every safety program is the implementation of lockout tagout procedures for selected machines.

OSHA states that “Compliance with the lockout/ tagout standard prevents an estimated 120 fatalities and 50,000 injuries each year.”, which is why every relevant industry needs to be able to develop and implement necessary LOTO programs.

With that in mind, here is the list of major areas we are going to cover in this article:

There’s a lot of things to cover so we better get started.

What does lockout tagout mean?

Lockout tagout (a.k.a. LOTO; lock and tag) represents a set of safety procedures and practices that protect workers from getting injured by a sudden start-up of the machine or by the release of hazardous energy, while performing maintenance activities. LOTO is required by OSHA and its purpose is to control hazardous energy.

As stated in the OSHA guidelines for lockout/tagout, this process requires: “…that a designated individual turns off and disconnects the machinery or equipment from its energy source(s) before performing service or maintenance and that the authorized employee(s) either lock or tag the energy-isolating device(s) to prevent the release of hazardous energy and take steps to verify that the energy has been isolated effectively.

As the name hints to, there are two types of devices that are used here. There are lockout devices that are placed to prevent machines from suddenly starting up and they can’t be removed without a key. Tagout devices (a.k.a lockout tags; loto tags) are basically glorified warning signs and as such are more easily removed.

LOTO procedures are most often used in industrial maintenance, but not exclusively, which leaves some businesses wondering if these standards apply to them.

If you too are unsure, you will be interested to know that the common compliance issue employers have is that their LOTO standards are too narrow: “Specifically, we have found that employers do a very good job of addressing hazardous electrical energy in their LOTO programs, but LOTO applies to every type of hazardous energy, including mechanical, thermal, hydraulic, pneumatic and gravity.

To learn more, take a look at this article that discusses LOTO compliance issues (and from which the above excerpt is taken).

Write lockout tagout procedure in 8 steps

The exact details of a lockout tagout procedure can vary depending on the type of machinery in question, but the process should follow these overarching set of steps:

Step #1: Preparing for shutdown

All affected employees need to be notified that a lockout is being performed and told the reasons why. The authorized worker that is performing this task should review the LOTO procedure for the equipment that is about to get serviced and make sure that the lockout is being performed on the right piece of machinery.

Step #2: Performing the shutdown

If the equipment is operating, a normal stopping procedure for that piece of equipment should be followed. If needed, there should be detailed steps outlined (in the proper sequence) that show how to shutdown the machine.

Step #3: Locating and disconnecting all energy sources

When the asset is powered down, the next step is to disconnect it from its energy source(s). The authorized person performing this action needs to be able to locate all primary energy sources (it can be electricity, steam, water, gas, compressed air…) and know how to disconnect them.

A good lockout tagout procedure will offer detailed explanations (and even photos/diagrams) for all actions that need to be taken in this step.

Step #4: Placing locks and tags

After the equipment has been isolated from its energy sources, it is time to install lockout devices on switches and controls and mark them with appropriate lockout tags.

If you have complex locks, consider including visual instructions.

Step #5: Releasing or blocking any stored energy

While the machine should now be safely locked down, there might be some residual energy that needs to be blocked or released. This is usually done by securing all moving and elevated assets, draining fluids, venting gases, dissipating heat from thermal systems, releasing springs to remove tension in the spring assembly, and so on.

Step #6: Verifying the lockout

When all of this is done, it is important to ensure that the system is actually properly locked. The best way to test that is to try and attempt the normal start-up. If everything has been done correctly, nothing should start to move. After the test, the controls need to be returned to the neutral/off position.

Step #7: Performing scheduled servicing

This is where maintenance techs step in to perform the required maintenance work and keep the scheduled downtime as short as possible.

Step #8: Restoring the equipment to service

After the scheduled maintenance has been performed, the equipment will need to be restored to normal operating conditions. The LOTO procedure should again explain how to “undo” the lockout and reconnect all energy sources. This includes inspecting if the machine is intact and double-checking that the area is clear before removing loto devices. Lastly, people that use the machine should be notified that the loto devices have been removed.

Here are the steps in a graphic form:

standard lockout tagout procedure

Lock out tag out procedure examples

Different organizations write LOTO procedures in different ways. Some use online tools to build checklists and other just write the instructions from scratch.

In the pictures below, you will see two examples. The first one is a lockout tagout procedure example for an air compressor built with a checklist tool.

The second LOTO procedure sample is for boilers and it presumably used by Northland College University as a part of their building maintenance efforts.

Requirements for successfully implementing a LOTO program

There are a few things you need to have in place to ensure that your LOTO program can be successfully adopted. Half-assed implementations are the main reason why lockout/tagout standards are frequently on the OSHA’s Top 10 most frequently cited violations.

We discuss the most important implementation requirements below.

#1) Buy-in from relevant parties

Who are relevant parties when it comes to LOTO programs? Everyone.

Management needs to approve the funds, the safety and maintenance teams needs to develop and respect LOTO procedures, and all employees need to follow basic safety guidelines.

Getting maintenance technicians and machine operators on board is easy as it is in their best interest to have a strong LOTO program. There might be some friction if the LOTO procedures contain steps that people find unnecessary, but those who are responsible for implementing safety programs should review if the complaints hold any merit. If all outlined steps are necessary, the implementation team should have strong enough arguments to convince everyone that this is the only safe way to perform a certain lockout procedure.

Convincing management to give you more funds to improve your LOTO program can be a little harder. The good thing is that LOTO is required by OSHA so you can always play that card. What might be more effective is to present convincing numbers. Unsafe working environment hinders productivity, accidents and injuries can cause a vast array of operational issues, and most importantly, the company can lose a lot of money in court if safety issues are not properly addressed.

#2) Getting quality lockout tagout kits & tags

A lock that doesn’t lock properly and a tag that is ruined by two droplets of water (hence the laminated tags) are not a good foundation for your LOTO program.

There are many lockout tagout kits on the market to choose from and they come in many different configurations:

lockout tagout kits
You can find these kits everywhere from Amazon and online safety shops to specialized hardware stores.

#3) Detailed lockout tagout procedures 

A common mistake when writing LOTO procedures is to only give the basic instructions: Shut down the machine. Disconnect two power cables. Place the lockout tag. 

While that might work for people intimately familiar with the machine, the LOTO procedures should be written as if you’re giving instructions to an outside contractor that has never been in your facility.

The more complex the machine is, the more detailed the instructions need to be. Additionally, if your plant floor and/or machinery in question have some kinks you need to account for, this type of tips and warnings should also be included.

How to implement a lockout tagout program

Before we move on, it is important to differentiate between a lockout tagout procedure and a lockout tagout program. Some use these terms interchangeably, but we need to separate them for the purpose of this article.

LOTO procedure is a set of steps you need to follow to lockout a specific piece of machinery while a LOTO program is a safety program which purpose is to ensure that necessary LOTO procedures are properly written and followed.

Since they have a very similar relationship, you can think of lockout tagout procedures as your preventive maintenance checklists, and the lockout tagout program as your preventive maintenance program. Programs are used to plan and schedule, checklists and procedures help in executing those plans. 

Step #1) Write your LOTO policy

Whenever you want people to follow specific rules, it’s best to write them down. A LOTO policy is the best way to put your LOTO program into writing.

Things that should be included on a standard loto policy are:

  • Purpose of the LOTO program (what is it, why is it written, why is it necessary).
  • Scope of the program (what does the program cover and when it is applied).
  • Explanations for commonly used terms (like affected employee, lockout device, energy isolating device, etc.).
  • Responsibilities and roles (who is responsible for what; i.e. top management needs to allocate funds, supervisors need to provide LOTO hardware and perform audits, authorized employees must follow written procedures…) .
  • Detailed lockout tagout procedures for specific machines.
  • Training requirements (required levels of training that depend on one’s role in the process).
structure of a LOTO policy
It is usually going to take 10+ pages to include everything. If you do a good job now, annual audits will require minimal updates.

Before we move on, let’s just touch on a few important things you should keep in mind while writing the LOTO policy:

  • Be aware of state-specific guidelines. Most US companies will be fine following the federal 29 CFR 1910.147 OSHA Standard but do check if your state/country has specific guidelines.  
  • Consider including additional guidelines for specific situations like what to do in emergency situations, how to perform Group LOTO (when multiple people have to be involved in the lockout process), and guidelines for outside contractors. 
  • Make sure all relevant parties read the policy. When the policy is written, all relevant parties should get their written copy. It also doesn’t hurt to ask everyone to confirm that they are familiarized with its contents. 
If you need help in writing your own loto policy, Department of Labor has a written sample you can use as a starting point and build upon it using everything else we explain in this article. 

When the policy is written, it should be taken to upper management to secure their commitment (in case the process hasn’t already been preapproved). 

Step #2) Purchase required LOTO hardware

Specific machines can require specific lockout devices. If you’ve finished writing your LOTO policy you should have already identified which machines need to be locked down for maintenance and have a good idea of the number and type of lockout devices you need to have available. 

The lockout tagout kits we mentioned earlier should be able to cover most of your needs. If not, there’s plenty of online safety product shops from where you purchase single lockout devices like:

  1. SafetyLock
  2. Lockout Safety
  3. J.J.Keller
  4. Seton

Step #3) Standardize everything you can 

Standardizing the LOTO process comes with three big advantages: 

  1. it is easier to scale it across multiple machines and different locations 
  2. workers have easier time sticking to the procedure if the core steps are always the same
  3. it speeds up the regular audits
If your locations are in different states/countries and you still want to keep the process standardized, one possible solutions is to outline the process according to the state with the most stringent rules and use that as a template for all other locations. 

Here are a few tips on how to standardize a LOTO process:

  • outline what exactly needs to be included in your LOTO policies
  • use a consistent template for all LOTO procedures
  • use the same type of lockout tagout devices
  • provide training that brings everyone to the necessary knowledge/skill levels
  • develop a standardized approach to annual audits and procedure evaluations

Step #4) Ensure proper lockout tagout training

Part of the effort to ensure that the program is being followed is equipping people with the necessary skills to put the theory into practice.

The training can be split into three categories. Employees are provided with the necessary level of training depending on how much they are involved in the process:

  1. Authorized-level training. Training for people who will be authorized to perform the lockout procedures. They need to go through in-depth course that includes on-site machine-specific training.
  2. Affected-level training. Training for people that will not be performing LOTO procedures but use the machines that are being stopped for servicing. 
  3. Awareness-level training. Training for people that do not use these machines but do work physically close to them. 
If you need help with lockout tagout training there are free online courses available at sites like OSHAcademy and National Safety Council.

Step #5) Perform regular audits and procedure updates 

Organizations tend do perform annual audits of their LOTO procedures as that is what OSHA usually recommends. There are many reasons why you should comply:

  • OSHA regularly updates their policies and best practices and your LOTO procedures should reflect that
  • an audit can show that your procedures have room for improvement
  • regular wear and tear combined with frequent breakdowns might result in a need to perform additional steps to safely lock out a specific machine
  • you might purchase new lockout devices that work a bit differently and the procedures need to be updated
  • it is a way to measure if your program has been successful
In addition to everything stated, regular audits bring LOTO standards into the spotlight every so often which is a good way to promote safety culture and remind people about the importance of these safety guidelines.

LOTO program steps visualized

Examples of LOTO programs

To wrap things up, let’s take a quick look at some examples of lockout tagout program. The first examples comes from UCONN. You can see which chapters it covers in the picture bellow.

LOTO program example
You can find their full program here.

The second LOTO program example comes from UCCS and is a bit more detailed:

lockout tagout program example
You can access the full document here.

They might not be directly translatable for your business, but they do provide a practical example that can be followed.

A safe facility is a productive facility 

Cutting corners while developing safety programs is a risky business (no pun intended). 

There are always people who will find the LOTO process cumbersome, but you have to keep in mind that safety policies have to be written to cater to those that are most careless and prone to accidents. Just like speed limits do the same for traffic safety.

An important player in creating a safe facility is quality maintenance work that keeps equipment in healthy operating condition. To ensure that maintenance tasks have been performed on time and up to a required standard, many organizations rely on CMMS software to manage all maintenance work. 

If you’re interested in how Limble CMMS can help your organization streamline its maintenance management, contact us for a no strings attached chat.

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