It is an employer’s responsibility to provide a safe work environment for his/her employees. As such, one of the areas of great safety risk to employees concerns hazardous energy. Subsequently, a well developed and effective program to control hazardous energy through a lockout/tagout (LOTO) program is of utmost importance. Occupational Safety and Health Administration (OSHA) has promulgated rules with regards to this area in 29 CFR 1910.147.

The purpose of a LOTO program is to ensure before an employee performs any servicing or maintenance on machinery or equipment, where the unexpected energizing, startup or release of any type of energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative. The employer needs to establish a program consisting of energy control procedures, employee training and periodic inspections. One of the most important and time-consuming of these tasks is the development of the energy control procedures. The regulatory standard describes this specific requirement in 29 CFR 1910.147[c](4). Exceptions to the requirement also are noted in this section of the regulation.

Training is another critical component of the LOTO program. Employees with potential exposure to hazardous energy sources shall be instructed in the safety and significance of the LOTO program and specific LOTO procedures. Employees authorized to perform LOTO shall receive training commensurate with their responsibilities in accordance with OSHA requirements. Each new or transferred "affected" employee and "other" employees who work with operations, who may be in the area, shall be instructed in the purpose and use of the lockout or tagout procedure. Employees who may work in areas where LOTO is being performed are considered affected employees. Persons working exclusively in office areas are not considered affected employees, but rather fall into the category of “other” employees. Even though these individuals do not perform LOTO activities or are even in the areas where these tasks take place, they are still required to receive awareness training about the program.

Finally, the area where many facilities fall short of the regulatory requirements is in regards to the required periodic inspections. The regulations state this requirement must be performed as least annually. Documentation of these periodic inspections is about the only way to effectively demonstrate the requirement is completed. In this documentation, the employer should certify the periodic inspections have been performed. The certifications shall identify the machine or equipment on which the energy control procedure was being utilized, date of the inspection, employees included in the inspection and the person performing the inspection.

Having a fully developed LOTO program and creating a culture of safe work practices is the first step in protecting your employees from the dangers of hazardous energy. The brevity of this article does not fully convey the importance of this critical safety program, but it does provide an overview of a few of the critical components that must be considered as a facility develops their program. After the program is developed, implementation is just as critical. A program is of little value if it is not properly implemented and practiced.