Occupational Safety and Health Administration Standard 1910.147, commonly known as lockout/tagout, is designed to protect workers from the sudden, unexpected start up of machines or equipment or the release of stored energy during servicing or maintenance work. In a nutshell, when fixing a piece of equipment, workers should turn it off and lock the ignition mechanism to prevent it from starting up until the maintenance work is done.
Following 1910.147 is fairly straightforward, yet it’s among OSHA’s most-cited violations every year. Here, we explain the need for the control of hazardous energy (lockout/tagout) standard, discuss the sections of the standard that employers are not following, and offer tips to ensure lockout/tagout is top-of-mind at your company.
You might like: The Future of Worker Safety in Utilities
Hazardous energy and its harmful effects
According to OSHA, electrical, mechanical, hydraulic, pneumatic, chemical, and thermal machines or equipment can be hazardous to workers when energy is not properly controlled during maintenance activities. An unexpected startup or release of stored energy can cause electrocution, burns, crushing, cutting, lacerating, amputating, fractured body parts, or even death.
For example, workers who are repairing a downstream connection in the piping of a steam valve could be injured if the valve is suddenly turned on. Another example, a worker who is repairing a jammed conveyor system could be crushed if the system suddenly releases.
As these examples illustrate, the most at-risk workers for lockout/tagout injuries are those who routinely service equipment. However, non-maintenance workers can be injured if they are near a piece of equipment during a sudden release of hazardous energy. Following OSHA standard 1910.147 is the best way to protect all workers from injuries related to lockout/tagout.
Most common lockout/tagout violations
In 2019, lockout/tagout ranked fourth on the list of top OSHA violations, according to Safety and Health Magazine. In total, 2,975 violations were given to companies, marking an increase from 2,923 in 2018.
The most commonly cited sections of 1910.147 include the following.
1. Energy control procedure
At 878 violations, 1910.147(c)(4) was the most common reason for citations in 2019. This section discusses procedures that must be developed, documented, and used to control potentially hazardous energy when workers are conducting activities that require lockout/tagout.
Read: Protective Measures for Common Electrical Safety Hazards
2. Training and communication
Despite the importance of lockout/tagout training, many employers don’t take it seriously enough. OSHA standard 1910.147(c)(7) requires employers provide training to ensure workers understand the energy control program and have the skills needed to safely apply, use, and remove any energy controls acquired.
3. Periodic inspection
Per 1910.147(c)(6), employers are required to conduct inspections of their energy control procedures at least once per year to ensure they’re being followed and to correct any deviations or inadequacies. OSHA issued 500 violations for this section in 2019.
4. Energy control program
1910.147(c)(1) is the general description for an energy control program. The section reads: “The employer shall establish a program consisting of energy control procedures, employee training, and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup, or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.” OSHA inspectors issued 300 violations of this section in 2019.
5. Application control
Section 1910.147(d) outlines the actions employers must take when a piece of equipment is being locked/tagged out. The section covers:
- Preparation for shutdown
- Machine or equipment shutdown
- Lockout/tagout device application
- Stored energy
- Verification of isolation
4 ways to ensure lockout/tagout procedures are followed
Injuries that result from not following the lockout/tagout standard are entirely preventable. Use the following tips to tighten up your procedures and make sure they’re fully enforced.
1. Set standards for maximum compliance
Workers commonly violate lockout/tagout procedures because employers don’t take them seriously enough. If your standards are aimed at doing the minimum to comply with OSHA regulations, this sets the tone that lockout/tagout is not important.
It’s a manager’s job to lead by example. Setting your team up to reach maximum compliance makes it clear you’re fully invested in worker safety. This attitude will help workers realize a lower level of risk, while increasing efficiency.
Look: 7 Ways to be More Proactive About Worker Safety
2. Provide thorough training (and retraining)
If workers are asking, “What is lockout/tagout?,” it’s clear training efforts have fallen far short of requirements.
OSHA requires employers train both authorized and affected employees. Authorized employees are responsible for putting locks in place, while affected employees are people nearby during a lockout. It’s essential everyone knows what to do in an emergency situation because proper training can be the difference between life and death.
Both authorized and affected workers should be trained before starting work at your company. It’s also important to provide periodic retraining to ensure this information is fresh in workers’ minds.
Watch: How to Create a Safety-First Culture
3. Conduct regular inspections
As previously noted, OSHA requires companies to inspect their energy control procedure at least annually. Doing so allows them to ensure workers are adhering to the procedure and the requirements of the standard.
This is crucial because, without these audits, you don’t know if your energy control procedure is being followed or if it’s up-to-date. Employee turnover, new equipment, and potentially rusty skill sets can lead to errors.
Holding periodic inspections helps minimize risk by allowing you to catch safety issues before an incident occurs. Make the necessary corrections immediately whenever you find holes in the system.
4. Create a hazardous energy control program
OSHA requires employers to have a hazardous energy control program, so if you don’t, it’s time to craft one. It should cover all the bases, including energy control procedures, employee training, and periodic inspections.
Putting your energy control program in writing gives both the managerial team and employees something to reference. Formalizing the program gets everyone on the same page, so there’s no grey area regarding your lockout/tagout procedures.
It might not seem important to lock and tag a piece of equipment before working on it, but accidents happen, and life-altering injuries can occur. If your team isn’t familiar with OSHA’s lockout/tagout standard, now is the time to take action. Familiarize yourself with OSHA’s lockout/tagout standard to ensure your company is in compliance, and schedule a session on the importance of lockout/tagout on your training calendar pronto.
For more safety management content, check out the blog “How to Combat Risk Normalization.”