Now that you have considered whether you are covered under the LOTO standard, it is time to consider whether you actually meet the basic requirements of the standards and have proper energy control procedures for each piece of equipment.
Do We Meet the Basic Requirements under the LOTO Standard?
If employees are exposed to hazardous energy during servicing and maintenance activities and one of the exceptions above do not apply, then employers must establish, at a minimum, a program consisting of detailed energy control procedures for each piece of equipment, employee training, and periodic inspections. 29 C.F.R. § 1910.147(c)(1).
Do We Need and Have Detailed Energy Control Procedures?
Energy control procedures for each piece of equipment must be developed, documented, and utilized when employees are engaged in servicing and maintenance activities unless all of the following elements exist:
- The machine or equipment has no potential for stored or residual energy or re-accumulation of stored energy after shut down which could endanger employees;
- The machine or equipment has a single energy source which can be readily identified and isolated;
- The isolation and locking out of the energy source will completely de-energize and deactivate the machine or equipment;
- The machine or equipment is isolated from the energy source and locked out during servicing or maintenance;
- A single lockout device will achieve a lock-out condition;
- The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
- The servicing or maintenance does not create hazards for other employees; and
- The employer, in utilizing this exception, has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.
29 C.F.R. § 1910.147(c)(4)(i).
If you do not meet the exception above, written procedures are required for each piece of equipment. They should all contain:
- a specific statement of the intended use of the procedures;
- specific procedural steps for shutting down, isolating, blocking, and securing all machines or equipment to control hazardous energy;
- specific procedural steps for the placement, removal, and transfer of lockout or tagout devices and the responsibility for them; and
- specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures. 29 C.F.R. § 1910.147(c)(4).
Separate written procedures should be developed for each machine or equipment when employees may be engaged in servicing and maintenance activities. However, similar machines and/or equipment (such as those using the same type and magnitude of energy), which have the same or similar types of controls, and which can be rendered safe using the same sequential procedural steps, can be covered by a single procedure, if that procedure satisfactorily addresses the hazards and specifies the measures for controlling the hazards.
For purposes of procedure grouping, machines and equipment may be grouped together as one procedure if all are listed or identified in the scope of the energy control procedure and if they all have the same or similar:
- Procedural steps for shutting down, isolating, blocking, securing, and dissipating stored energy in machines or equipment;
- Procedural steps for the placement, removal, and transfer of the lockout or tagout devices and the responsibility for them; and
- Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures.
On the next installment, we will discuss the training requirements under OSHA’s LOTO standard.