In today’s dynamic work environment, prioritizing the safety of your team is paramount to ensure optimal operational efficiency and your employees go home safely at the end of each day. If you are like similar companies in your industry, you already have a wide variety of safety “tools” in your “toolbox.”
- However, how well are those tools utilized and understood by your frontline supervisors and employees, especially around the control of hazardous energy?
- How do you ensure the program, training, and regulatory requirement(s) are being met, or exceeded, to guarantee gaps have been properly closed?
Let this article be your comprehensive guide, walking you through the common compliance gaps observed across all spectrums of industry as well as in OSHA’s infamous Top 10 citations.
From the fundamentals of a Hazardous Energy Control Program, training competent authorized/affected workers, to machine specific procedures for simple or complex industrial equipment. SEAM Group will help you address your queries about this crucial part of keeping the workplace safe with Lockout/Tagout (LOTO) training.
Understanding the Fundamentals of Hazardous Energy Control Program with LOTO Training
The purpose of a Hazardous Energy Control program serves as a cornerstone for safeguarding the well-being of workers during maintenance or servicing tasks involving machinery and/or equipment. Here is a breakdown of the fundamental components of the program:
Applicable Standards
There are a variety of regulations and standards that apply to the control of hazardous energy including, but not limited to:
- OSHA 29 CFR 1910.147
- ANSI Z244.1-2016 (R2020)
- OSHA Machine Guarding Standard (29 CFR 1910.212)*
- Variety of ANSI Specific Machine Guarding Standards (i.e.: B11, Z50, B151, B65, etc.)**
Compliant Hazardous Energy Program
Hazardous Energy Programs should align with regulatory standards and provide clear direction on three core competencies: energy control procedures, employee training, and periodic inspections. This includes maintaining records of training sessions, auditing equipment-specific procedures, verifying employee competency, ensuring equipment lists are current, and a history of lockout/tagout activities.
Identifying Energy Sources
It is imperative to identify all energy sources associated with the equipment in your facility to prevent unintended energization while employees are performing maintenance tasks. The most common energy sources found are electrical, pneumatic, steam, mechanical, and hydraulic, to the more overlooked energy sources such as thermal, chemical, natural gas, water, and gravity. It is important to correctly identify these sources to ensure proper shutdown of equipment, isolation of energy, and arming employees with the knowledge of what hazards could potentially harm them or others.
Energy Control Procedures (ECP)
Energy Control Procedures must be developed, documented, and utilized by employees to control hazardous energy. Specific exceptions do exist that override the need for documented ECP procedure; however, those circumstances are exceedingly rare. A considerable number of machines used in manufacturing today do not meet the exceptions listed under 1910.147(c)(4)(i) and require written energy control procedures. To simplify, equipment with two or more energy sources are required under 29 CFR 1910.147 to have documented energy control procedures. Each ECP should have procedures that clearly outline the scope, purpose, authorization, rules, and techniques for properly controlling a machine’s hazardous energy. This includes, but is not limited to, intended use of the procedure, energy sources and strength, type & number of lockout devices to be utilized, seven steps of LOTO shutdown, testing considerations, and the four steps of re-energization. Creating Energy Control Procedures can be a daunting and complex task, but with the help of SEAM Group, you can rest easy knowing your equipment’s hazardous energy procedures will be easy to use, correct, and reliable providing your employees with the correct knowledge to remain safe.
Hazardous Energy Control Plan & ECP Training/Communication
All authorized & affected employee(s) shall be formally trained on the hazardous energy control plan, Lock out Tag out (LOTO) standard, LOTO equipment, LOTO process, group LOTO, shift change, contractor involvement/authorization, and equipment specific energy control procedures. If a tagout system is being utilized, then it is required that both authorized and affected employees are trained on the limitations of tags and their application. Re-training should occur on an annual basis, or when revisions are made to the Hazardous Energy Control Plan and/or any of its supporting documents (energy control procedures, equipment modifications/changes, etc.).
Authorized/Affected Employees
Only trained LOTO authorized employees shall de-energize equipment and perform lockout tagout. Training should emphasize the importance of communication, coordination among both authorized & affected personnel, and the energy control procedures to ensure safe execution of maintenance activities.
LOTO Equipment Inspection
Regular inspection of lockout devices and tagout systems is essential. Employees should be trained to inspect equipment before and after each use to ensure equipment is in good working order.
Periodic Inspections
A periodic inspection is the verification of the energy control procedure as well as its understanding by authorized and affected employees. These inspections are required, at minimum, on an annual basis and apply to every energy control procedure to correct any deviations, physical changes, or inadequacies that may exist with the equipment. Inspections must be performed by a competent LOTO authorized employee and documented so that the employer may certify the inspections took place. If the periodic inspection identifies a change needed in the energy control procedure, then a revision will occur and subsequent re-training on that procedure will follow the procedure revision.
A Control of Hazardous Energy program ensures that employees have the knowledge and skills to safely perform maintenance and servicing activities which in turn, reduces the risk of accidents and injuries. Compliance with LOTO procedures prevents approximately 50,000 injuries and 120 fatalities every year, according to the Occupational Safety and Health Administration (OSHA) and the Bureau of Labor & Statistics (BLS)
Dispelling Common Misconceptions about Lockout Tagout (LOTO) Training
Misunderstandings surrounding Lockout Tagout (LOTO) training often hinder a thorough grasp of its applicability and effectiveness. Some common misconceptions are:
Myth #1: LOTO is exclusive to electrical equipment
It is a common misconception that Lockout Tagout (LOTO) protocols exclusively apply to electrical equipment, a belief from a limited understanding of its comprehensive applicability.
LOTO procedures are integral to ensuring the safety of personnel during the maintenance or servicing of a wide array of machinery and equipment, far surpassing just electrical systems. This includes but is not limited to mechanical, hydraulic, pneumatic, and thermal energy sources.
Such an expansive application spectrum underscores the versatility and adaptability of LOTO protocols, making them indispensable across diverse industrial landscapes.
Myth 2: LOTO is a time-consuming process
The implementation of a Hazardous Energy Control program brings numerous benefits, including heightened worker safety, prolonged equipment lifespan, and minimized downtime. Applying LOTO with the correct processes and procedures in place significantly increases safety and efficiency when conducting maintenance on equipment as well as keeping your company in compliance with regulatory standards. This approach is particularly significant considering that each year, approximately 3,000 workers endure lost-time injuries from being caught in dangerous parts of equipment or machinery during maintenance or cleaning activities, as reported by the Bureau of Labor Statistics (BLS).
Myth #3: LOTO is only necessary for large industrial facilities
The third myth assumes that LOTO is exclusive to extensive industrial facilities, dismissing its universal applicability. Workplace hazards exist irrespective of facility type or size. Real-life examples underscore the importance of LOTO in various settings, from small workshops to expansive manufacturing plants.
LOTO’s universal relevance stems from its capacity to safeguard workers and prevent accidents, regardless of the scale of operations.
Frequently Asked Questions About Lockout Tagout Training
LOTO (Lockout/Tagout) training is crucial for workplace safety, particularly in industries where machinery and equipment are used. Here are some frequently asked questions (FAQs) about LOTO training:
Is LOTO Training required?
Yes, LOTO (Lockout/Tagout) training is a requirement set by occupational safety authorities like OSHA in the United States and similar regulatory organizations worldwide. It is the employer’s responsibility to ensure their team members understand LOTO and energy control procedures. LOTO training is all about empowering employees with the knowledge and skills they need to de-energize and handle equipment safely.
How can employers ensure effective LOTO training?
Employers can ensure effective Lockout/Tagout (LOTO) training by providing compliant hazardous energy control plan, post training testing, for authorized & affected employee, knowledge retention, conducting hands-on training sessions, and reinforcing procedures through regular auditing, lessons learned, communication, and periodic inspections. The combination of these tools applied to everyday work will empower an employer’s team to make the correct and safe decision when working on machinery or equipment.
How often should LOTO training be conducted?
Training should be conducted initially for all authorized & affected employees to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. Re-training shall also be conducted whenever a periodic inspection reveals, or whenever the employer has reason to believe, that there are deviations or inadequacies in the employee’s knowledge or use of the energy control procedures. At minimum, retraining of authorized & affected employees should occur on an annual basis.
What are the key components of LOTO Training?
Key components of Lockout/Tagout (LOTO) training include:
- Purpose & Application
- Scope of Energy Control
- Alternative Procedures* (if applicable)
- Energy Sources, Isolation, & Devices
- Energy Control Procedures
- Group LOTO, Shift Change, and Exceptions to the standard
- Periodic Inspections
- Annual Program Auditing
- Contractor Protocols
What is the difference between lockout and tagout? When do you need to do one vs. the other or both?
Lockout involves physically securing energy-isolating devices with locks to prevent machinery from being energized or started unintentionally. Tagout involves attaching warning tags to energy-isolating devices to communicate that maintenance or servicing is being performed when physical lockout is not possible. Both lockout and tagout may be necessary depending on the level of risk and the specific equipment being serviced.
Are there specific regulations or standards for LOTO training?
Yes, LOTO training requirements are often outlined by government occupational safety agencies such as OSHA (Occupational Safety and Health Administration) in the United States or similar regulatory bodies in other countries. These regulations provide guidelines for proper LOTO procedures and training.
What are the consequences of not following LOTO procedures?
Failure to follow LOTO procedures can result in serious injuries up to and including death. Some injury examples include, but are not limited to electrocution, shock, burns, crushing injuries, de-gloving, amputation, dismemberment, and/or severe physical trauma. Employers may face legal penalties, fines, and lawsuits, damaging the company’s reputation and more importantly, causing irreversible physical and emotional damage to the employee, employee’s family, and co-workers.
Beyond direct regulatory fines, there are broader financial ramifications that can affect the employer dramatically. Workplace incidents resulting from inadequate hazardous energy control can lead to increased insurance costs due to the severity and frequency of the incident. This includes higher premiums due to perceived increased risks and potential claims from injured employees. Insurance companies assess risks and adjust premiums based on a company’s adherence to safety protocols, including hazardous energy control.
Additionally, other indirect costs to the organization can often include:
- Training replacement employees
- Accident investigation time and implementation of corrective measures
- Lost productivity
- Repairs to damaged or soiled equipment & property
- Lower employee morale and absenteeism
An effective Control of Hazardous Energy program implemented and driven effectively by management, can help mitigate these risks, thereby potentially reducing insurance costs as well as indirect costs. Remember, if you think the cost of safety is high, just wait until you get the bill for regret.
Where can I get LOTO training materials or resources?
From strategic advisory services to custom training solutions, field inspection, and maintenance services, SEAM Group integrates advanced technology and actionable data management to ensure your team is well-equipped with the knowledge and tools necessary for safe and effective lockout/tagout procedures.
SEAM Group: Setting the Standard in LOTO Training
SEAM Group delivers Lockout Tagout (LOTO) training, showcasing profound expertise in energy asset solutions and safety practices. Our unwavering commitment to excellence is apparent in our meticulous approach to LOTO training, precisely addressing the intricacies of energy control procedures.
Our comprehensive training programs standout for their detailed exploration of LOTO fundamentals, ensuring participants thoroughly understand the critical aspects involved. Our emphasis on real-world applicability sets us apart, offering unique features and methodologies that bridge the gap between theory and practical implementation.
By incorporating these innovative elements, we ensure that our LOTO training programs meet regulatory standards and equip participants with practical knowledge and skills for real-world situations.
SEAM Group establishes a benchmark for excellence in LOTO training and workplace safety, consistently striving to provide unparalleled learning experiences beyond industry norms.