Employers are required to provide effective training for all employees covered by the lockout/tagout standard and ensure that all employees understand the basic program concepts, including the purpose, function, and restrictions of the energy control program, and how to control those hazards.
Authorized employees must possess the knowledge and skills necessary for the safe application, use, and removal of energy controls. This training also must make employees aware that disregarding or violating the energy control program could endanger their own lives or the lives of co-workers.
It is important to train employees so they understand the purpose and function of the energy control program and get the knowledge and skills necessary to safely apply, use and remove the energy controls. The LOTO standard requires different levels of training for the three categories of workers: authorized, affected, and other employees.
A recent news report shows the importance of lockout/tagout training within a company.
Expect the unexpected.
An employee at a wood chip company went through a wood chipper and survived. Something got stuck inside the machine and he went into the wood chipper to get the object. He thought everything was turned off. However, a fellow employee turned on the machine while he was inside.
The victim spent some time in the hospital with multiple injuries.
There are three types of employees which must receive training: authorized, affected, and other.
The amount and type of training that each employee receives is based upon the relationship of that employee's job to the machine or equipment being locked or tagged out and upon the degree of knowledge relevant to hazardous energy that the employee must possess.
In addition, employers are required to certify that effective training and retraining has been provided to all employees covered by the standard. The certification must contain each employee's name and dates of training.
Authorized employees lockout or tagout equipment and service or maintain the equipment. Required training for authorized employees includes:
Affected employees operate equipment serviced under lockout or tagout procedures or work in an area affected by the procedures. An affected employee becomes an authorized employee when the employee performs service or maintenance work on the equipment. Required training for affected employees includes:
Other employees may work around or be near equipment that is under lockout/tagout. They need to receive awareness-level training regarding the Energy Control Program. They need to understand that if they see LOTO devices, they are not to touch them.
The employer should retrain employees when the employer has reason to believe employees do not have adequate understanding, skills, or abilities (KSAs). Employers should conduct annual retraining if employees do not perform lockout/tagout procedures regularly. Situations requiring retraining include the following:
The purpose of retraining is to re-establish employee proficiency and introduce new or revised control methods and procedures, as necessary. Employers do not need to retrain their employees annually. However, if your employees do not actually use LOTO procedures often, it is a good idea to practice the procedures at least annually.
Employers must train workers in the following limitations of tags listed below:
Employer must certify that training or retraining took place and that the employee is kept up to date. However, if the training program aspires to conform to ANSI Z490.1, Criteria for Accepted Practices in Safety, Health, and Environmental Training, the employer will need to certify that each employee has demonstrated proficiency in the learning environment immediately after training. After training, the employer is required to certify that the employee has successfully applied what they have learned in the workplace.
To meet basic Federal OSHA requirements in the USA, certification need only contain the information listed below:
We believe the documentation should also include certifications by the trainer and authorized employees' supervisors.
For more information on certifying safety training, see OSHAcademy course Developing OSH Training, Module 5.
Periodic inspections help employers discover and correct program deficiencies. Each energy control procedure must be inspected at least annually by an authorized employee. The authorized employee who inspects an energy control procedure cannot be an employee who is following that specific procedure at the time of the inspection.
Inspections of energy control procedures can be scheduled or random audits. The authorized employee who does the inspection must understand the energy control procedure and must not be among those following the procedure at the time of the inspection. A successful inspection confirms that:
The employer must certify that the periodic inspections have been performed. The certification must identify:
An authorized employee must inspect each energy control procedure for its accuracy, completeness, and effectiveness in energy control. A single procedure can cover a group of similar equipment if they all have the same or similar types and magnitudes of energy, and the same or similar energy control methods. Also, inspections must include a review of the energy control procedure between the inspector and the employees using the procedure.
When an inspection reveals employees not following the energy control procedure or discovers that the procedure is not fully protecting them, the employer must take corrective action. Corrective actions could include:
Best Practice: If you have several authorized employees, rotate them in the inspector role so everyone has the opportunity to be the inspector.
If the inspection covers a procedure for equipment with an energy- isolating device that can be locked out, the inspector must review the procedure with the authorized employees who use it to service the equipment. The inspector can review the procedure with the authorized employees individually or in a group.
If the inspection covers a procedure for equipment with an energy-isolating device that can only be tagged out, the inspector must review the procedure with the authorized employees who use it to service the equipment and with affected employees who may work in the area when the equipment is serviced. The inspector can review the procedure with the authorized and affected employees individually or in a group.
The employer must certify that the energy control procedure has been inspected. The certification must contain the following information:
Best Practice: Record findings of successes and deficiencies and incorporate them into your inspection records to improve training, procedures, and accountability.
You can use this lockout/tagout inspection checklist developed by Oregon OSHA as part of your inspection process.
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The son of the owner of a commercial drywall construction company in Oregon, who was also an employee of the company, was preparing an aerial lift for a job and had replaced two battery terminals. He raised the aerial boom and was reaching toward the battery compartment across the metal enclosure that houses the lift’s toggle controls when the boom dropped and pinned him to the control panel. His father discovered him and summoned emergency responders, but he died at the site.
If you have the time, watch this Pipeline Safety video is a great tailgate safety meeting discussion starter.