LOTO Standard FAQs on Scope and Application

The Lockout/Tagout standard found at 1910.147, also known as LOTO or the Control of Hazardous Energy, requires implementation of safe practices and procedures to shut down machinery, isolate it from its energy source or sources, and prevent the release of potentially hazardous energy while maintenance and servicing activities are being completed. It’s important for employers to be crystal clear on understanding who the LOTO standard applies to, and what activities are covered.

Below are frequently asked questions (FAQs) and answers about the lockout tagout standard's scope and application to help clarify who the LOTO standard does and does not apply to and what activities are and are not covered. Understanding the LOTO standard's applicability and what tasks apply to the LOTO standard is an essential first step for an effective Lockout Tagout Program.

A photo of a lock and tag on a lockout hasp on a disconnect switch.

FAQS

Question 1: Who does the Control of Hazardous Energy (LOTO) standard apply to?

This standard applies to workers in the general industry sector performing servicing or maintenance on machines or equipment. These workers are exposed to the unexpected energization, startup, or release of hazardous energy.

Under the standard, the term "unexpected" also covers situations in which the servicing or maintenance is performed during ongoing normal production operations if:

1. An employee is required to remove or bypass machine guards or other safety devices OR

2. An employee is required to place any part of their body into a point of operation or into a machine where work is completed or into the danger zone associated with the machine's operation.

Question 2: What activities are covered under the LOTO standard?

Any servicing or maintenance activities of machines when the source of energy is electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.

Examples include constructing, setting up, installing, inspecting, adjusting, modifying, maintaining, or servicing machines or equipment, including lubrication, cleaning or unjamming of machines. Another example includes performing adjustments or tool changes where employees could be exposed to the unexpected energization or startup of the equipment or release of hazardous energy.

Question 3: Who does the LOTO standard not apply to?

General Industry workers who perform servicing and maintenance on machines that are NOT exposed to the unforeseen energization or startup of the machines or the release of hazardous energy.

Question 4: What activities are not covered in the LOTO standard?

1. Servicing or maintenance of equipment performed during normal production operations if:

a. The safeguarding provisions of Subpart O and other applicable general industry standards are effective in preventing employee exposure to hazards created by the unexpected energization or startup of machines, or the release of energy

b. Minor tool changes and adjustments, and other minor servicing activities that take place during normal production operations which are routine, repetitive, and integral to the use of that production equipment, as long as workers are effectively protected by alternative measures which provide adequate machine safeguarding protection

2. Construction, agriculture, and maritime workers

3. Installations under the exclusive control of electric utilities for power generation, transmission, and distribution

4. Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations

5. Oil and gas well drilling and servicing

6. Work on cord and plug connected electrical equipment, if the equipment is unplugged from the energy source, and the authorized employee has exclusive control of the plug

7. Hot tap operations that involve transmission and distribution systems for gas, steam, water, or petroleum products on pressurized pipelines, if the continuous service is critical, the shutdown of the system is impractical, documented procedures are followed, and employees are effectively protected by special equipment

Next month, we will dive into the LOTO Standard more deeply, including the Purpose of the LOTO standard and the core elements.

This blog was written by Brandy Bossle, Triangle Safety Consulting LLC's Owner and Principal Consultant. She offers audits, expertise, resources, and guidance to help clients improve their site's safety program. She is a Certified Safety Professional (CSP) under the Board of Certified Safety Professionals (BCSP).