How to write a Lockout/Tagout (LOTO) procedure that OSHA loves

According to recent data, OSHA writes more citations to manufacturers for violations of Lockout/Tagout than any other OSHA standard. In fact, 13% of all citations, and 21% of all penalty dollars are directly related to Lockout/Tagout violations.

One of the most common violations under the umbrella of lockout/tagout, is failing to have adequate written procedures for specific machines or equipment. Most commonly, this means the employer has no procedures whatsoever, but OSHA will also issue citations if procedures are developed, but they are inadequate.

When employers fail to “drill down” deep enough into the OSHA rule, they miss the fact that it has very specific requirements for the content and format of written procedures. As a result, they may develop a single “general” procedure intended to cover every piece of machinery or equipment, and/or they may develop overly general and brief procedures, such as:

“Step 1 – Turn off machine

Step 2 – Apply lock and tag”

Frankly, it wasn’t that long ago, that OSHA’s enforcement policy on the content and format of the procedures was much more permissive, and very basic and general procedures were frequently accepted. But those days are long gone.

So here are some tips for developing a written Lockout/Tagout procedure that OSHA loves.

1. Identify machines and equipment that may require a procedure. In summary, this is any machine or equipment on which your employees perform service or maintenance activities, such as installation, set up, tooling changes, maintenance, repair, inspection, etc. AND which has energy sources which may cause injury to employees during those activities, if not properly controlled. Note that there are 3-4 key exceptions to the requirement, so you might check each of the machines you identify to see if one of those exceptions applies.
2. Develop a written inventory of the machines you identify. This isn’t technically required, but will aid in the procedure development process. The inventory should include at least the following; name and location of the machine, names and job titles of authorized and affected employees, means for normal shut down, an inventory of hazardous energy sources the machine utilizes, each energy sources’ hazards, magnitudes, and proper methods for isolating, and proper methods for verifying that each energy sources has been rendered safe after application of lockout/tagout.
3. Develop a standard format for your written procedures. The requirements to have written procedures are found in 1910.147(c)(4). This section also describes the key exception to that requirement – the so-called “readily identifiable” exception. This section also goes on to describe required content for the procedures. 29 CFR 1910.147(c)(4) requires that the procedures include

• A specific statement of the intended use of the procedure;
• Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;
• Specific procedural steps for the placement, removal and transfer of lockout devices 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.

Note that the word “specific” or specifically” is used at least five times in this section. That’s not a coincidence.

Requirements for the procedures are further explained in 29 CFR 1910.147(d) which explains the sequential steps that must be addressed in the procedure. If you read between the                  lines, you’ll note that all procedures must have at least six procedural steps AND procedures for removal of lockout/tagout devices.

4. Populate the standard procedure form with the data from the inventory.  

While not technically required, I normally recommend the following:

• Incorporate photos into the procedure to illustrate each specific procedural step.
• Be crystal clear in identifying who the authorized and affected employees are for each individual procedure.
• Use the “man on the street” rule. In other words, your procedure should be so clear and understandable that you would be able to hand your procedure to a random man on the street, who has never set foot in your facility, and he would be able to lock/tag the machine out, using just the written procedure.

As you can see, finding a procedure format which is consistent, understandable and meets OSHA’s requirements is a key first step in this process. You can develop your own form for this, but that might take hours or days or work, and there’s no way to know if you’ve gotten it right. So be sure to check out the “downloads” section of our website for a template form which is based on OSHA requirements and guidance. The form gives you step-by-step instructions on completing the procedures. It will save you countless hours for less than $50!

Please call Paul at (612)597-6463 or email paul@soteraconsulting.com if you have questions.