LOTO Training Requirements

OSHA’s performance-oriented LOTO training program requirements, as detailed in §1910.147(c)(7), were developed to provide employer flexibility and deal with various workplace conditions. The specific training material will vary from workplace to workplace and even from employee to employee within a single workplace, depending upon:

1. the complexity of the machine or equipment and the procedures,
2. the employee’s job duties,
3. their responsibilities, and other factors

To provide adequate information, any LOTO training program MUST address, AT A MINIMUM, the following three areas:

1. the purpose and function of the energy control program;
2. the elements of energy control procedures relevant to employee duties; and
3. the pertinent requirements and prohibitions of the LOTO standard.

The training, detailed in paragraph 1910.147(c)(7)(i), MUST be specific to the needs of authorized, affected, and other employees, and the degree of knowledge required for these three employee groups diminishes from authorized employee to affected employee and from affected employee to other employees.

Authorized employees are those responsible for implementing the energy control procedures (e.g., an employee who locks out or tags out machines) and/or performing the servicing or maintenance activities. These employees must have the knowledge and skills necessary to safely apply, use, and remove energy-isolating devices. For employers with many procedures, each authorized employee must be able to safely perform the work required by any energy control procedure that he may be called upon to use, however rarely. Therefore, these employees need training in the applicable aspects of the procedure and its proper utilization, together with training in the:

1. Recognition and understanding of all applicable hazardous energy sources;
   
2. Type and magnitude of the hazardous energy sources associated with machinery or equipment on which they will perform servicing or maintenance; and
   
3. Energy control procedures, including the methods and means to isolate and control relevant energy sources. 

Affected employees are those employees (e.g., machine operators and material handling specialists) who operate or interact with machines that are serviced and maintained pursuant to energy control procedures, as well as those employees (e.g., general laborers) who are assigned to work in areas where energy control procedures are utilized to service or maintain machinery. In other words, employees who are assigned to areas where servicing or maintenance work is performed but who do NOT implement energy control procedures or perform servicing and/or maintenance work need only be trained as affected employees. Affected employees must be able to:

1. Recognize LOTO devices IMMEDIATELY;
   
2. Recognize when the energy control procedure is being used;
   
3. Understand the purpose and use of the procedure; and, most importantly,
   
4. Understand the importance of NOT tampering with lockout or tagout devices and not starting or using equipment that has been locked out or tagged out.

Affected employees are REQUIRED to be instructed in these matters and be informed that disregarding or violating the prohibitions imposed by the energy control procedure could endanger their own lives or the lives of their co-workers.

All other employees who may be in an area where energy control procedures may be utilized MUST receive instruction regarding the energy control procedure and the prohibition against removing a lockout or tagout device and attempting to restart, reenergize, or operate the machinery. This instruction, which can be provided during new employee orientations, by use of employee handbooks, or through safety meetings, MUST convey:

1. what the energy control program does,
2. the program’s prohibitions, and
3. that the employees are NOT to touch any locks, tags, energy isolation devices, or equipment covered by the LOTO program.

This instruction is required for ALL employees who are not classified as “authorized” or “affected” employees unless the company establishes, communicates, and enforces a policy prohibiting an employee or group of designated employees from ever being in an area where servicing or maintenance is performed pursuant to an energy control procedure. Thus, for example, this training would not be required for an office administrator who is prohibited from entering production areas where all servicing and maintenance activities are performed. On the other hand, this training would be required for a salesperson who rarely goes into production areas but who may go into production areas to discuss product specifications associated with a particular order while servicing or maintenance work may be being performed. In addition, if tagout devices are used, all employees in all three of the aforementioned categories must receive training regarding the inherent limitations of tags.

The training, described in paragraph 1910.147(c)(7)(ii), must inform employees that:

1. Tags are essentially warning labels affixed to energy-isolating devices, and therefore do not provide the physical restraint associated with locks;
2. Employees are NOT to remove tags attached to energy isolating devices by authorized employees (unless they are permitted to do so by the employer’s energy control procedure due to the unavailability of authorized employees at the workplace – in accordance with paragraph 1910.147(e)(3) exception), and that they are NEVER to BYPASS, IGNORE, or in any manner DEFEAT the tagout system;
   
3. Tags MUST be legible and understandable by authorized and affected employees, as well as other employees who work, or may work, near operations using the energy control procedure;
   
4. The materials used for tags, including the means of attaching them, MUST be able to withstand the environmental conditions encountered in the workplace;
   
5. Tags invoke a FALSE SENSE of security, and employees MUST understand that tags are only part of the overall energy control program; and
   
6. Employees MUST attach tags SECURELY to energy-isolating devices to prevent the removal of the tags during use.

Although the standard does NOT prescribe annual refresher training or a set frequency for retraining, it does REQUIRE training under specific circumstances. It specifies those issues that the training MUST cover; for example, the employer MUST provide initial training before the servicing and maintenance activities begin and MUST provide retraining as necessary. However, retraining is REQUIRED, by paragraph 1910.147(c)(7)(iii), if a periodic inspection reveals, or an employer has reason to believe, that there are deviations from the application of the energy control procedure or inadequacies in an employee’s knowledge of or use the energy control procedure. Additionally, retraining must be provided for all authorized and affected employees whenever there is a change in:

1. Job assignments;
   
2. Energy control procedures; or
3. Machinery, equipment, or processes that present a new hazard.

The retraining MUST reestablish employee proficiency and, if relevant, address new or revised energy control procedures. The scope and content of all the retraining must be based upon the severity of the problems encountered and must be directed toward eliminating those problems. Unless employees are retrained whenever deviations or inadequacies are discovered (or when the employer has reason to believe a problem exists), the overall effectiveness of the energy control program will diminish over time.

Properly trained employees, who are proficient in their energy control responsibilities, are critical to the success of the energy control program.

NOTE: OSHA issued a citation of 29 CFR 1910.147(c)(7)(iii)(A), alleging that the employer did not give lockout/tagout retraining to all employees who had been given new job assignments. The violation addressed two employees, one a pipe-fitter for 20 years, the other an automotive mechanic, who were reclassified as maintenance employees during a reorganization of the plant. The Occupational Safety and Health Review Commission (OSHRC) affirmed the citation holding that these employees were required to perform jobs they had not performed before and were not familiar with the associated lockout/tagout hazards. See Caterpillar, Inc., 17 BNA OSHC 1584, (No. 93- 2230, 1996).

Training certifications, which contain each employee’s name and dates of training, are required, by paragraph (c)(7)(iv), for both initial training and retraining. These training records must be kept only for the last training activity. However, the employer must certify that the training (required by the LOTO standard) has been given to each employee covered by the standard. In other words, employers must be able to demonstrate that the required LOTO training, which is directly relevant to the duties of the employee, was provided and understood. In evaluating whether an employee has been adequately trained, Compliance Safety and Health Officers (CSHOs) need to examine the employee’s responsibilities under the energy control program in relation to the elements of the LOTO standard.

NOTE: The American National Standard on the Control of Hazardous Energy – Lockout/Tagout And Alternative Methods (ANSI/ASSE Z244.1-2003; Communication and training, Section 5.5) utilizes an approach that, in part, directs users (employers) to inform all personnel regarding the provisions of the energy control program to an appropriate level and to apprise appropriately authorized individuals of aspects of the program. Very importantly, this consensus standard emphasizes that the user should avoid the exclusive use of generic training programs to ensure that authorized individuals adequately understand the user’s specific program and that a structured program should be used to make training understandable to all authorized individuals regardless of their education, primary language, or disabilities. The section on Communication and training, however, differs from the specific training requirements contained in the OSHA LOTO standard and utilizes a more general approach to the subject. Some of the §1910.147(c)(7) issues that are not explicitly addressed in the consensus standard include the requirement to:

1. Train each employee in the elements of each energy control procedure relevant to his job duties and responsibilities (whereas Section 5.5.2
   permits employers to train personnel on a sample of machine-specific procedures);
   
2. Train employees in the pertinent requirements of the LOTO standard;
   
3. Train affected employees and other employees for the subject matter contained respectively in §§ 1910.147 (c)(7)(i)(B) and (c)(7)(i)(C);
   
4. Provide additional employee training requirements on the limitations of tags, as required by §1910.147(c)(7)(ii), when employees utilize tagout
   systems; and
   
5. Provide retraining to re-establish employee proficiency pursuant to the §1910.147(c)(7)(iii)(C) requirements.

According to the LOTO requirements, training MUST be commensurate with each employee’s job responsibilities. Employees have the understanding, knowledge, and skills required to safely apply the applicable provisions of the energy control procedure(s). The ANSI Z244.1-2003 consensus standard does not affect the employer’s obligation to meet all of the requirements contained in 1910.147(c)(7) and (d)(1).