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This material is for training purposes only. Its purpose is to inform employers and workers and workers of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.
MODULE 2: ENERGY CONTROL PROGRAM COMPONENTS

What is management's obligation in establishing energy control procedures?

Management must develop, document, and make sure employees use specific written LOTO procedures to control potentially hazardous energy.

Are there any situations in which a worker need not develop and use a written LOTO procedure?

Yes, the employer need not develop and use a written LOTO procedure for servicing or maintenance on a particular machine or equipment, but only when all of the following elements exist:
  1. The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees;
  2. the machine or equipment has a single energy source which can be readily identified and isolated; (
  3. the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment;
  4. the machine or equipment is isolated from that energy source and locked out during servicing or maintenance;
  5. a single lockout device will achieve a locker-out condition;
  6. the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
  7. the servicing or maintenance does not create hazards for other employees; and
  8. the employer has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

What specific elements must be documented in the LOTO procedures?

If the employer can't meet the above exception criteria, written LOTO procedures must be developed and used. The procedures for equipment with one or more sources of energy must outline the scope, purpose, authorization, rules and techniques that the employer will use to control hazardous energy. The scope might be limited to a single or group of similar pieces of equipment or machinery. The purpose of the procedures is to ensure the unexpected energization/startup or shutdown does not occur during servicing or maintenance activities. The responsible manager authorizes the procedures and specific rules/techniques are listed within the procedures.

The procedures must state the means to be used to enforce compliance. Typically this requirement is met by stating the procedure is mandatory and may result in disciplinary action if not followed.

At a minimum, the procedures must include:
  • A specific statement of the intended use of the procedure.
  • Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.
  • Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices, and a description of who has responsibility for them.
  • Specific requirements for testing a machine or piece of equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
If an energy isolating device is not capable of being locked out, can the employer use a tagout system?

Yes, and this is very important to remember: if an energy isolating device is not capable of being locked out, the employer's energy control program must use a tagout system.

If an energy isolating device is capable of being locked out, must the employer use a lock out system?

Yes. Unless the employer can demonstrate that the tagout system will provide full employee protection. The employer may choose to use a tagout system as long as the requirements for additional training and periodic inspections are met. You'll read more about "full employee protection" in a later module.

What are the requirements for the use of tagout devices when lockout devices are capable of being used?

  1. The tags must be attached where the lockout devices would be.
  2. The employer must demonstrate (prove) that the tagout system will provide protection at least as effective as locks and will assure full employee protection.
How does an employer demonstrate that the protection achieved using the tagout program is equivalent to the level of safety obtained by using a lockout program?

The employer must comply with all tagout-related provisions and also use additional safety measures that provide a level of safety equivalent to that obtained by using lockout. Examples include:
  • removing and isolating a circuit element
  • blocking a controlling switch
  • opening an extra disconnecting device
  • removing a valve handle to reduce the potential for any inadvertent energization while the tags are attached

What about new or modified equipment?

All new machines and equipment, or all machines and equipment that undergo major repair, renovations or modification, must be equipped with energy-isolating devices capable of accepting a lockout device.

After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment must be designed to accept a lockout device.

Last Words

That's about it for a discussion of the basic components of the ECP. Remember, make sure all three components have been developed and deployed. If OSHA comes inspecting, they will not cut you any slack when it comes to the LOTO program because if something goes wrong, a serious injury or fatality is likely the result. Okay...time for the quiz.

GO TO MODULE 2 QUIZ Remember to take each module quiz! The final exam questions are derived directly from the module quizzes.

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