Controlling Hazardous Energy

Wisconsin Lockout/Tagout: What you need to know

Comparison: State vs Federal

Wisconsin does not have a federally approved occupational safety and health regulatory program for the state; therefore, private sector workplaces must comply with federal occupational safety and health standards.

Wisconsin's safety and health rules govern public sector (state and local government offices and operations) workplaces. The state has adopted the federal lockout/tagout rules by reference (SPS 332.50).

The U.S. Department of Labor/Occupational Safety and Health Administration (OSHA) administers and enforces federal workplace safety and health requirements in private sector workplaces. The Wisconsin Department of Safety and Professional Services (DSPS) administers the state workplace safety and health rules for public sector workplaces.

Lockout-tagout (LOTO) or lock and tag is a safety procedure which is used in industry and research settings to ensure that dangerous machines are properly shut off and not able to be started up again prior to the completion of maintenance or servicing work.

Employees must be protected from unexpected startup of equipment, or release of hazardous energy. Lockout Tagout is a system used to isolate employees from these hazards while performing work.

To comply with (OSHA Lockout Tagout Regulations: 29 CFR 910.147 - The control of hazardous energy ) Lockout Tagout requirements, employers must:

Create equipment specific lockout tagout procedures.
Provide locks and tags to employees.
Train employees on the safe and proper use of lockout tagout.
Create a company Energy Control Program.

What are OSHA's requirements? OSHA's standard establishes minimum performance requirements for controlling hazardous energy. The standard specifies that employers must establish an energy-control program to ensure that employees isolate machines from their energy sources and render them inoperative before any employee services or maintains them.

As part of an energy-control program, employers must:

Establish energy-control procedures for removing the energy supply from machines and for putting appropriate lockout or tagout devices on the energy-isolating devices to prevent unexpected reenergization. When appropriate, the procedure also must address stored or potentially reaccumulated energy;
Train employees on the energy-control program, including the safe application, use, and removal of energy controls; and
Inspect these procedures periodically (at least annually) to ensure that they are being followed and that they remain effective in preventing employee exposure to hazardous energy.

If employers use tagout devices on machinery that can be locked out, they must adopt additional measures to provide the same level of employee protection that lockout devices would provide. Within the broad boundaries of the standard, employers have the flexibility to develop programs and procedures that meet the needs of their inpidual workplaces and the particular types of machines being maintained or serviced. What must an energy-control procedure include? Employers must develop, document, and use procedures to control potentially hazardous energy.3 The procedures explain what employees must know and do to control hazardous energy effectively when they service or maintain machinery. If this information is the same for the various machines used at a workplace, then a single energy-control procedure may suffice. For example, similar machines (those using the same type and magnitude of energy) that have the same or similar types of control measures can be covered by a single procedure. Employers must develop separate energy-control procedures if their workplaces have more variable conditions such as multiple energy sources, different power connections, or different control sequences that workers must follow to shut down various pieces of machinery. The energy-control procedures must outline the scope, purpose, authorization, rules, and techniques that employees will use to control hazardous energy sources, as well as the means that will be used to enforce compliance. These procedures must provide employees at least the following information:

A statement on how to use the procedures;
Specific procedural steps to shut down, isolate, block, and secure machines;
Specific steps designating the safe placement, removal, and transfer of lockout/tagout devices and identifying who has responsibility for the lockout/tagout devices; and
Specific requirements for testing machines to determine and verify the effectiveness of lockout devices, tagout devices, and other energy-control measures.

What must workers do before they begin service or maintenance activities? Before beginning service or maintenance, the following steps must be accomplished in sequence and according to the specific provisions of the employer's energy-control procedure:

Prepare for shutdown;
Shut down the machine;
Disconnect or isolate the machine from the energy source(s);
Apply the lockout or tagout device(s) to the energy-isolating device(s);
Release, restrain, or otherwise render safe all potential hazardous stored or residual energy. If a possibility exists for reaccumulation of hazardous energy, regularly verify during the service and maintenance that such energy has not reaccumulated to hazardous levels; and
Verify the isolation and deenergization of the machine.

What must workers do before they remove their lockout or tagout device and reenergize the machine? Employees who work on deenergized machinery may be seriously injured or killed if someone removes lockout/tagout devices and reenergizes machinery without their knowledge. Thus, it is extremely important that all employees respect lockout and tagout devices and that only the person(s) who applied these devices remove them. Before removing lockout or tagout devices, the employees must take the following steps in accordance with the specific provisions of the employer's energy-control procedure:

Inspect machines or their components to assure that they are operationally intact and that nonessential items are removed from the area; and
Check to assure that everyone is positioned safely and away from machines.

After removing the lockout or tagout devices but before reenergizing the machine, the employer must assure that all employees who operate or work with the machine, as well as those in the area where service or maintenance is performed, know that the devices have been removed and that the machine is capable of being reenergized. (See Sections 6(e) and (f) of 29 CFR Part 1910.147 for specific requirements.) In the rare situation in which the employee who placed the lockout/tagout device is unable to remove that device, another person may remove it under the direction of the employer, provided that the employer strictly adheres to the specific procedures outlined in the standard. (See 29 CFR 1910.147(e)(3).) When do I use lockout and how do I do it? You must use a lockout program (or tagout program that provides a level of protection equal to that achieved through lockout) whenever your employees engage in service or maintenance operations on machines that are capable of being locked out and that expose them to hazardous energy from unexpected energization, startup, or release of stored energy. The primary way to prevent the release of hazardous energy during service and maintenance activities is by using energy-isolating devices such as manually operated circuit breakers, disconnect switches, and line valves and safety blocks. Lockout requires use of a lock or other lockout device to hold the energy-isolating device in a safe position to prevent machinery from becoming reenergized. Lockout also requires employees to follow an established procedure to ensure that machinery will not be reenergized until the same employee who placed the lockout device on the energy-isolating device removes it. How can I determine if the energy-isolating device can be locked out? An energy-isolating device is considered "capable of being locked out" if it meets one of the following requirements:

Is designed with a hasp or other part to which you can attach a lock such as a lockable electric disconnect switch;
Has a locking mechanism built into it; or
Can be locked without dismantling, rebuilding, or replacing the energy-isolating device or permanently altering its energy-control capability, such as a lockable valve cover or circuit breaker blockout.

What do I do if I cannot lock out the equipment? Sometimes it is not possible to lock out the energy-isolating device associated with the machinery. In that case, you must securely fasten a tagout device as close as safely possible to the energy-isolating device in a position where it will be immediately obvious to anyone attempting to operate the device. You also must meet all of the tagout provisions of the standard. The tag alerts employees to the hazard of reenergization and states that employees may not operate the machinery to which it is attached until the tag is removed in accordance with an established procedure. What other options do I have? If it is possible to lock out an energy-isolating device, employers must use lockout devices unless they develop, document, and use a tagout procedure that provides employees with a level of protection equal to that provided by a lockout device. In a tagout program, an employer can attain an equal level of protection by complying with all tagout-related provisions of the standard and using at least one added safety measure that prevents unexpected reenergization. Such measures might include removing an isolating circuit element, blocking a controlling switch, opening an extra disconnecting device, or removing a valve handle to minimize the possibility that machines might inadvertently be reenergized while employees perform service and maintenance activities. When can tagout devices be used instead of lockout devices? When an energy-isolating device cannot be locked out, the employer must modify or replace the energy-isolating device to make it capable of being locked out or use a tagout system. Whenever employers significantly repair, renovate, or modify machinery or install new or replacement machinery, however, they must ensure that the energy-isolating devices for the machinery are capable of being locked out. Tagout devices may be used on energy-isolating devices that are capable of being locked out if the employer develops and implements the tagout in a way that provides employees with a level of protection equal to that achieved through a lockout system. When using a tagout system, the employer must comply with all tagout-related provisions of the standard and train employees in the limitations of tags, in addition to providing normal hazardous energy control training for all employees. What are the limitations of tagout devices? A tagout device is a prominent warning that clearly states that the machinery being controlled must not be operated until the tag is removed in accordance with an established procedure. Tags are essentially warning devices and do not provide the physical restraint of a lock. Tags may evoke a false sense of security. For these reasons, OSHA considers lockout devices to be more secure and more effective than tagout devices in protecting employees from hazardous energy. What are the requirements for lockout/tagout devices? Whether lockout or tagout devices are used, they must be the only devices the employer uses in conjunction with energy-isolating devices to control hazardous energy. The employer must provide these devices and they must be singularly identified and not used for other purposes. In addition, they must have the following characteristics:

Durable enough to withstand workplace conditions. Tagout devices must not deteriorate or become illegible even when used with corrosive components such as acid or alkali chemicals or in wet environments.
Standardized according to color, shape, or size. Tagout devices also must be standardized according to print and format. Tags must be legible and understandable by all employees. They must warn employees about the hazards if the machine is energized, and offer employees clear instruction such as: "Do Not Start," "Do Not Open," "Do Not Close," "Do Not Energize," or "Do Not Operate."
Substantial enough to minimize the likelihood of premature or accidental removal. Employees should be able to remove locks only by using excessive force with special tools such as bolt cutters or other metal-cutting tools. Tag attachments must be non-reusable, self-locking, and non-releasable, with a minimum unlocking strength of 50 pounds. Tags must be attachable by hand, and the device for attaching the tag should be a one-piece nylon cable tie or its equivalent so it can withstand all environments and conditions.
Labeled to identify the specific employees authorized to apply and remove them.

What do employees need to know about lockout/tagout programs? Training must ensure that employees understand the purpose, function, and restrictions of the energy-control program. Employers must provide training specific to the needs of "authorized," "affected," and "other" employees. "Authorized" employees are those responsible for implementing the energy-control procedures or performing the service or maintenance activities. They need the knowledge and skills necessary for the safe application, use, and removal of energy-isolating devices. They also need training in the following:

Hazardous energy source recognition;
The type and magnitude of the hazardous energy sources in the workplace; and
Energy-control procedures, including the methods and means to isolate and control those energy sources.

"Affected" employees (usually machine operators or users) are employees who operate the relevant machinery or whose jobs require them to be in the area where service or maintenance is performed. These employees do not service or maintain machinery or perform lockout/tagout activities. Affected employees must receive training in the purpose and use of energy-control procedures. They also need to be able to do the following:

Recognize when the energy-control procedure is being used,
Understand the purpose of the procedure, and
Understand the importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked or tagged out.

All other employees whose work operations are or may be in an area where energy-control procedures are used must receive instruction regarding the energy-control procedure and the prohibition against removing a lockout or tagout device and attempting to restart, reenergize, or operate the machinery. When is training necessary? The employer must provide initial training before starting service and maintenance activities and must provide retraining as necessary. In addition, the employer must certify that the training has been given to all employees covered by the standard. The certification must contain each employee's name and dates of training. Employers must provide retraining for all authorized and affected employees whenever there is a change in the following:

Job assignments,
Machinery or processes that present a new hazard, or
Energy-control procedures.

Retraining also is necessary whenever a periodic inspection reveals, or an employer has reason to believe, that shortcomings exist in an employee's knowledge or use of the energy-control procedure. What if I need power to test or position machines, equipment, or components? OSHA allows the temporary removal of lockout or tagout devices and the reenergization of the machine only in limited situations for particular tasks that require energization—for example, when power is needed to test or position machines, equipment, or components. However, this temporary exception applies only for the limited time required to perform the particular task requiring energization. Employers must provide effective protection from hazardous energy when employees perform these operations.

The following steps must be performed in sequence before reenergization:

Clear tools and materials from machines.
Clear employees from the area around the machines.
Remove the lockout or tagout devices as specified in the standard.
Energize the machine and proceed with testing or positioning.
Deenergize all systems, isolate the machine from the energy source, and reapply energy-control measures if additional service or maintenance is required.

The employer must develop, document, and use energy-control procedures that establish a sequence of actions to follow whenever reenergization is required as a part of a service or maintenance activity, since employees may be exposed to significant risks during these transition periods. What if I use outside contractors for service or maintenance procedures? If an outside contractor services or maintains machinery, the onsite employer and the contractor must inform each other of their respective lockout or tagout procedures. The onsite employer also must ensure that employees understand and comply with all requirements of the contractor's energy-control program(s). What if a group performs service or maintenance activities? When a crew, department, or other group performs service or maintenance, they must use a procedure that provides all employees a level of protection equal to that provided by a personal lockout or tagout device. Each employee in the group must have control over the sources of hazardous energy while he or she is involved in service and maintenance activities covered by the standard. Personal control is achieved when each authorized employee affixes a personal lockout/tagout device to a group lockout mechanism instead of relying on a supervisor or other person to provide protection against hazardous energy. Detailed requirements of inpidual responsibilities are provided in 29 CFR 1910.147(f)(3)(ii)(A) through (D). Appendix C of OSHA Directive STD 1-7.3, 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout)-Inspection Procedures and Interpretive Guidance, (September 11, 1990), provides additional guidance. What if a shift changes during machine service or maintenance? Employers must make sure that there is a continuity of lockout or tagout protection. This includes the orderly transfer of lockout or tagout device protection between outgoing and incoming shifts to control hazardous energy. When lockout or tagout devices remain on energy-isolation devices from a previous shift, the incoming shift members must verify for themselves that the machinery is effectively isolated and deenergized. How often do I need to review my lockout/tagout procedures? Employees are required to review their procedures at least once a year to ensure that they provide adequate worker protection. As part of the review, employers must correct any deviations and inadequacies identified in the energy-control procedure or its application.

What does a review entail? The periodic inspection is intended to assure that employees are familiar with their responsibilities under the procedure and continue to implement energy-control procedures properly. The inspector, who must be an authorized person not involved in using the particular control procedure being inspected, must be able to determine the following:

Employees are following steps in the energy-control procedure;
Employees involved know their responsibilities under the procedure; and
The procedure is adequate to provide the necessary protection, and what changes, if any, are needed.

For a lockout procedure, the periodic inspection must include a review of each authorized employee's responsibilities under the energy-control procedure being inspected. Where tagout is used, the inspector's review also extends to affected employees because of the increased importance of their role in avoiding accidental or inadvertent activation of the machinery. In addition, the employer must certify that the designated inspectors perform periodic inspections. The certification must specify the following: