Lockout Tagout (LOTO) Procedure: Keeping your team safe
July 13 2020
Lockout Tagout: How to Achieve an Airtight LOTO Procedure
Imagine this worst-case scenario: You realize the HVAC has stopped running. You prepare to restart it, but you pause. Upon investigation, you find your newest technician, Mr. Go-Getter, has climbed inside to do a repair.
Your instincts have saved you and your team member from an unthinkable situation. But you, and your instincts, may not always be able to save the day. This is where lockout tagout (LOTO) procedures come in.
In this article, we’ll cover what a LOTO program is, when to use it, how to write one, and how to keep yourself out of trouble with your boss and OSHA.
What lockout tagout means
Lockout tagout (a.k.a. LOTO; lock and tag) is a set of safety protocols and checklists that protect workers from getting hurt by a sudden machine start-up or by releasing hazardous energy while performing maintenance activities.
Hazardous energy is the big dangerous stuff. Things like electrical energy and wires, heavy mechanical, hydraulic, pneumatic machinery (things operated by air or gas), natural gases, chemicals, and thermal energy.
How LOTO standards came to be
As much of a headache as these thorough safety procedures can be, they exist for a reason.
OSHA standards — the uptight for-your-own-good rules and regulations — came about some 50 years ago with efforts by employers, unions, and trade associations, together with now well-known national consensus and safety organizations such as the National Safety Council (NSC), the American National Standards Institute (ANSI), and the National Fire Protection Association (NFPA).
All the people you’ve come to know from the “because I said so” club. They’re not your enemies (even if it feels like they are).
When we need lockout tagout
Ask yourself this: “Could someone get injured while repairing a machine? Do my machines need to be taken offline for repairs and maintenance?” If you answered yes, it’s LOTO time.
Maintenance like this can either be right on schedule or, more often than not, catching you by surprise. If you’re working for a big company with lots of moving parts, complicated and even dangerous machinery (with new techs and the not-so-dependable on-call guys?) It can be a real headache.
What’s worse than a headache, though? A nightmare. Let’s look at what can happen when you don’t have a LOTO procedure in place.
LOTO program vs. LOTO procedure: Not the same thing
It’s important to differentiate between a lockout tagout procedure and a lockout tagout program. Some use these terms interchangeably, but we need to separate them here to clarify some things:
LOTO program: a safety program whose purpose is to ensure that necessary LOTO procedures are correctly written and followed.
LOTO procedure: a set of steps you need to follow to lockout a specific piece of machinery.
Since they have a very similar relationship, you can think of it this way; lockout tagout procedures are your preventive maintenance checklists, and the lockout tagout program is your preventive maintenance program. Programs are used to plan and schedule. Checklists and procedures help in executing those plans. Ahhh. Now we feel better, too.
Why you can’t afford NOT to have a LOTO procedure
Compliance, of course, is top of mind for facilities managers. But safety is always right up there too. Safety, especially when working with hazardous materials like gas, and toxic waste, makes having a LOTO procedure an absolute must.
Tragic deaths do happen
In 2006, a Wisconsin-teen named Dusty Babcock was pinned beneath a machine that hadn’t been properly de-energized. Dusty died of his injuries six days later. Multiple safety violations were found at the facility, including the failure to conduct periodic inspections of machine safety procedures and affix lockout devices to isolate energy before allowing employees to enter machine-hazard areas.
Unfortunately, this story isn’t exactly unique. If lockout tagout practices are not followed, employees can be seriously injured or killed by the machinery they use every day.
Keeping your employees safe is a priority, of course. But another significant consideration is the HUGE fines involved if you choose not to follow the regulations laid out by the Code of Federal Regulations (you can kiss your bonus goodbye).
Here’s something to think about: the fines! Fines can range from $12,653 – $136,532 per violation. Don’t think your boss will be too happy about that. (You’ll have lots of free time to think it over if you’re fired, too). Lucky for you, OSHA put together a fact sheet on exactly how to avoid these astronomical fines and other big problems.
One example is OSHA’s standard on the control of hazardous energy. The standard tells us the minimum requirements for controlling hazardous energy. But it also requires employers to have a program in place to make sure employees lockout machines before servicing or maintaining them.
OSHA requires LOTO, and its purpose is to control big freakin’ oopsies that help avoid things like explosions from hazardous energy that injure the nice new guy, Craig — the imaginary maintenance tech.
Craig’s company ended up agreeing to a 1.5 million dollar settlement to settle the allegations that the company allowed workers to ignore OSHA LOTO safety standards, which caused Craig’s injuries. All of this is after $525,000 in lawyer fees and a complete shutdown of the organization.
The investigation stated that their facility officials knew that workers were not following the proper lockout tagout (LOTO) steps to turn off the machinery before servicing or repairing it. Nightmare, right?
The wrong kind of media attention
Here’s the full story on what happened with Craig. He worked at a well-known metal stamping plant in Alabama. Their machinery operator walked into a confined space to troubleshoot a piece of machinery that was acting up. The worker was then struck by a robotic arm, pinning him against another machine, causing significant injuries.
Now it’s not just the settlement you have to worry about. It’s also the media bonanza heading your way. Once the word gets out that your company failed to comply with a simple LOTO procedure and it caused the injury or death of one of your employees, you can say goodbye to your yearly bonus, your job, and your entire company’s reputation.
Oh no, everyone quit their job!
Guess what? Your employees care about the company’s reputation too. And when they heard about what happened to Craig, they lost a lot of trust. People want to work for a company that cares about their well-being and safety. When tragic incidents like Craig’s happen, not too many folks are keen on sticking around because they fear what might happen to them if they’re in the wrong place at the wrong time.
What makes a successful LOTO program
No one is too cool for occupational safety. And although it can be a lot of work to put together a robust safety plan, it benefits employees, management, and the company in big ways. Let’s look at the steps you can take to make your LOTO program efficient and effective.
Safety is your #1 priority
The top of your to-do list is to develop, implement, and enforce an energy control program. Use lockout devices for equipment that can be locked out. Tagout devices may be used instead of lockout devices only if the tagout program provides employee protection equivalent to that provided through a lockout program.
Ensure that new or overhauled equipment is capable of being locked out. Develop, implement, and enforce an effective tagout program if machines or equipment are not capable of being locked out.
Assess all risks
Whenever new equipment is added or reconfigured in the plant, assess potential hazards and potential personnel exposure. All plant system components and energy isolation points need to be documented. As things change, this documentation must be diligently updated.
Keep thorough documentation
Once LOTO procedures and equipment are in place, documentation is mandatory. This helps everyone understand what was done, what’s planned to be done, who is involved, and what steps are needed for resolution.
Procedures for isolating and locking out hazardous energy must be readily available and highly visible to anyone coming into contact with the equipment or system.
Easy-to-access documentation makes the process less complicated for everyone. Posted procedures must be up-to-date, readable, and protected from the environment by lamination or some other protective method. Employees must be instructed to leave the information with the equipment at all times. If electronic notification of procedures is used, then everyone involved must have access to a computer.
With a mobile CMMS like Limble, LOTO procedures can be in your techs’ hands at all times. You can quickly put together a work order template that walks your tech through the LOTO procedure for any specific asset, and they can access it from their phone at all times.
Creating a LOTO checklist in Limble CMMS
Uphold company standards and reputation
The success of your business is dependent on the trust and confidence you earn from your employees, customers, and shareholders.
We know that companies gain credibility by adhering to their commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct; a commitment to safety showcases this.
Train your team
An ongoing training program for LOTO procedures should be part of your company’s training. All parties involved in working with equipment or systems with hazardous energy sources must be required to participate.
Hold a briefing at each shift to familiarize everyone with the procedures and LOTO expectations. Discuss the consequences of not following LOTO procedures, that it won’t just be your ass on the line if these rules don’t get followed.
This must happen at least once a year, especially when there’s been a change in job assignments, machines, equipment, or procedures or when the employee fails to follow LOTO procedures properly.
When you’re out managing your team, take some time to inspect and audit. Let the team know that you’ll be making rounds from time to time to check and ensure that this safety program is being followed. Stay up-to-date with the latest technology and best practices.
Does OSHA do inspections, for real?
Yes. At least once per year. Santa is watching you. Here are the top six reasons OSHA will make an inspection.
1) A worksite or employee is in imminent danger
You typically see this when OSHA gets tipped off that your worksite is unsafe and severe harm could happen to your team. We see this on worksites where it is reasonably likely that a severe accident could occur immediately.
2) There has been a fatality or serious accident
After someone has been injured, or any workers comp claim has been filed, OSHA will often visit your site to investigate the working conditions and regulations being upheld (or not).
Your employees have the legal right to file a workplace safety violation complaint with OSHA. OSHA takes these complaints very seriously. How OSHA responds to the criticism varies depending on the specific area of concern(s), the seriousness of the safety & health issue(s) raised, and other factors.
OSHA will maintain strict confidentiality of anyone who files a complaint, and they will also inform them of any action it takes regarding the protests.
4) Referrals from third parties
Some people may combine “referrals” with “complaints,” but separating them into two categories is essential. A referral for an OSHA inspection can come about from many different situations, not just current or former employees. If you allow public tours of your facility, be “extra sure” that everything is being done safely. You never know who might be in that tour group who would/could call OSHA if they see workers exposed to severe hazards.
A few actual source examples of OSHA referral inspections include:
Media stories of an accident or unsafe conditions
State or local health departments
State or local police and fire departments
Occasionally, from OSHA’s On-Site Consultation services programs
Other Federal agencies (i.e., OSHA and EPA are increasingly collaborating on this method)
Compliance officer driving by a worksite and observes possible violations from the street (not uncommon). For those work locations where there is engagement with the public, a compliance officer visiting your site on personal time can also trigger a referral inspection.
5) Planned inspections
Planned or scheduled inspections follow a ‘surprise lottery’ site selection process (yay! Don’t you love surprises?). These inspections are aimed at specific high-hazard industries and work sites that tend to yield high safety/health hazards.
Planned inspections usually focus on workplaces that have reported significantly higher injury rates compared to their peers. Keep in mind that when a compliance officer shows up to conduct an OSHA safety inspection, they’re more likely to have a negative preconception of the site’s safety compliance if you’ve had high injury rates reported.
These inspections are why employers need to maintain accurate OSHA 300/301 recordkeeping logs and not over-record/report injuries. For example, many employers over-report by including first-aid cases in their records.
6) Follow-up visits
A follow-up inspection checks if a previously cited employer has corrected violations received in an earlier inspection. Suppose an employer fails to correct a cited violation. In that case, the employer will be subject to Failure-To-Abate (FTA) offense (these are bad news) which involves additional penalties until the violation is corrected (around $7,000 per day).
An FTA exists when a violation previously cited has never been brought into compliance and is observed in a later inspection. If, however, that violation was corrected only to happen again later, then OSHA may issue the employer a repeat violation with a penalty amount of up to $125,000!
Having a LOTO procedure that will keep OSHA off your back
By this point, you’ve got the idea that you don’t want to mess with neglecting your LOTO safety protocols. But you might still be wondering how to put together a LOTO procedure that keeps OSHA happy. Let’s cover some common questions you might have.
Does my facility need LOTO procedures?
While most businesses that use heavy machinery and dangerous equipment have established LOTO checklists, it does not apply in every case. According to OSHA, LOTO generally applies to “the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees.”
In this case, it’s probably easier to list the specific industries where LOTO doesn’t apply (because they have their own safety standards).
Here’s a look at industries that don’t use LOTO procedures:
oil and gas well drilling and servicing
When do OSHA standards apply?
OSHA has identified two key activities:
Normal production: We see this as any use of a machine or piece of equipment to perform its intended purpose, like your mechanical lifts and power presses.
Servicing and maintenance: OSHA defines any action necessary to prepare or maintain a machine or piece of equipment for regular production, like greasing the gears or inflating the tires on a device.
As a general principle, the LOTO standard does not apply to normal production activities unless the employee is required to remove or bypass a machine guard (like a control panel) or place any part of their body in an area where unexpected startup of the machine or equipment may cause injury. The bypass process is where your power on/off checklist has to be thorough; this way, your team knows the procedure for each piece of equipment.
If you’re unsure about any activity that may or may not fall under the scope of this standard, always play it safe and perform the lockout.
Training that makes OSHA happy
When OSHA evaluates a company’s lockout tagout compliance and performance, it looks for employee training in the following categories:
Authorized employees: Those who perform the lockout procedures on machinery and equipment for maintenance.
Affected employees: Those who do not perform lockout requirements but use the machinery that is receiving maintenance.
Other employees: Any employee who does not use the machinery but is in the area where equipment is receiving maintenance.
Do I need a LOTO procedure for every piece of equipment?
Well, no…but, yes. You need a different LOTO procedure for every additional piece of equipment. For example, if you have multiple HVAC units, they can all share the same LOTO procedure. But the HVAC unit will need a different LOTO procedure than the baler.
Where do I get these LOTO procedures?
Most Operation & Maintenance Manuals will include the LOTO procedures. However, if the manufacturer does not supply it, then one will need to be developed. Limble makes this process super easy. Manuals, pictures, and specific protocols can all be easily added to the software, so they’re available each time your technician needs to complete a lockout tagout checklist.
Exceptions for LOTO procedures
There are a few exceptions when LOTO procedures do not apply:
Your employee has to place any part of their body into an area of/near a machine or piece of equipment where work is performed.
Your employee has to place any part of their body into an area where an associated danger zone exists during a machine operating cycle (like on a forklift)
Your employee is working on equipment that requires a plug-in-connected electric supply. In this case, exposure to the hazards of unexpected energization or startup of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.
How to write your LOTO procedures
The exact details of a lockout tagout procedure can vary depending on the type of machinery in question, but the process should follow this overarching set of steps. These should be extremely thorough, leaving no room for interpretation. No detail is too small to include in a suitable LOTO procedure.
Step 1: Preparing for shutdown
It’s essential to consider OSHA’s guidelines and create custom requirements for your employees to ensure they can understand and apply the program to their workday.
All affected employees need to be notified that a lockout is being performed and told the reasons why. The authorized worker performing this task should review the LOTO procedure for the equipment that is about to get serviced and ensure that the lockout is being performed on the right piece of machinery.
Note: Creating a lockout program should be a collaborative effort from all levels of the organization, and don’t forget to make procedures easy to access!
Step 2: Review the specific LOTO procedure for the asset
Before performing the shutdown, review all the steps to make sure you and your team are clear on your next steps. The procedures should detail the specific steps necessary for shutting down, isolating, blocking, and securing equipment to control hazardous energy and measures for the placement, removal, and transfer of lockout /tagout devices.
Lockout procedures should be easy to create, edit, and access. In Limble, creating a LOTO checklist for each asset is easy. Whenever your techs need to perform maintenance on a piece of equipment, they can easily change the status on the machine so everyone can see that it is non-operational (the app updates live, too!). You can set up a Work Order template with your LOTO checklist instructions, complete with manuals and images, so you know that your techs are following the same procedure every single time.
Going beyond compliance, we recommend creating best practice procedures that include machine-specific photos identifying energy isolation points. These should be posted at the end of use to provide employees with clear, visually intuitive instructions.
Step 3: Performing the shutdown
If the equipment is operating, a standard stopping procedure for that piece of equipment should be followed. If needed, detailed steps should be outlined (in the proper sequence) that show how to shut down the machine. Employers must establish the procedures for removing the energy source from machines and putting the appropriate devices on them to prevent unexpected startup or re-energization (tags, padlocks, safety stoppers).
Step 4: 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 locate all primary energy sources (it can be electricity, steam, water, gas, compressed air…) and know how to disconnect them.
A suitable lockout tagout procedure will offer detailed explanations (and even photos/diagrams) for all actions that need to be taken in this step.
Step 5: 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. With so many products on the market designed to help keep your employees safe, selecting the most suitable solution for your application is the key to lockout effectiveness.
Once selected, it’s essential to document and use devices that best fit each lockout point. If you have complex locks, consider including visual instructions.
A note about tags: If tags are going to be used instead of a physical lock, there must be additional levels of employee protection to prevent an employee’s accidental injury or death.
While the machine should now be safely locked down, there might be some residual energy that needs to be blocked or released. A lockdown 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 7: Verifying the lockout
When all of this is done, it is important to ensure that the system is locked correctly. 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 8: Perform scheduled servicing
This is where maintenance techs step in to perform the necessary maintenance work and keep the scheduled downtime as short as possible.
Not sure if you can maintain the sustainability costs? In the long run, programs that lack sustainability tend to have higher prices because the lockout tagout program must be recreated each year. By simply maintaining your schedule throughout the year, you’ll enhance your safety culture and use fewer resources because you won’t need to reinvent the wheel each time.
When looking at your program from this perspective, it’s clear that a sustainable program helps you stay one step ahead while saving time and money.
Step 9: 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 explain how to “undo” the lockout and reconnect all energy sources. This includes inspecting the machine’s integrity 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.
Laying the groundwork for a LOTO program
Writing one LOTO procedure is one thing, but implementing a whole LOTO program is a whole other thing. It can feel daunting. You can set yourself up for success by preparing well. Here are a few things we recommend considering when preparing to implement a LOTO program at your company.
Get buy-in from relevant parties
Who should care about LOTO programs? Everyone. Management needs to approve the funds, the safety and maintenance teams need to develop and respect LOTO procedures, and all employees must follow basic safety guidelines.
Getting maintenance technicians and machine operators on board is usually 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, and those who are responsible for implementing safety programs should review if the complaints hold any merit.
Convincing management to give you more funds to improve your LOTO program can be more complicated. The good thing is that OSHA requires LOTO, so you can always play that card. What might be more effective is to present convincing numbers. Unsafe working environments hinder productivity; accidents and injuries can cause a vast array of operational issues. Most importantly, the company can lose money in court if safety issues are not adequately addressed.
Write your LOTO policy
A LOTO policy is the best way to put your LOTO program into writing. Think of it as the “safety Bible” for your company. It details the big picture of your LOTO program down to the minute details of each particular LOTO procedure.
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).
Definitions of commonly used terms (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).
This document could turn out to be quite lengthy if you are thorough! If you do a good job now, annual audits will require minimal updates.
Before we move on, let’s just touch on a couple of 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 check if your state/country has specific guidelines.
LOTO for all situations. Consider including additional guidelines for specific situations like what to do in emergencies, how to perform Group LOTO (when multiple people have to be involved in the lockout process), and guidelines for outside contractors.
Purchase quality LOTO hardware
Buying quality safety devices matters a lot. A lock that doesn’t lock properly and a tag that is ruined by two water droplets (hence the laminated labels) are not a good foundation for your LOTO program. You need locks and tags that will last for the long haul.
Specific machines can require specific lockout devices. Suppose you’ve finished writing your LOTO policy. In that case, 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.
There are plenty of online safety product shops where you can purchase single lockout devices like:
Be sure to document the details of your purchase so you can easily replace them and keep LOTO equipment consistent throughout the building.
Standardize everything you can
Standardizing the LOTO process comes with three big advantages:
it is easier to scale it across multiple machines and different locations
workers have an easier time sticking to the procedure if the core steps are always the same
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 solution is to outline the method according to the state with the most stringent rules and use that as a template for all other locations. Limble makes this easy. You can duplicate LOTO procedures for similar assets at different locations with just a few clicks.
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
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. Training can be split into three categories. Employees are provided with the required level of training depending on how much they are involved in the process:
Authorized-level training: Training for people who will be authorized to perform the lockout procedures. They need to go through an in-depth course that includes on-site machine-specific training.
Affected-level training: Training for people who will not perform LOTO procedures but use the machines that are being stopped for servicing.
Awareness-level training: Training for people who do not use these machines but work physically close to them.
Organizations tend to perform annual audits of their LOTO procedures since that is what OSHA usually recommends. There are many reasons why you should comply:
OSHA regularly updates its 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 lock out a specific machine safely
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
Additionally, regular audits bring lockout/tagout standards into the spotlight, which is an excellent way to promote safety culture and remind people about the importance of these safety guidelines.
Examples of LOTO programs
To wrap things up, let’s take a quick look at some examples of lockout tagout programs.
University of Connecticut
The first example comes from UCONN. You can see which chapters it covers in the picture below. You can find their entire program here.
UCONN LOTO program content table
The University of Colorado, Colorado Springs (UCCS)
This one is a bit more detailed. Their program might not be directly translatable for your business, but they provide a practical example that can be followed. Find their complete program here.
UCCS LOTO program content table
Common LOTO mistakes you don’t want to make
Everybody makes mistakes, but when it comes to LOTO, there’s a whole laundry list of missteps you never want to make:
Lack of specificity in your LOTO procedures — as in, not enough detail. You don’t want to leave anything up for interpretation.
Failure to stop equipment prior to performing work.
Not using a LOTO because the job “will only take a few minutes”.
Performing the energy isolation by only locking out the circuit breaker and not the main switch or unit.
Asking someone else to lock out another machine for you.
Leaving the keys in the lock.
Failure to follow energy control procedures (i.e., disconnecting from the power source, neutralizing residual energy, etc.).
Accidental restarting of equipment.
Failure to clear work areas before restarting.
Not implementing your LOTO program well enough.
A safe facility is a productive facility
Cutting corners while developing safety programs is a risky business (no pun intended). Just as your company, supplies, and equipment grow and change, your lockout tagout procedure should continuously improve and evolve.
An important player in creating a safe facility is quality maintenance work that keeps equipment in healthy operating condition. Many organizations rely on CMMS software to manage all maintenance work to ensure that maintenance tasks have been performed on time and up to a required standard. To learn more about a CMMS, check out our guide on What is a CMMS System and how it works.
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