Lockout Tagout

If we look close enough, we can see OSHA’s approach to some of its more extensive standards through the lens of its fitting into a formal Safety Management System.  The Control of Hazardous Energy (e.g., Lockout/Tagout) standard is one of these standards.  Using the old Plan→Do→Check→Act SMS model, we can breakdown 1910.147 into this model,…...

Today’s MSHA Fatality Report made me wonder how many LOTO programs require the SECONDARY SECUREMENT of large objects, even after the power source that normally moves the equipment has been locked out.  For example, cooling towers and condenser fan blades. I have experienced firsthand a piece of equipment two times involved were very large fan…...

Earlier today, I shared my thoughts on a critical safety step that is often not part of LOTO periodic inspections involving qualified electrical workers.  That article spurred a conference call with a client this afternoon.  That discussion led to the next layer of the proverbial onion being peeled back… Who should be responsible for managing…...

Scenario: You’re out and about, and you come up on two workers working on a piece of equipment.  You stop and engage the two workers on their energy isolation for their work.  One of the workers operates the machine and has it locked out as part of his end-of-shift cleaning tasks.  The other worker is…...

There is an evil myth regarding LOTO training and Periodic Inspections.  I recently had a lengthy discussion with a Labor Lawyer regarding the FACT that annual LOTO training does NOT satisfy the Annual Periodic Inspection requirements.  An employer is NOT required to perform annual training on LOTO, but they are REQUIRED to conduct a periodic…...

A federal investigation has found that the operator of a specialty frozen pizza manufacturing plant in Illinois could have prevented the death of a 29-year-old sanitation worker by following proper machine safety procedures.  OSHA CSHOs learned the sanitation worker suffered fatal injuries while working on the overnight shift under the supervision of the Pizza Company…...

A 29-year-old worker suffered the amputation of a fingertip while reassembling a pump, an injury the employer could have prevented by ensuring to shutdown and lockout the equipment to prevent it from unexpectedly starting during maintenance. OSHA investigated after the company reported the December 2022 injury and found the employer did not train workers on…...

This happens more often than most think: At 6:30 a.m. on December 7, 2022, an employee was removing wood bark from a de-barker machine at the CHANGE OF NIGHT SHIFT WHEN A DAY SHIFT COWORKER STARTED THE DE- BARKER. The employee was crushed and killed due to internal injuries. Had the worker performing the “cleaning”…...

We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)).  It is a topic of great debate, still in the Year 2023.  But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in…...

I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock.  This is different than what Federal OSHA allows.  Federal…...

In OSHA’s fiscal year 2022, the agency issued over 3,800 LOTO citations. Here is a breakdown of those citations… Top 10 by # of Citations Top 10 by Citations $ Full listing of Citations with Number of Citations and $… Membership Required You must be a member to access this content.View Membership LevelsAlready a member?...

Employers are required by 29 CFR* § 1910.147(c)(6) to conduct a periodic inspection of written hazardous energy control (lockout/tagout) procedures.  The inspection must be performed at least once annually [per 12-month interval, as stated in 1910.147(c)(6)(i)] because of the significant risks associated with inadequate energy control procedures or the failure to properly implement them [OSHA…...