The OSHA standard for The Control of Hazardous Energy (Lockout/ Tagout), Title 29 CFR 11910.147, applies to all GAWDA member companies that have service and maintenance activity performed on their equipment and machinery. The equipment/machinery could be as complex as working on a main air compressor for an air separation unit, or as simple as servicing a vacuum pump at a cylinder fill plant.

GAWDA has a wide variety of members that range from companies with a few employees to those with several hundred. We have member companies that operate rather complex manufacturing plants and member companies that operate retail stores. The point is, the size and complexity of our operations vary significantly, but the Lockout/Tagout standard applies to all companies if servicing and maintenance work exposes the employee(s) to injury from exposure to hazardous energy sources or the start-up, or release, of stored energy. No one is exempt from the standard based on company size, complexity of equipment, or frequency of service or maintenance activity.

The standard gives each employer the flexibility to develop an energy control program suited to the needs of the particular workplace and the types of machines and equipment being maintained or serviced. Therefore, the program doesn’t necessarily need to be big and complex.

What You Must Do to Protect Employees
The following are some of the more critical requirements from the standard that should be in place.

  • Develop, implement and enforce an energy control program. A sample program is in your GAWDA OSHA Manual, Section 20, which can be modified and made site specific.
  • Use lockout devices (padlocks) on equipment to block the flow of energy from the energy sources to the piece of equipment.
  • Ensure that all new or overhauled equipment is capable of being locked out.
  • Develop, implement and enforce an effective tagout program if machines or equipment are not capable of being locked out. This approach requires additional training and more frequent auditing.
  • Develop, document, implement and enforce energy control procedures. Refer to 1910.147(c) (4) (i) for an exception to the documentation requirements. 1910.147 App. A “Typical minimal lockout procedure” can be used as a guide for the development of site-specific procedures. A sample procedure is also offered in your OSHA Manual, Section 20, Appendix C.
  • Use only specially designed and designated lockout/tagout devices authorized only for energy control. Lockout padlocks must only be used for lockout purposes.
  • Ensure that lockout/tagout devices identify the individual users.
  • Establish a policy that permits only the employee who applied a lockout/tagout device to remove it.
  • Inspect energy control procedures at least annually.
  • Provide effective training for affected and authorized employees. Refer to GAWDA OSHA Manual, Section 20, for definitions of affected and authorized employees.
  • Comply with the additional energy control provisions when machines or equipment must be tested or repositioned, when outside contractors work at the site, in-group lockout situations, and during shift or personnel changes.

What Employees Need to Know
Provide awareness training to all employees working in or around an area where energy isolation may occur. They must be trained so they understand the purpose and use of energy isolating devices and they are never to attempt to remove or bypass the device or attempt to operate any equipment or machinery that is locked or tagged out.

Authorized employees – need to be trained to ensure they know, understand and follow the applicable provisions of the hazardous energy control procedures. The training must cover at least three areas: aspects of the employer’s energy control program; elements of the energy control procedures; and the various requirements of the OSHA standards related to lockout/tagout. They must possess the knowledge and skills necessary for the safe application, use and removal of energy controls.

What You Should Do Now
If you have any questions regarding your compliance with this standard, the following is recommended:

  • Assign someone in your organization the responsibility to determine if you have a lockout/tagout program that is working properly.
  • Review your program against the most critical requirements from the OSHA standard listed above. It also is suggested that you measure the effectiveness of your program by utilizing the “Safety Checklist” for lockout/tagout on page 18, Section 8, of the GAWDA OSHA Manual.
  • If you don’t have a program or if your program is deficient, assign someone to develop or upgrade your program by becoming familiar with the standard. You can access the complete standard at http://www. osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804. Additional help on understanding the standard and what is required for compliance is in the GAWDA OSHA Manual, Section 20, entitled Lockout/Tagout.
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    Meet the Author
    GAWDA OSHA & EPA Consultant Thomas W. Eynon is senior associate at B&R Compliance Associates LLC, based in Merritt, North Carolina. Members can reach him at 252-745-7391 and at tom.eynon@brcompliance.com.