Joe Mlynek, CSP, OHST
Updated: Mar 28
Core Elements of an Effective Program
The Occupational Safety and Health Administration (OSHA) promulgated the standard for The Control of Hazardous Energy (Lockout Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147 in 1982. The standard is responsible for preventing numerous injuries and fatalities since it went into effect in 1989. Lockout tagout is defined as specific practices and procedures to safeguard employees from unexpected energization or start-up of machinery or equipment or the release of hazardous energy during servicing or maintenance. This blog will discuss the core elements of an effective lockout tagout program.
Energy Control Procedures
The OSHA standard requires employers to develop a program consisting of energy control procedures, employee training, and periodic inspections. Energy control procedures must be developed and utilized for the control of potentially hazardous energy during servicing or maintenance. The energy control procedures must be equipment specific unless all of the following elements exist:
The machine or equipment has no potential for stored or residual energy or re-accumulation of energy after shut down.
The machine or equipment has a single energy source which can be readily identified and isolated.
The isolation and locking out of that energy source will completely deenergize and deactivate the equipment.
The machine or equipment is isolated from the energy source and locked and tagged out during servicing and/or maintenance.
A single lockout device will achieve a locked-out condition.
The servicing or maintenance does not create hazards for other employees.
The employer has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.
If energy control procedures are required, they must clearly outline the scope, authorization, rules, and techniques utilized to control the hazardous energy, include a specific statement of the intended use of the procedures, and specific procedural steps for shutting down, isolating, blocking, or securing machines or equipment to control hazardous energy. The procedure must also include specific steps for placement, removal, and transfer of lockout devices, tagout devices, and other energy control measures.
Employers are required to conduct periodic inspections of the energy control procedure(s) at least once per year. The purpose of the inspection is to ensure that the procedure(s) is being followed. The inspection must be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected. Any inadequacies or deficiencies identified during the inspection must be corrected immediately. In addition, periodic inspections must include a review between the inspector and each authorized employee to include that employee’s responsibility under the control procedure being inspected. Inspection documentation must include the identity of the machine or equipment, date of inspection, names of employees included in the inspection, and the person performing the inspection.
Employers are also expected to ensure that employees have knowledge and skills required for safe application, usage and removal of energy controls. Training must focus on the recognition of applicable hazardous energy sources, the types and magnitude of the energy available in the workplace, and the methods and means for energy isolation and control. The employer is expected to provide training specific to the needs of the employee with a focus on both the authorized and affected employee.
An affected employee operates or uses a machine or equipment on which servicing or maintenance is being performed under lockout tagout. An authorized employee is a person who locks or tags out machines or equipment in order to perform servicing or maintenance. Affected employees must be trained on the purpose of the energy control procedure(s), recognition of when an energy control procedure is being used and understand the importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked and tagged out. Authorized employees must be trained to ensure that they have knowledge and skills necessary for the safe application, use, and removal of energy isolating devices, the ability to recognize hazardous energy, the type(s) and magnitude of hazardous energy sources in the workplace and the energy control procedure(s). Authorized and affected employees must be retrained when there is a change in job assignments, equipment or processes that present a new hazard, a change in energy control procedures, or a periodic inspection that reveals shortcoming with employee knowledge or use of energy control procedures.
An effective energy control program can prevent employee injuries and fatalities. The core elements of an effective program include procedures, training, and periodic inspections. In addition to the core program elements, consider program language to address key elements such as contractor coordination, group lockout tagout requirements, lockout device removal, and continuity of lockout tagout during shift changes. Remember, safety doesn’t have to be difficult, simple steps, like inspecting lockout tagout procedures to ensure effectiveness, can prevent injuries and save lives.
Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at email@example.com