I promise you; these are written in the blood of many who have perished – THEY ARE LOTO FACTS, and they are not wrong. If employers could grasp these simple facts, many limbs and lives could be saved yearly.
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The standard is called “The Control of Hazardous Energy”. It is NOT Lockout AND Tagout; it is either – or.
- LOTO applies ANYTIME a worker has to REMOVE a guard, BYPASS a guard, or place any part of your body into the point of operation during “servicing or maintenance” activities. (NOTE: OSHA has provided an extensive listing of these tasks)
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Lockout is the preferred method; however, if an employer can demonstrate Tagout to be equally effective as Lockout, then and ONLY then can tagout be used as the primary means of energy control.
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When Tagout is used in place of Lockout, TAG-PLUS must be utilized to demonstrate it is equally effective.
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We can NOT take just any lock, put some Tag on it, and claim it to be a Lockout Lock.
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Lockout Locks must be SINGULARY IDENTIFIED by either Color, Shape, or Size. Then those Lockout Locks (specific color, shape, or size) can ONLY be used for LO and NOT for any other purposes on site.
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Energy Control practices are ALL ABOUT EACH WORKER having EXCLUSIVE CONTROL of EACH isolation device protecting them. This applies even in Group LOTO practices.
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Lockout Locks on energy isolation devices MAY BE KEYED A LIKE; however, PERSONAL Lockout Locks MUST BE INDIVIDUALLY KEYED, and the worker MUST solely possess his/her key(s) while their lock(s)are in use.
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Periodic Inspections must be done ANNUALLY on EACH Authorized Employee. These inspections MUST be performed by an AUTHORIZED EMPLOYEE not associated with the LOTO being inspected. Hint: Hiring a contractor/consultant to perform your inspections, yet they were never trained to be “authorized” within your program, is NOT compliant and can lead to serious misses in your inspection program. If the LOTO being inspected utilized Tagout to control the isolation devices, then that “periodic inspection” MUST also include a discussion/verification with the “Affected Employee(s).”
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MINOR SERVICING (there is NO such thing as minor “maintenance”) is an EXCEPTION – LOTO is the rule! For minor servicing to apply to a situation, there are FIVE (5) hurdles to cross: 1) The task is part of NORMAL PRODUCTION, 2) there is NO DISASSEMBLY involved, 3) the task is ROUTINE, 4) the task is REPETITIVE, 5) the task is INTREGAL. The employer MUST DEFINE and QUANTIFY “routine, repetitive, and integral” to ensure this “exception to the rule” is properly applied and the safeguards are formally controlled to ensure the worker is adequately protected using alternative safeguards that are as equal to the hazardous energy sources being LOTO’ed.