A Ten Step Lockout/Tagout Program

Ultimately, management commitment comes not only from stated support, but rather from demonstrated support through implementation and accountability.

• By Berta Lippert, Robert E. Brown Jr.
• Mar 01, 2004

ARE you in charge of creating a lockout/tagout (LOTO) program for your company? If so, beyond being familiar with the standard, you must fully understand the process of creating and implementing a successful LOTO program that will ultimately save time, injuries, and possibly lives.

This one standard can have a tremendous impact on the approximately 3 million workers who service equipment throughout the United States. Successful LOTO programs have been credited with saving hundreds of lives since the standard requiring such a program was promulgated by OSHA more than a decade ago. Not only do successful programs save lives; they have prevented approximately 50,000 injuries each year. (See the OSHA Fact Sheet at www.osha.gov/OshDoc/data_General_Facts/factsheet-lockout-tagout.pdf.)

An effective LOTO program protects not only the workers performing the maintenance and service, but also the other employees working in the area who can be hurt if someone else isn't following the program requirements. OSHA estimates there are some 3 million workers who perform the maintenance and service and are directly affected, but there are also millions of others who work around those employees who may be affected as well. Someone must take ownership of this standard and protect them by establishing and enforcing an effective LOTO program.

History of the Standard
First, let's take a brief look at the history of the standard to give you an idea of its intent, as well as an understanding of what's required. LOTO (also known as the "Control of Hazardous Energy") started some 50 years ago with efforts by employers, unions, and trade associations, in conjunction with now well-known national consensus and safety organizations such as the National Safety Council (NSC), the American National Standards Institute (ANSI), and the National Fire Protection Association (NFPA).

These efforts led to the development of several consensus standards, which ultimately led to what today are the regulations enforced by federal and state agencies. OSHA's LOTO regulation was published in the Federal Register on Sept. 1, 1989. Although the LOTO regulation met with some resistance and court challenges by labor and industry organizations when first published, OSHA responded with final rule corrections and technical amendments that were published in the Sept. 20, 1990, Federal Register. While they call them something other than LOTO, many other countries also have promulgated regulations mandating the elimination of the unexpected start-up or release of hazardous energy that may cause injury or fatality.

What did everyone have in mind when drafting the OSHA standard? Despite the complexities of the hazards presented, they simply wanted to establish a program that would eliminate the injuries and fatalities associated with hazardous energy while performing service and maintenance activities.

Just how big is this problem? Does it warrant a dedicated standard? In short, yes. Several studies indicated the failure to establish an effective LOTO program resulted in significant increases in employee exposure to hazardous energy, and in the resulting injuries and fatalities. OSHA and the National Institute for Occupational Safety and Health conducted the studies using data relating to injuries and fatalities from 1974-84. To no one's surprise, the seriousness of the problem was quite evident and the significant risk resulting from exposure to hazardous energy clearly affected the majority of general industry. Findings relating to the cause of the incidents gathered from these studies indicated most were completely preventable. OSHA used this information to develop the currnt LOTO standard that is designed to prevent future incidents.

Now we know the program's importance, but just where should you start? One look at several pages of the standard can be intimidating. The following 10 steps provide guidance on one way to develop and implement this program successfully at your company.

Step 1: Plan for Success
The first step is to create a plan for you to follow to ensure successful implementation of your LOTO program. Implementing this safety program needs to be managed like any other initiative at your company. You must ensure the funding, time, and resources to make it successful.

Far too often, the responsibility is placed on someone with no knowledge of the requirements and/or no support or authority, which places that person in a position to fail. By creating a plan, you not only identify what will be required with regard to compliance, but also establish the foundation for a successful program.

Step 2: Understand the Requirements
The second step to creating and implementing a successful program is to understand the requirements applicable to your company's specific program. Most end users must follow the federal OSHA standard (29 CFR 1910.147). Those within the jurisdiction of state OSHA programs must follow your state-specific regulations.

Many state OSHA programs have adopted the federal LOTO standard. Four states currently have their own LOTO standards--California, Kentucky, Oregon, and Washington. While the principles of their programs are the same, review the state-specific differences to ensure full compliance at your company.

Step 3: Create a Company-Specific Program
The third step in this process will be for you to develop your company-specific LOTO written program. It is essential that you create a program specific to the operations of your company, paying particular attention to the types of equipment and processes it uses. Resist the temptation to use a boilerplate program found on the Web somewhere; instead, work with the service professionals who will ultimately be end users of the program and internal expertise to make the program "your own."

Step 4: Secure Commitment from Upper Management
The fourth step will be taking your newly written program to upper management and key stakeholders. In addition to providing commitment and support of the program, they need to understand the requirements, how they will be implemented at their facility, and why you have chosen to implement them in this fashion. Ultimately, management commitment comes not only from stated support, but rather from demonstrated support through implementation and accountability.

Step 5: Communicate
After you have the necessary buy-in and support from upper management and key stakeholders, you are ready to begin implementing the program. The first step in the implementation process will be this one, involving communication. You have to create initial awareness training about LOTO for your company. This creates a general understanding throughout the company of the importance and requirements of this program. (Note: This is also the time to introduce the accountability element being driven by management.)

Step 6: Determine What Needs LOTO Control
The sixth step is the process of identifying what requires LOTO control at your company. Survey your operations, maintenance, and facilities to identify where LOTO is required. This will generate a list of necessary procedures to be developed. The list should be reviewed annually and updated when any new equipment or process is added. (Note: This will be easier if you did an effective job at Step 3, ensuring that your written program is "company specific.")

Step 7: Create Equipment- and Area-Specific Procedures
The next step is perhaps the most critical element of the entire program and the one most often missed by most organizations: writing equipment- and area-specific LOTO procedures. This is often the stage where the program stalls.

Safety professionals need to partner with technicians and equipment experts to generate equipment- and area-specific LOTO procedures that employees can and will follow. These procedures also must be tested to ensure they are effective at protecting the worker.

Step 8: Obtain Hardware and Devices
Step 8 is the identification and acquisition of the necessary LOTO hardware and devices. Most of the devices required are easy to identify and obtain; it is the few unique valves or breakers for which you may struggle with identifying proper LOTO devices.

Don't be afraid to call on local vendors or distributors of LOTO devices. They often will come to your facility at no charge to assist you in identifying devices capable of meeting your control needs. (Note: If that doesn't work, talk to your internal maintenance personnel; some of the best devices these authors have seen were customized devices developed "in house.")

Step 9: Equipment- and Area-Specific Training and Authorization
The ninth step of this process is to complete equipment- and area-specific LOTO training. The initial, awareness-level training is a great start for everyone. But for the individuals performing service or maintenance, awareness training is simply not enough. This step involves a qualified individual taking the procedures created from Step 7 and training and authorizing all necessary personnel on those procedures.

Step 10: Measure the Effectiveness of Your Program
The tenth and final step in this program is to complete periodic inspections. This is not only legally required, but is also a necessary part of the process to ensure employees understand the procedures they are expected to follow, the intentions of the program, and their individual roles and responsibilities.

It is critical that your LOTO program be integrated into your "management of change" program. Changes in equipment or processes also may result in changes to equipment-specific procedures. These changes must be made, the new procedures tested, and training provided prior to start-up of the equipment after the changes.

You also must measure the success of your program. Often it can be difficult to determine how effective your training or overall LOTO program may be. However, it is critical that we make sure all of these efforts are effective. To do this, you can use qualitative measures such as routine assessments on the floor, ensuring employees are using the program while performing service or maintenance. You also may want to benchmark with others in your industry to determine quantitative measures they use to assess their programs accurately.

If you employ or manage any of the millions of workers directly or indirectly affected by this standard, following these 10 steps can assure you do your part in keeping that worker and others safe.

This article originally appeared in the March 2004 issue of Occupational Health & Safety.