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Avoiding Lockout/Tagout Violations

Lockout/Tagout (LOTO) finished fifth on OSHA's Top 10 list for 2005. Last year, it was fourth. LOTO is confusing. It's also technical and hard to comply with. So, while its exact place might change from year to year, as long as OSHA keeps a Top 10 you can bet LOTO will be on it.

This article will discuss the "TO" aspect of LOTO. When you shut off a piece of equipment or machinery for servicing, you must ensure that it remains shut off, that it isn't unexpectedly energized or activated. The tagout is designed to ensure that people in the area know the equipment is being serviced. OSHA citations are a cheap price to pay for tagout mistakes. Accidental start up of machines during servicing often causes nasty accidents resulting in death, amputation and other grizzly injuries.

A Primer on TO Requirements
OSHA requires employers to control the release of hazardous energy by using either lockout or tagout devices during servicing (or, in some cases, a combination of both):

Lockout involves applying a locking device to the equipment's energy isolating device. It imposes a physical barrier to prevent start-up of the equipment.

Tagout involves notifying people in the area that the machine is being serviced so they don't start it up. Tagout devices are prominently displayed tags securely fastened to a piece of equipment's energy isolating device while the equipment is being serviced. The tagout device warns employees and others not to operate the equipment until an authorized employee removes it.

Since they don't physically bar starting of the equipment, tagout devices are more risky than lockouts. Consequently, you must meet certain additional requirements when using tagout instead of lockout:

  • The piece of equipment being serviced must not be capable of being locked out;
  • You must be able to demonstrate that using tagout will provide a level of safety "equivalent to that under a lockout program."

The Equivalent Safety Requirement
As you might suspect, it's the equivalent safety part that causes most of the confusion. To demonstrate equivalent safety you must fully comply with all of the technical aspects of the tagout provisions set out in the LOTO standard.

But even that isn't enough. You must also use additional means, such as removing the serviced equipment's isolating circuit element, blocking the equipment's control switch or removing its valve handle. Each of these measures reduces the likelihood of accidental energization during servicing.