In terms of sheer number, citations for violating hazardous energy control (lockout/tagout, aka LOTO) typically hit about the middle of OSHA’s annual list of violations with the most citations. To avoid being one of those companies, begin with understanding the scope, application, and purpose of 29CFR 1910.147, sometimes referred as “the LOTO regs.”
This standard (29CFR 1910.147) “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 cause injury to employees” [29CFR 1910.147(a)(1)(i)].
Did you notice there’s no qualifier before “energy”? It does not say electrical energy — it just says energy. Energy can be kinetic, for example, when the ram on a 100-ton press is not sitting at its lowest position. A coiled spring is another form of stored energy. Energy might be stored pneumatically, hydraulically, or chemically. Often, it’s not the energy itself that is the danger, but rather, what that energy propels or operates.
It is not enough to lock out the breaker. You must control all of the sources of hazardous energy. This can include bringing the ram down, bleeding off the compressed air, opening the bypass valve, pulling the lever to release the spring, and so forth. In short, if it might move and injure an employee, you must ensure it does not move. You prevent current from moving through branch-circuit conductors by opening the supply breaker (or other disconnecting device) and then locking it in the open position. You may have to do something analogous with the air-driven cutting tool in front of which a maintenance worker might put his hand.
There are five exceptions noted in 29CFR 1910.147(a)(1)(ii)(A) through (E). For example, it doesn’t apply to oil and gas well drilling and servicing.
Now, let’s move on to the application. It’s similar to the scope, in that it applies to the control of energy during “servicing and/or maintenance of machines and equipment” [29CFR 1910.147(a)(2(i)]. It does not apply to normal operation [29CFR 1910.147(a)(2)(ii)], unless an employee is required to:
- Remove a guard, bypass, or other safety device.
- Place any part of his body into an area that is referred to as the “point of operation” or where an associated danger exists during a machine operating cycle. For example, an operator manually feeds a punch press by placing a new blank under the punch.
It also does not apply to:
- Cord-and-plug-connected equipment where the employee has exclusive control of the plug and can unplug the equipment to prevent it from starting. The same logic extends to battery powered equipment, so for example, you remove the battery from your reciprocating saw before changing the blade.
- Hot tap operations involving transmission and distribution.
Which brings us to the purpose [29CFR 1910.147(a)(3)]. It is for the employer to establish a program and utilize procedures “for affixing appropriate lockout devices or tagout devices to energy isolating devices and to otherwise disable machines or equipment to prevent unexpected energization, start-up, or release of stored energy….”. That sentence then concludes with the whole point of 29CFR 1910.147, which is “to prevent injury to employees.”
