Common Compliance Deficiencies with the OSHA Control of Hazardous Energy (Lockout/Tagout) Requirements

1.     OSHA standard 29 CFR 1910.147(c)(4)(i)* requires that equipment-specific LOTO procedures be developed for each piece of equipment that has more than one energy source (electric, hydraulic, pneumatic, and/or stored energy). APTIM’s experience is that most facilities either don’t have these equipment-specific procedures or they don’t have procedures for all equipment that has more than one energy source. An example of a piece of equipment where an equipment-specific procedure hasn’t been developed is an air compressor which has two energy sources (pneumatic and electric). Alternatively, meeting any one of the exceptions below does not require equipment-specific LOTO procedures:

• The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut-down which could endanger employees
• The machine or equipment has a single energy source which can be readily identified and isolated
• The isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment
• The machine or equipment is isolated from that energy source and locked out during servicing or maintenance
• A single lockout device will achieve a locked-out condition
• The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance
• The servicing or maintenance does not create hazards for other employees, and
• The employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

2.     OSHA standard 29 CFR 1910.147(c)(6)(i)* requires the employer to “conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed”. Many employers think that this means reviewing the LOTO written procedure to ensure that it is still accurate. While this is part of the requirement, it doesn’t meet all requirements of this rule. There is also a requirement that “the annual inspection include a review between an inspector and each authorized employee (those who perform LOTO) of that employee’s responsibilities under the energy control procedure being inspected”. The inspector must be an authorized employee that has not been involved with the LOTO of the equipment being evaluated. The annual review is normally accomplished by the maintenance supervisor or safety and health manager who perform the annual reviews of all authorized employees when they are performing a LOTO to ensure they are doing it properly and following the equipment-specific procedure. Note: There must be certifications that the periodic inspections have been performed. Each certification must identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspections, the employee(s) included in the inspection, and the person performing the inspection.

3.     OSHA standard 29 CFR 1910.147(c)(7)(i)(b)* requires that “each affected employee shall be instructed in the purpose and use of the energy control procedure”. An “affected employee” is defined as “an employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed”. Most employers provide training to the “authorized employees” but do not realize that “affected employees” must be trained also.

APTIM has written numerous equipment-specific LOTO procedures and has performed annual inspections of authorized employees for many employers. For more information on LOTO, contact Harry Pullum, CIH, CSP, CIAQP, at harry.pullum@aptim.com.

*This requirement is applicable for all states but may be a different regulation number in some states that have their own approved OSHA program. For example, the California OSHA (Cal-OSHA) regulation number is T8 CCR 3314.