LOTO Procedures: Why They Must Be OSHA-compliant

Companies follow LOTO procedures and practices to disable, de-energize, or shut down assets and equipment that can unexpectedly start or release hazardous energy, such as electricity, hydraulic pressure, pneumatic pressure, or gas.

Most machineries keep their energy isolation devices in an off position to shut down hazardous energy sources.

An OSHA-compliant LOTO procedure helps you stay on top of total shutdown and safe release of hazardous energy sources.

A successful lockout tagout program is more than using protective hardware or materials like padlocks, tags, and lockout devices.

OSHA-compliant LOTO programs require a written plan, comprehensive training, and effective communication between employees.

This article has everything you need to create one from scratch.

Why is LOTO important?

A solid lockout tagout program ensures workplace safety in occupational environments where workers come into direct contact with machinery or equipment.

OSHA imposes hefty fines on companies that fail to follow the OSHA lockout/tagout CFR 1910.147 standard, which is also one of the most commonly cited violations.

There’s also the human cost to consider when it comes to LOTO.

Craft workers, laborers, and machine operators face the most significant risk without the right hazardous energy release processes.

As a result, 3.4 per 100,000 full-time equivalent workers suffered from fatalities in 2020 alone.

Common hazardous energy-release injuries include burns, crush injuries, amputations, fractures, chemical exposure, lacerations, and electrical accidents or electrocution.

Servicing energized systems required specialized maintenance procedures, which often caused fatalities and injuries.

These incidents led to the American National Standards Institute (ANSI) publishing the first lockout/tagout guidance in 1982. The LOTO guidelines became an OSHA regulation in 1989.

OSHA also offers some guidance for lockout/tagout exceptions for cord and plug equipment and minor services.

However, the minor service exception doesn’t apply when a worker needs to put any body part in a danger zone or bypass a guard. In such cases, they should use long tools to protect their hands while reaching into machinery.

LOTO procedure vs. LOTO program

While many refer to LOTO procedures and LOTO programs interchangeably, they aren’t the same thing.

Think of a LOTO program and procedures like a preventive maintenance (PM) program and checklist. Like a PM program, a lockout tagout program helps you plan and ensure safety.

On the other hand, the lockout tagout procedure is like a preventive maintenance checklist offering ways to execute those plans.

Now, let’s understand lock-out tag-out devices in detail.

What are “lock out tag out” devices?

Lockout tagout devices protect workers from exposure to hazardous energy while servicing machinery and equipment.

Lockout devices such as blank flanges, padlocks, or bolted slip blind hold energy-isolating devices in a safe position and prevent equipment from energizing.

Tagout devices are warning devices that you fasten to energy-isolating devices. These devices tell you that you can’t operate equipment without removing the tagout device.

It's now time to look at the steps to perform the lock out and tag out procedure.

Steps to “lock out tag out”

Any routine or planned maintenance on equipment with moving parts must follow six lockout tagout steps to prevent unexpected energy release while servicing.

These steps include preparation, isolation, shutdown, lockout/tagout, stored energy check, and isolation verification.

1. Preparation includes understanding and investigating different hazardous energy sources in a machine or equipment. An authorized employee performs preparation to spot specific hazards and comes up with ways to control the energy.

2. Shut down requires you to power down the machine and disconnect the main power supply. This is the stage where you inform employees about equipment shutdown.

3. Isolation checks whether you have disconnected all energy sources. Different isolation activities include turning off the power, disengaging and blocking lines, closing valves, and blocking moving parts.

4. Lockout/tagout is where authorized employees attach locks and tags to energy-isolating devices. The goal is to ensure those devices stay off position and can’t be switched on during maintenance. Lockout device tags contain the authorized person’s name and contact info so anyone can reach out in case of questions.

5. Stored energy check double-checks if there’s still any stored or residual energy in equipment capacitors, springs, rotating flywheels, and hydraulic systems. This check confirms if it’s safe to perform filter press maintenance. The authorized personnel generally relieve, restrain, or disconnect stored hazardous energies at this stage.

6. Isolation verification is the final stage, where you ensure that the machine is shut down, isolated from the power source, checked for residual energies, and has start-up components locked out. Again, this stage ensures you’ve correctly followed all processes and are ready to perform maintenance.

While site-specific LOTO policies may differ but include all these steps, the next step is to build a safe LOTO procedure.

Building the right LOTO Procedure

Building the right LOTO procedure doesn’t have to be too difficult.

Add these steps to your LOTO process to get started.

Step 1: Prepare for the shutdown. Preparation includes training employees about hazardous energy sources and the means to control them.

Step 2: Notify employees. Communicate equipment shutdown to all affected employees over the radio or during a physical debrief. This communication about lockout initiates the LOTO procedure.

Step 3: Shut down equipment. Turn off the machinery following the O&M manual or equipment-specific process.

Step 4: Add LOTO devices to energy sources once you isolate energy sources. Authorized employees add lockout devices to machinery and add tags that explain who locked it, when, and why.

Step 5: Control stored energy, such as capacitors that can store electrical charge or compressed springs with stored mechanical energy.

Step 6: Verify lockout—Double-check hazardous energy source isolation at this stage.

Step 7: Maintain lockout to keep equipment locked until you can safely restore service.

Step 8: Follow LOTO release protocols. Test all machinery and remove all lockout devices before removing lockout devices from machinery. Also, communicate with the authorized person about the LOTO removal. Lastly, don’t forget to inform employees about the ready-to-use status of equipment.

LOTO Procedures in 2022

In 2022, all industries are moving toward ensuring worker safety with written lockout instructions, employee training, and periodic lockout procedure inspection.

Start by getting buy-in from stakeholders before you write your LOTO policy and procedures.

Then, once you buy lockout tagout kits and devices, conduct training at all levels, i.e., authorized, awareness, and affected levels.

Finally, commit to continuous improvement with regular updates and annual audits.

Achieve safety and productivity with CMMS

Creating a safe facility is easier with a computerized maintenance management system (CMMS). CMMS software like Facilio helps you streamline maintenance tasks, protect assets, and keep your facility safe.

Wondering how a CMMS can help? Get on a no-obligation personalized demo today.