5 Common Lockout/Tagout (LOTO) Violations and How to Avoid Them

If you’re a company with equipment and machinery being operated in the workplace, lockout/tagout is probably one of your most important programs. Did you know it’s also one of the most cited standards according to OSHA?  In fact, violations of the Control of Hazardous Energy standards (or lockout as it’s also called) have made it onto OSHA’s Top 10 most frequently cited standards list for at least the past 10 years, and last year was no different. For fiscal year 2023, lockout violations came in at number 6 on the list with 2,554 violations which is up 17% over fiscal year 2022. According to the various citations issued to employers last year, there were five main sections of the lockout standards that seem to be violated the most and we’re going to go over each one, offering a few suggestions along the way.  

1. 1910.147(c)(4): Energy Control Procedures  

29% of the 2,554 lockout citations issued in 2023 had to do with energy control procedures. If you’re not familiar, an energy control procedure is a set of written steps or guidelines detailing how to safely isolate and de-energize machinery and/or equipment prior to maintenance or servicing to keep workers from being exposed to harmful stored energy. In other words, it’s an instructional for how to safely perform work on equipment without coming into contact with stored energy.  

While OSHA does not provide a required format for these written procedures, they are quite specific about what must be included in a compliant energy control procedure. Surprisingly, the list is not very long and only includes four things:  

• 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 

Unfortunately, missing procedures are the main reason for citations of this section of the lockout standards but that’s not the only thing. The other most common reason for citations involving energy control procedures has to do with energy sources missing from the procedures. Employers sometimes only include the most common energy sources, omitting things like gravitational energy because they either don’t realize it’s a contributing energy source or because they don’t think it’s important or required. If you’re unsure of whether your energy control procedures are adequate or maybe you’re just looking for a new template to use, we’ve got you covered. Our energy control procedure template will help get you moving towards creating compliant energy control procedures.  

2. 1910.147(c)(7): Training and Communication 

17% of the lockout citations issued in 2023 were related to training and communication. This particular section of the lockout standard is expansive and covers things like training for authorized and affected employees, communication methods involving the use of tags, who’s allowed to perform lockout and how affected employees are to be notified prior to and after lockout has taken place. When it comes to training, it’s not just authorized employees who have to be trained. Affected employees need training too because even though they aren’t physically performing lockout on equipment, they are part of the lockout scenario. Affected employees need to understand what lockout is and to recognize the potential hazards to themselves and their authorized co-workers when lockout is taking place.  

In their quest to simply things, employers will often make the mistake of lumping both types of lockout employees into the same training. While there is a lot of overlap in the content provided to both affected and authorized employees, it’s not a good practice to provide the same training to both camps. In fact, employers should draw a very clear line of demarcation between affected and authorized employees to prevent any misunderstandings where lockout is concerned. Several things employers can do to minimize problems are to do the following:  

• Officially designate workers as either affected or authorized from day one, keeping a detailed list of those designations   

• Provide separate training for affected employees that covers just what they need to know  

• Create an acknowledgement for affected employees to sign stating they understand their lockout responsibilities  

For those companies who want to take things a step further, consider creating a shadow board for authorized lockout users to leave no doubt about who is authorized to perform lockout/tagout activities.  

If you’re looking for a way to better manage your lockout training program, take a look at our Training Management module which offers the ability to deliver your own training but also purchase a complete training library which includes lockout/tagout training topics, among many others.  

3. 1910.147(c)(6): Periodic Inspections 

Coming in third with 14% of the lockout citations issued in 2023 are violations of the part of the lockout standard that requires periodic inspections. Even though this section of the standard is very small with just six requirements making up the whole section, those six requirements seem to cause a lot of grief for employers. Some of this confusion has to do with a mindset that inspections are for things and not people, which in this case isn’t correct. OSHA is absolutely requiring employers to periodically inspect both the energy control procedures and the authorized employees using them.  

There are three things employers are trying to determine when conducting periodic inspections:  

1. Whether the steps in the energy control procedure are being followed. 

2. Whether the employees involved know their responsibilities under the procedure. 

3. Whether the procedure provides the necessary protection, and what changes, if any, are needed.

The other thing employers seem to miss in this section is a requirement to annually certify the completion of periodic inspections and capture specific information in the process. OSHA requires these written certifications to include the following items:  

• The machine or equipment on which the energy control procedure was used 

• The date of the inspection 

• The employees included in the inspection 

• The name of the inspector who performed the inspection 

A great way to complete these inspections is using our Periodic Lockout Inspection Form template. This template will walk you through the process for completing each inspection and provides a place to track deficiencies and signatures. Additionally, to make it easier to keep up with these inspections and to prevent any of them from slipping through the cracks, we’ve also created a Periodic Inspection Log where you can log and track up to three years of periodic inspections.  

4. 1910.147(c)(1): Energy Control Program   

10% of the lockout violations issued in 2023 dealt with the requirement to develop an Energy Control Program that includes energy control procedures, employee training and periodic inspections, each of which as to satisfy the requirement to ensure before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.2 

This should be the easiest part of the standard to be in compliance with however, if an employer is already lacking energy control procedures, adequate employee training and periodic inspections, it would be impossible to be in compliance with this section of the standard. Avoiding a citation for 1910.147(c)(1) really requires the employer to be up to speed on their current program, how it functions and whether it sufficiently satisfies other parts of the standards. 

5. 1910.147(d): Application of Control 

Last but not least, coming in 5th with 9% of the 2,554 lockout citations written in 2023 are the application of control violations. If you’re not familiar with what this is, it’s where OSHA specifies what elements must be included in a company’s energy control procedures and the sequence in which they must be performed. There are six elements that must be included in every energy control procedure and those six elements are: 

1. Preparation for shutdown 
2. Machine or equipment shutdown 
3. Machine or equipment isolation 
4. Lockout or tagout device application 
5. Stored energy 
6. Verification of isolation

The reason for so many citations of this part can sometimes be attributed to the wrong people being tasked with lockout procedure creation. Many times it’s the EHS person who is given the responsibility of creating these procedures and while the EHS person may understand lockout, understanding the energy sources and means of controlling them for each piece of equipment is quite another thing. Creating energy control procedures should really be a collaborative effort between EHS and maintenance so that the procedures will be complete from both a maintenance and a regulatory standpoint.  

Final Thoughts  

Being in compliance with federal lockout standards doesn’t have to be difficult. It just requires a good understanding of what’s required and the right tools, like those offered by EHS Insight. Whenever you’re ready to improve your lockout program, we’re ready to help.