LOTO Procedure Requirements and Best Practices
Last month, we dove into the scope and application of OSHA's Control of Hazardous Energy Standard, also known as the lockout tagout (LOTO) standard. We discussed whom the lockout tagout standard applies to and does not apply to, and what activities and operations are and are not covered. This month we will discuss the lockout tagout standard's purpose and the core components of the energy control program, focusing on energy control procedures.
Purpose
The purpose of OSHA’s Control of Hazardous Energy Standard is to prevent injuries to employees who perform servicing and maintenance activities due to unexpected start-up or release of stored energy. To prevent injury, the employer must create an energy control program. The energy control program’s goal is to ensure that before any employee performs servicing or maintenance on equipment, the machine or equipment is isolated from the energy source and made inoperative. This applies to machinery where there is the potential for unexpected energization, start-up, or the release of stored energy. Energy could range from electrical, to hydraulic, to gravity.
What are the Core Elements of the Energy Control Program?
The energy control program must include machine-specific procedures on controlling energy, employee training, and periodic inspections. The three main elements of the standard ensure that the machines are isolated from their energy sources and are considered safe to prevent injury before maintenance is performed.
Energy Control Procedure Requirements
Each piece of equipment should have its own written LOTO procedure. Energy control procedures must be created and should document the specific detailed information that an authorized employee must know to successfully lockout a piece of machinery or equipment to ensure it is safe before working on it. The procedures must include the scope, purpose, authorization, rules, and techniques to control hazardous energy and the means to enforce compliance.
At a minimum, the procedures must include:
· a specific statement of the intended use of the procedure
· specific steps in procedure form to properly shut down, isolate, block, and secure machines or equipment to control hazardous energy
· specific steps in procedure form for the placement, removal, and transfer of lockout tagout devices, and a description of who has a responsibility for them
· specific requirements for testing a machine or piece of equipment to determine and verify the effectiveness of the lockout tagout devices to ensure that the machine can not function
There are limited situations when the documentation of procedures are not required, and those specifics can be found here.
Best Practices for Successful LOTO Procedures
Add machine-specific photos where the authorized employee must use a lockout device
Be specific about which type of LOTO device should be used for each energy type. If the employee is locking out compressed air on a ball valve, add that a lock, tag, and and ball valve LOTO device will be needed.
Make the procedure easy to read with step-by-step steps in numerical order so nothing is forgotten. In my experience, the most forgotten part of the procedure is to ensure that the affected employees (the daily operators) have been notified that the authorized employee (the person trained to lockout machinery) is going to work on the machinery. This is an important step in the process and must not be forgotten!
Always be specific about how the employee should verify that the energy on the machine has been properly shut down, isolated, blocked, or secured. Is it pressing the start button and controls on the machinery to ensure it does not function? Is it checking a gauge to ensure the pressure reads 0? Be specific!
Employee Training
Employee training and retraining, along with additional training under a tagout system, ensure that the employee understands the purpose and function of the energy control program.
Periodic inspections
Periodic inspections of the energy control procedures ensure that the standard's guidelines and requirements are followed.
Next month, we will discuss employee training and periodic inspections in much more detail!
We are here to help!
If you need assistance developing your company's LOTO procedures, 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 developing lockout procedures for a 500,000 square foot building with over 200 pieces of equipment.
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).
