Sharon Spielman outlines OSHA's lockout/tagout inspection guidelines as well as what questions your employees should anticipate regarding your company's lockout/tagout training program should an OSHA compliance officer ask.

As I outlined last month, the Occupational Safety and Health Administration's "Control of Hazardous Energy" standard -- also known as the lockout/tagout standard -- specifically addresses practices and procedures necessary to disable machinery or equipment and to prevent the release of potentially hazardous energy while maintenance and servicing activities are being performed. The standard applies to any source of mechanical, hydraulic, pneumatic, chemical, thermal or other energy. In this month's installment, I outline OSHA's lockout/tagout inspection guidelines as well as what questions your employees should anticipate regarding your company's lockout/tagout training program should an OSHA compliance officer ask.

Inspection Guidelines

The "Control of Hazardous Energy" standard (29 CFR 1910.147) incorporates performance requirements that allow employers flexibility in developing lockout/tagout programs suitable for their particular facilities. According to OSHA's compliance directive for lockout/tagout, a compliance officer shall determine whether the employees are performing servicing and maintenance operations. If so, the compliance officer shall further determine whether the servicing and maintenance operations are covered by 29 CFR 1910.147.

The compliance directive also states that evaluations of compliance with 29 CFR 1910.147 will be conducted during all general industry inspections. The review of records will include special attention to injuries related to maintenance and servicing operations.

What to Expect During Evaluation

The following is a general framework of what to expect from the compliance officer during inspections.

Employee Interviews. Your training programs for "authorized," "affected" and "other" employees will be evaluated (see sidebar for definitions of employee types). The compliance officer will interview a representative sampling of selected employees as a part of this evaluation (29 CFR 1910.147 (c)(7)(i)). The training of authorized employees will be verified to include:

  • Recognition of hazardous energy.

  • Type and magnitude of energy found in the workplace.

  • Means and methods of isolating and/or controlling energy.

  • Means of verification of effective energy control.

  • Purpose of the procedures to be used.

You also will have to verify that affected employees have been instructed in the purpose and use of the energy control procedures. You also will have to verify that all other employees who may be affected by the energy control procedures are instructed about the procedure and the prohibition relating to attempts to restart or reenergize such machines or equipment. Your manner of enforcing a lockout/tagout program also will be evaluated.

Hazard Analysis. You will be asked for any hazard analysis or other basis on which the program relating to the standard was developed. Although this is not a specific requirement of the standard, when provided, such information will aid in determining whether the program is adequate. It should be noted that the absence of a hazard analysis does not indicate noncompliance with the standard.

Documentation. You may be asked to provide documentation of the procedures for the control of hazardous energy, including:

  • Shutdown.

  • Equipment isolation.

  • Lockout/tagout application.

  • Release of stored energy and verification of isolation.

  • Certification of periodic inspections.

  • Certification of training.

The documented procedure must identify the specific types of energy to be controlled. In addition, in instances where a common procedure is to be used, the specific equipment covered by the common procedure must be identified by at least type and location. Identification of the energy to be controlled may be by magnitude or type of energy.

If You're Found Out of Compliance

If deficiencies are identified, the compliance officer will evaluate your compliance with specific requirements of the standard, paying particular attention to the following:

  • Evaluate compliance with the requirements for periodic inspection of procedures.

  • Ensure that the person performing the periodic inspection is an authorized employee; that is, someone other than the employee(s) utilizing the procedure being inspected.

  • Evaluate compliance with retraining requirements that result from the periodic inspection of procedures and practices, or from changes in equipment/processes.

  • Evaluate your procedures for assessing and correcting any inadequacies that are identified during periodic energy control procedure inspections.

  • Identify the procedures for release from lockout/tagout (including replacement of safeguards, machine or equipment inspection, and removal of nonessential tools and equipment); safe positioning of employees; removal of lockout/tagout device(s); and notification of affected employees that servicing and maintenance is completed.

The lockout/tagout standard is a performance standard; therefore, the OSHA field staff will provide additional guidance to assist in effective implementation by employers and for uniform enforcement.

It is important for facilities that use thermal processes to take precautions and follow lockout/tagout procedures. You cannot be sure of when a compliance officer is going to walk through your door. More to the point, no one wants to call OSHA in after an incident has occurred. The standard is intended to satisfy OSHA's mission -- "to save lives, prevent injuries and protect the health of America's workers" -- which is some-thing every employer wants.

In future installments, I will talk specifically about what your training program must cover, lockout vs. tagout and the types of devices that can be used to control hazardous energy sources.

Sidebar: Defining Employee Types

According to OSHA's "Control of Hazardous Energy" standard, employee types can be defined as follows:

  • Affected Employee. One whose job requires him to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him to work in an area in which such servicing or maintenance is being performed.

  • Authorized Employee. A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under the lockout/tagout standard.

  • Other Employee. A person whose work operations are or may be in the area.

Depending on the function of your employee and the definition they fall into according to OSHA, they will have to be trained appropriately for lockout/tagout.