When Does the Lockout/Tagout Standard Apply?
Knowing is half the battle. This technical guide to lockout/tagout standards will help keep your workplace safe and compliant.
The Occupational Safety and Health Administration’s (OSHA’s) Control of Hazardous Energy (Lockout/Tagout) standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of machines or equipment, or release of stored energy, could cause injury to employees. Employees servicing or maintaining machines or equipment may be exposed to serious physical harm or death if hazardous energy is not properly controlled. The Lockout/Tagout (LO/TO) standard establishes minimum performance requirements for the control of this hazardous energy.
To better understand when the LO/TO standard applies in the workplace, OSHA has identified two key activities that are performed. The first activity is normal production. This is defined as any utilization of a machine or equipment to perform its intended purpose. The second activity is servicing and/or maintenance. This is defined as any action that is necessary to prepare or maintain a machine or piece of equipment.
As a general principle, the LO/TO standard does not apply to normal production activities unless the employee is required to remove or bypass machine guarding required by 29 Code of Federal Regulations (CFR) Part 1910 Subpart O, Machinery and Machine Guarding or place any part of their body in an area where unexpected startup of the machine or equipment may cause injury.
When the employee is not exposed to hazardous energy, the LO/TO standard does not apply. OSHA has identified five conditions where employees are not considered exposed to hazardous energy:
- Complying with the minor servicing exception to the LO/TO standard contained in the note found in 29 CFR 1910.147(a)(2)(ii)(B);
- Utilizing the cord and plug connected equipment or hot tap exemptions found in 29 CFR 1910.147(2)(iii)(A) and (B) respectively;
- Effective machine guarding, in compliance with 29 CFR Part 1910 Subpart O;
- Final actions granting LO/TO standard variances; or
- Other applicable portions of Part 1910 preventing employee exposure to hazardous energy.
If unsure about any activity that may or may not fall under the scope of this standard, always play it safe and perform the lockout.
Energy Control Program
An energy control program must be established to control the unexpected release of energy under the scope of this standard. An energy control program has three core components:
- Energy control procedures which detail and document the specific information that an authorized employee must know to accomplish LO/TO [29 CFR 1910.147(c)(1)]; [29 CFR 1910.147(c)(4)(i)]; and [29 CFR 1910.147(c)(4)(ii)].
- Periodic inspections to help ensure that the energy control procedures and the requirements of the standard are being followed [29 CFR 1910.147(c)(1)].
- Employee training and retraining, which helps ensure that the purpose and function of the energy control programs are understood [29 CFR 1910.147(c)(1)]; and [29 CFR 1910.147(c)(7)(ii)].
Commonly Asked Questions
Q. Can I use a tagout instead of a lockout when it is infeasible to lock out?
A: When it is infeasible to lock out, or in industries where tag use has been well established and accepted as a recognized prohibitive to the operation of energy-isolating devices, a tagout procedure is acceptable.
Q. Do I have to lock out/tag out a machine that only requires the unit to be unplugged?
A: No. The standard does not apply in situations where work on cord- and plug-connected electric equipment is under the exclusive control of the employee performing the servicing or maintenance.
Q. Are there any other standards related to lockout/tagout?
A: Yes. OSHA has used 29 CFR 1910.212, General Requirements for All Machines, and 29 CFR 1910.219, Mechanical Power Transmission Apparatus, to cite businesses for a lack of compliance. In addition, 29 CFR 1910.333, Selection and Use of Work Practices, sets forth requirements to help protect employees working on electric circuits and equipment. This section requires workers to use safe work practices, including lockout/tagout procedures. These areas also allow OSHA to issue a double citation for noncompliance.
ANSI/ASSE Z244.1-2003 (R2014), Control of Hazardous Energy Lockout/Tagout and Alternative Methods, 2014
OSHA LO/TO eTool, Lockout/Tagout Interactive Training Program, March 2008