Lockout / Tagout: Program vs. ProceduresDid you know that the Control of Hazardous Energy (Lockout/Tagout) consistently ranks in OSHA’s Top 10 Most Frequently Cited Standards? In 2006 it was ranked #7. In 2014 it was ranked #6. In 2015 it was ranked #4. And, according the OSHA’s Control of Hazardous Energy Webpage, the “Failure to control hazardous energy accounts for nearly 10 percent of the serious accidents in many industries.”
It seems that there is a misperception among the OSHA regulated community that employers only need to a create and implement a Lockout/Tagout (LOTO) Program but they do not need to develop a LOTO procedure for each piece of equipment. |
OSHA’s Energy Control Program (Lockout/Tagout) is outlined in 29 CFR 1910.147. Confusion about these requirements appears to be common, so much so that OSHA created a Lockout/Tagout HOT Topics webpage. When you click on the “Energy Control Program,” it links you to three elements, one of which is called “Specific Procedures for Energy Control and Control Circuitry Prohibition.”
Here it states:
Here it states:
“Employers must develop, document, and implement energy control procedures to control potentially hazardous energy and render equipment or machinery inoperative whenever employees perform activities covered by the Lockout/Tagout standard. The energy control procedure provides the authorized employee with written instructions specifying how to eliminate the potential for the unexpected activation, or start up of machinery or equipment or the release of stored energy.”
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One could argue that this paragraph doesn’t specifically say that each piece of equipment must have it’s own written procedure. But the paragraph uses the plural of the word procedure, indicating that more than one procedure is necessary.
So, continue reading and use a little deductive reasoning.
The next paragraphs on the webpage provide the details needed in the procedures:
So, continue reading and use a little deductive reasoning.
The next paragraphs on the webpage provide the details needed in the procedures:
"The energy control procedures must outline the scope, purpose, authorization, rules, and techniques that will be used to control hazardous energy, and the means that will be used to enforce compliance. The energy control procedures must identify the type and magnitude of the hazardous energy and the means and methods that will be used to protect employees during servicing or maintenance operations. The energy control procedure must identify the machine(s) or equipment on which the procedure is to be used. This will ensure that the authorized employee implements the appropriate energy control procedure for the equipment or machine to be serviced or maintained. Employers are required to address within the energy control procedures the sequential steps necessary to shut down, isolate, block, and secure machines or equipment. Sequential steps for placing, removing, and transferring lockout/tagout devices are also required." |
These requirements are outlined in the Standard here (1910.147(c)(4)(ii). And although the regulation does not specifically use the words “machine-specific procedures,” it does use the term “specific” many times in relation to procedures:
It would be a rare occasion when all of the equipment in a machine shop, factory, or bottling facility would have the exact same sequential steps for isolating energy and/or shutting down all of the equipment. |
Then the Website finally states, “If energy control procedures are the same for various pieces of equipment or machines, or if the equipment or machines can be grouped in another logical manner, then a single energy control procedure may be sufficient.” So it is looking like multiple procedures are a necessity.
OSHA Instructions to its Inspectors
OSHA Instruction, Directive Number: CPL 02-00-147 (effective February 11, 2008), The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures, says it the best:
OSHA Instruction, Directive Number: CPL 02-00-147 (effective February 11, 2008), The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures, says it the best:
“Energy control procedures are the cornerstone of the LOTO standard because they provide employees the guidance necessary to effectively and safely control hazardous energy when they service or maintain machinery or equipment.”
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I could not have said it any better. Procedures need to be detailed so employees can do their jobs – safely. The directive also states that procedures are performance oriented and has a long section on what constitutes “necessary information.” I leave that for you to read, see pp 3-39 to 3-48 of the Directive.
I do want to point out that OSHA inspectors are instructed to “evaluate an employer’s energy control procedures to determine whether each procedure provides enough detailed information and guidance for an authorized employee to understand how to safety and effectively utilize energy control measures when servicing each machine covered by the procedure.”
I also want to point out that OSHA is aware of the debate between a program type procedure and machine-specific procedures. Here is what OSHA says:
I do want to point out that OSHA inspectors are instructed to “evaluate an employer’s energy control procedures to determine whether each procedure provides enough detailed information and guidance for an authorized employee to understand how to safety and effectively utilize energy control measures when servicing each machine covered by the procedure.”
I also want to point out that OSHA is aware of the debate between a program type procedure and machine-specific procedures. Here is what OSHA says:
“OSHA recognizes that some employers choose to develop "machine-specific" energy control procedures for individual machines or pieces of equipment because this approach provides an optimum level of detail, enhancing overall employee safety during servicing operations.”
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OSHA applauds this method because it is the best way to make sure employees know how to do what they need to do. But, OSHA also states,
“In order not to discourage this practice, employers who develop energy control procedures for individual machines still may group same or similar individual machine/equipment procedures for periodic inspection purposes.”
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However, OSHA recognizes that, while in many cases an employer will be able to develop a single energy control procedure applicable to all machines and equipment in a facility, an employer may be required to develop more than one procedure when variations in machine types, energy sources, or energy control methods mandate additional specificity in order to permit employees to effectively isolate hazardous energy and safely perform servicing/maintenance activities.
So there you have it. It is the intent of this regulation that each piece of equipment (or at a minimum a group of like equipment) is required to have a “machine-specific-like” Lockout/Tagout procedure. The symantics do not matter. Employers must provide written procedures to employees, and the likelihood that one procedure will cover all machines and equipment is very very low.
Effort Needed for Procedures
Yes, creating multiple procedures can be a lot of work and it can be time consuming. But, the health and welfare of your employees is depending on accurate, easy-to-understand procedures that everyone involved uses – every time.
Conclusion
This article is written a little tongue-in-cheek. But in all seriousness, employers are required to have both – an overall program that describes how it will implement energy control at its facility and procedures, whether that is a single procedure for each piece of equipment or multiple procedures that cover several pieces of equipment, that contain all the specific details of controlling the energy for each piece of equipment.
So there you have it. It is the intent of this regulation that each piece of equipment (or at a minimum a group of like equipment) is required to have a “machine-specific-like” Lockout/Tagout procedure. The symantics do not matter. Employers must provide written procedures to employees, and the likelihood that one procedure will cover all machines and equipment is very very low.
Effort Needed for Procedures
Yes, creating multiple procedures can be a lot of work and it can be time consuming. But, the health and welfare of your employees is depending on accurate, easy-to-understand procedures that everyone involved uses – every time.
Conclusion
This article is written a little tongue-in-cheek. But in all seriousness, employers are required to have both – an overall program that describes how it will implement energy control at its facility and procedures, whether that is a single procedure for each piece of equipment or multiple procedures that cover several pieces of equipment, that contain all the specific details of controlling the energy for each piece of equipment.