LOTO Training and Periodic Inspections
Over the past two months, we have discussed OSHA’s Control of Hazardous Energy Standard’s (also known as Lockout Tagout) applicability, scope, and energy control procedures best practices. This week, we will discuss two more crucial elements of a successful Lockout Tagout (LOTO) program; employee training and periodic inspections.
Employee Training
Employee training and retraining ensures that the purpose, function, and responsibilities of the energy control programs are understood. Training will allow employees to learn the knowledge and skills necessary for the safe application, use, and removal of the energy controls.
The Control of Hazard Energy Standard requires different levels of training for the three categories of employees; authorized, affected, and other employees.
Authorized employees (a person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment, usually maintenance employees) must receive training on how to recognize hazardous energy sources, the type and magnitude of the energy of the machinery they will be performing lockout on, and the methods necessary for energy isolation and control.
Affected employees (an employee whose job requires them to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires them to work in an area in which servicing or maintenance is being performed, usually the operator of a machine) must receive training on the purpose and use of the energy control procedures.
Other employees (those whose work activities are or could be in an area where energy control procedures may be utilized) must be instructed about the procedure and about the prohibition relating to attempts to restart or reenergize machines or equipment that are locked out or tagged out.
If a tagout system is implemented, there must be additional training.
Employee Retraining
Retraining must be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment, or processes that present a new hazard, or when there is a change in the energy control procedures. Additional retraining must also be conducted whenever a periodic inspection reveals that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures.
The retraining must reestablish employee competence, skill, and introduce new or revised control methods and procedures. The employer should certify that employee training has been completed and is being kept up to date. The certification must contain each employee's name and dates of training.
An authorized employee is using a lock and tag to lock out compressed air.
Periodic Inspections
Periodic inspections are another key component of a company’s LOTO program. Periodic inspections ensure that energy control procedures (or LOTO procedures) continue to be implemented properly, that the employees are familiar with their responsibilities, and that any deviations or procedural inadequacies that are observed are corrected.
Periodic inspections must take place at least annually by an authorized person not involved in the energy control procedure being inspected.
Basically, an authorized person (the inspector) familiar with the LOTO procedure will observe another authorized person perform the LOTO procedure to ensure it is properly followed and that the procedure is correct. The authorized employees must identify any deficiencies or deviations and correct them. For example, if the LOTO procedure does not identify gravity as a source of energy, but the machine requires that part of the machine is to be locked and blocked in the “up” position to prevent it from falling after compressed air and the electrical is turned off, the LOTO procedure must be corrected to add the energy source of gravity. This would be an inadequacy found from the periodic inspection. Retraining would also have to occur because of a change in a LOTO procedure.
Where lockout is used, and in addition to the observation, the inspector must review each authorized employee's responsibilities under the LOTO procedure with that employee. Group meetings are acceptable for the responsibility review.
If lockout is not used on a machine and tagout is used instead, the inspector must review both the authorized and affected employee's responsibilities with those employees for the LOTO procedure being inspected, and the additional training responsibilities associated.
After the periodic inspection is completed, the employer must certify that the periodic inspection has been performed. The documented certification must:
• Identify the machine on which the LOTO procedure was observed for the periodic inspection
• The date of the periodic inspection
• Identify the authorized employee included in the inspection
• Identify the authorized person who performed the inspection
We are here to help!
If you need assistance developing your company's LOTO training program or periodic inspections, complete our contact form, and we will be in touch. Brandy Bossle, CSP and founder of Triangle Safety Consulting, created a successful LOTO program that included periodic inspections and an effective training program for over 100 authorized employees.
This blog was written by Triangle Safety Consulting’s President, and CEO, Brandy Bossle, CSP.
