OSHAcademy Course 621 Controlling Hazardous Energy (Lockout/Tagout) - Module 2

Course 621 Controlling Hazardous Energy (Lockout/Tagout)

Training and Inspections

OSHA LOTO Photo
Training should include classroom instruction and hands-on practice.

Employee Training and Communication

The employer is 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.

Why Training is Important

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.

Real Life Event

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.

1. Who must possess the knowledge and skills necessary for the safe application, use, and removal of energy controls during lockout/tagout of equipment or machinery?

a. Other employees
b. Affected employees
c. Authorized employees
d. Qualified employees

Training Differences

"When do employees need to receive training for lockout/tagout?" Tom Campbell, Brady's Global Product Manager for LOTO, provides helpful input on this matter.

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

Authorized employees lockout or tagout equipment and service or maintain the equipment. Required training for authorized employees includes:

  • how to find and recognize hazardous energy sources;
  • how to identify the types and magnitudes of energy used in the workplace; and
  • how to isolate energy sources.

Affected Employees

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:

  • the purpose of energy-control procedures;
  • how energy-control procedures are applied; and
  • how energy-control procedures will protect them.

Other Employees

Other employees work around or otherwise might be in the vicinity of 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.

2. Which category of employees operates equipment serviced under lockout or tagout procedures or work in an area affected by the procedures?

a. Other employees
b. Affected employees
c. Authorized employees
d. Area employees

Retraining

OSHA LOTO Photo
Ensure all authorized, affected, and other employees receive initial training and appropriate retraining.

The employer should retrain employees when the employer has reason to believe employees do not have adequate understanding, skills, or abilities (KSAs). Retraining should also be conducted annually if employees do not perform lockout/tagout procedures regularly. Situations requiring retraining include the following:

  • When changes in job assignments affect lockout/tagout procedures;
  • When changes in the workplace render previous training obsolete or inadequate;
  • When changes in processes, equipment or machinery render previous training obsolete or inadequate; or
  • When inadequacies in an authorized employee's knowledge of lockout/tagout procedures or equipment indicate that the employee no longer has the requisite understanding or skill necessary to correctly perform those procedures.

The purpose of retraining is to re-establish employee proficiency and introduce new or revised control methods and procedures, as necessary. You do not need to retrain your employees on an annual basis. However, if your employees do not actually use LOTO procedures often, it's a good idea to practice the procedures at least annually.

Additional Training

Employers must train workers in the following limitations of tags listed below:

  • Tags are essentially warning devices attached to energy isolating devices and do not provide the physical restraint on those devices that is provided by a lock.
  • When a tag is attached to an energy isolating means, it is not to be removed without authorization and it is never to be bypassed, ignored, or otherwise defeated.
  • Tags must be legible and understandable by all workers.
  • Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace.
  • Tags may evoke a false sense of security and their meaning needs to be understood as part of the overall energy control program.
  • Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use.

3. What is the purpose of retraining in lockout/tagout procedures?

a. Conform to ANSI standards
b. Re-establish employee proficiency
c. Comply with OSHA requirements
d. Satisfy due diligence

Training Certification

OSHA LOTO Photo
Supervisors should certify authorized employees are fully qualified.

Employer must certify that training or retraining took place and that the employee is kept up to date. However, if your training program aspires to conform to ANSI Z490.1, Criteria for Accepted Practices in Safety, Health, and Environmental Training, you will need to certify that each employee has demonstrated proficiency in the learning environment immediately after training. After training, you will be required to certify the employee has successfully applied what they have learned in the workplace.

Certificate Information

To meet basic Federal OSHA requirements in the USA, certification need only contain the information listed below:

  • Each employee's name.
  • The dates of training and/or retraining.

We believe the documentation should also include certifications by the trainer and authorized employees' supervisors.

  • The trainer's certifies that, based on testing and practice in the learning environment, authorized employees are initially competent and qualified to perform lockout/tagout procedures.
  • The supervisor will evaluate authorized employees as they perform lockout tagout on the job. If an evaluation shows that employees have demonstrated adequate knowledge, skills, and abilities (KSAs), the supervisor may then certify authorized employees as fully competent and qualified.

For more information on certifying safety training, see OSHAcademy course Developing OSH Training, Module 5.

4. Although OSHA standards require only the employee's name and date of training/retraining, it is also important to include _____.

a. the location and duration of the training
b. Start and end times of training
c. testing methods used and scores obtained
d. trainer and supervisor written certification
Door or Gate Opening on Stairway - OSHA Image
Annual and random no-notice LOTO inspections should be conducted.

Lockout/Tagout Inspections

Periodic inspections help employers discover and correct program deficiencies. An inspection of each energy control procedure must be completed at least annually by an authorized employee other than the ones(s) using the energy control procedure being inspected.

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 energy control procedure is correct.
  • The energy control procedure is being followed.
  • The energy control procedure addresses all energy sources.
  • Employees understand the energy control procedure.
  • Employees understand their energy control responsibilities.

The employer must certify that the periodic inspections have been performed. The certification must identify:

  • the machine or equipment on which the energy control procedure was being utilized,
  • the date of the inspection,
  • the employees included in the inspection, and
  • the person performing the inspection.

5. As part of the Energy Control Program, annual inspections must include _____.

a. inspection of training curriculum
b. inspection of each energy control procedure
c. a list of all lockout/tagout procedures
d. a job hazard analysis of hazardous tasks
Image shift change OROSHA photo</a>
Spiral Stairs

Correcting Program Weaknesses

Each energy control procedure must be inspected 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:

  • Revising the procedure to correct deficiencies
  • Acquiring additional or more-specific lockout or tagout devices to provide employees with appropriate equipment to complete the energy control procedure
  • Providing additional employee training
  • Increasing oversight of those that use energy control procedures

Best Practice: If you have several authorized employees, rotate them in the inspector role so everyone has the opportunity to be the inspector.

6. A single procedure can cover a group of similar equipment if the equipment meets all of the following criteria, EXCEPT _____.

a. the equipment has similar energy control methods
b. the equipment has the same magnitudes of energy
c. the equipment has the same types of energy sources
d. the equipment is in a similar location
OSHA LOTO Photo
Review LOTO procedures at least annually.

Reviewing a Lockout Procedure

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.

Reviewing a Tagout Procedure

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.

Documenting Inspections

The employer must certify that the energy control procedure has been inspected. The certification must contain the following information:

  • The equipment on which the procedure is used
  • The date of the inspection
  • The employees included in the inspection
  • The person who did the inspection

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.

7. With whom must the Energy Control Program inspector review lockout/tagout procedures during annual inspections?

a. Authorized employees
b. Affected employees
c. Authorized and affected employees
d. Affected and other employees

Check your Work

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Real-Life Scenario

Hazardous Energy in the Workplace Can Kill

loto1
Lockout/Tagout could have prevented this tragedy.

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.

Oregon OSHA Investigation findings

  1. The employee did not use lockout procedures while he was working on the lift and did not block the boom to prevent it from dropping.
  2. The lift’s emergency valve, hydraulic hoses and fittings, and electrical wiring were inspected after the accident and were not defective; however, the on/off key switch had been bypassed so that the operator could use the toggle switches without using the key.
  3. The battery charging system was missing a fuse that would stop the system from charging, and the spring-loaded toggle switches that controlled the boom did not have guards to prevent accidental contact.
  4. The owner had not reviewed the lift’s instruction manual with the victim or other company employees.

The accident resulted in the following violations:

  1. OSHA Standard 1910.147(c)(4) – The employer did not develop, document, and require employees to use lockout procedures to control hazardous energy during maintenance work.
  2. Oregon Standard 437-001-0760 – The employer failed to ensure that employees did not remove or tamper with required safety devices.

Video

If you have the time, watch this Pipeline Safety video is a great tailgate safety meeting discussion starter.



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