Enforcement and Inspection

Is Your LOTO Program Designed to Prevent Accidents and Penalties?

Lockout/tagout accidents are common, and citations are featured on OSHA’s Top 10 Violation list nearly every year. Is your LOTO program designed to prevent accidents and citations?

OSHA has cited a Cleveland company for 27 violations, including a willful for failing to report two amputations. The workers were injured while operating mechanical power presses before a January OSHA inspection. The company now faces fines of $426,100.

Regional Administrator Michael Connors said lack of proper machine guarding and procedures to control hazardous energy to prevent amputations "demonstrates a blatant disregard for the safety of workers."

The company had been inspected 6 years before and been cited for nine violations at that time, including lockout/tagout and machine guarding.

With cases like this and the accidents described in yesterday’s Advisor, it’s not hard to see why LOTO violations usually feature in OSHA’s Top 10 Violations list every year.

Clearly, this is a topic to which employers and safety managers need to pay careful attention. It’s also a topic where detailed understanding of the requirements is essential.


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LOTO Program Requirements

The lockout/tagout rule applies to the control of hazardous energy during servicing or maintenance of machines and equipment, including any source of mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.

According to OSHA’s lockout/tagout standard (29 CFR 1910.147), you must have a written program that clearly outlines the scope, purpose, authorization, rules, techniques, and employee training to be used for the control of hazardous energy, and the means to enforce compliance.

Your LOTO program must include documentation of all of the following elements:

  • A specific statement of the intended use of the procedure
  • The specific types of energy to be controlled and, in instances where a common procedure is to be used, the specific equipment covered by the common procedure by type and location (the identification of the energy to be controlled may be by magnitude and type of energy)
  • 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
  • Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures
  • Certification of periodic inspections
  • Certification of training

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LOTO and Lots More

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