OSHA’s lockout-tagout (LOTO) standard was the fifth-most-frequently cited agency standard in FY 2018.

Enforcement citations FY 2018: 2,629

Number of inspections: 1,444

Proposed penalties: $13,532,440

Most frequently cited industries

• Manufacturing
• Wholesale trade
• Construction
• Services
• Waste management and remediation
• Retail trade
• Transportation and warehousing

Enforcement case studies

1. In November, 2018, OSHA cited Sabel Steel Service Inc. – based in Montgomery, Alabama – for exposing employees to amputation, fall, and other hazards at four of the company’s facilities. The manufacturer faces $320,261 in penalties.
   
   OSHA conducted separate inspections at the company’s facilities in Montgomery, Dothan, and Theodore, Alabama; and in Newnan, Georgia. OSHA cited the company for exposing employees to amputations hazards; failing to 1) use safety procedures to control the release of hazardous energy during machine maintenance or servicing; 2) provide fall protection; 3 0 conduct medical evaluations to determine an employee’s ability to use a respirator; improperly storing oxygen, propane and acetylene cylinders; and electrical and fire hazards. The inspections are part of OSHA’s National Emphasis Program on Amputations.
    
2. In September, 2018, OSHA cited JBS Green Bay Inc. for machine guarding violations that led to an employee suffering serious injuries after becoming caught in an unguarded machine. OSHA cited the company - based in Green Bay, Wisconsin - for one willful and 10 serious violations, and faces proposed penalties of $221,726, which includes the maximum penalty for the willful violation.
   
   OSHA’s safety investigation determined that the company failed to install adequate safety guards, and exposed workers to fall and lockout/tagout hazards. Inspectors opened a concurrent health inspection after a review of the company’s safety and health logs determined that employees had been exposed to an ammonia release. The company was cited for having an inadequate process safety management program.

Background

Energy sources including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment can be hazardous to workers. During the servicing and maintenance of machines and equipment, the unexpected startup or release of stored energy can result in serious injury or death to workers.

Workers servicing or maintaining machines or equipment may be seriously injured or killed if hazardous energy is not properly controlled. Injuries resulting from the failure to control hazardous energy during maintenance activities can be serious or fatal. Injuries may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts. LOTO incidents include these examples:

• A steam valve is automatically turned on, burning workers who are repairing a downstream connection in the piping.
• A jammed conveyor system suddenly releases, crushing a worker who is trying to clear the jam.
• Internal wiring on a piece of factory equipment electrically shorts, shocking worker who is repairing the equipment.

Craft workers, electricians, machine operators, and laborers are among the three million workers who service equipment routinely and face the greatest risk of injury. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.

Failure to control hazardous energy accounts for nearly ten percent of the serious accidents in many industries. Proper lockout/tagout (LOTO) practices and procedures safeguard workers from hazardous energy releases. 

Hazard protection

The LOTO standard establishes the employer's responsibility to protect workers from hazardous energy. Employers are required to train employees in the following:

• Proper lockout/tagout (LOTO) practices and procedures safeguard workers from the release of hazardous energy. The OSHA LOTO standard outlines specific action and procedures for addressing and controlling hazardous energy during servicing and maintenance of machines and equipment. Employers are required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures. Workers must be trained in the purpose and function of the energy control program and have the knowledge and skills required for the safe application, usage and removal of the energy control devices.
• All employees who work in an area where energy control procedure(s) are utilized need to be instructed in the purpose and use of the energy control procedure(s), especially prohibition against attempting to restart or reenergize machines or other equipment that are locked or tagged out.
• All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to be trained in recognition of applicable hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling the energy.
• Specific procedures and limitations relating to tagout systems where they are allowed.
• Retraining of all employees to maintain proficiency or introduce new or changed control methods.

Key lockout-tagout standard takeaways:

• The standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees. The standard establishes minimum performance requirements for the control of such hazardous energy. This standard does not cover construction and agriculture employment.
• Normal production operations are not covered by this standard. Servicing and/or maintenance which takes place during normal production operations is covered by this standard only if: an employee is required to remove or bypass a guard or other safety device; or an employee is required to place any part of his or her body into an area on a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine operating cycle. 
• The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start-up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.
• If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
• If an energy isolating device is capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.
• Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware shall be provided by the employer for isolating, securing or blocking of machines or equipment from energy sources.

Compliance resources

Lockout-Tagout Interactive Training Program. OSHA eTool. This interactive tool provides the user with an in-depth understanding of the LOTO standard, with three components: Tutorial, Hot Topics, and Case Studies -- a series of case studies for review, followed by related questions. Each of the case studies is based on descriptions of LOTO inspections derived from compliance interpretations, court decisions, review commission decisions, and inspection files.

Small Business Handbook (PDF). OSHA Publication 2209, (2005). Handbook is provided to owners, proprietors and managers of small businesses to assure the safety and health of workers and covers lockout/tagout procedures.