In today’s Advisor we feature questions about OSHA’s lockout/tagout requirements recently received and answered by the safety experts at Safety.BLR.com.
Q. Do I have to train the authorized employees and affected employees separately, or can I train one class comprised of both audiences?
A. There are separate training requirements for authorized and affected employees under OSHA’s lockout/tagout standard. You may train them together as long as you cover both areas.
The standard says:
1910.147(c)(7)(i)(A) Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.
1910.147(c)(7)(i)(B) Each affected employee shall be instructed in the purpose and use of the energy control procedure.
1910.147(c)(7)(i)(C) All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.
Q. How often do we have to inspect each piece of equipment for lockout/tagout?
A. OSHA requires an annual inspection of energy control procedures on each machine:
1910.147(c)(6)(i) The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.
1910.147(c)(6)(i)(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.
1910.147(c)(6)(i)(B) The periodic inspection shall be conducted to correct any deviations or inadequacies identified.
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1910.147(c)(6)(i)(C) Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected.
1910.147(c)(6)(i)(D) Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.
1910.147(c)(6)(ii) The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.
Q. How often do we have to train our employees in lockout/tagout?
A. Although the standard does not prescribe annual refresher training or a set frequency for retraining, it does require training under specific circumstances and specifies those issues that the training must cover. For example, the employer must provide initial training before the servicing and maintenance activities begin and must provide retraining as necessary. However, retraining is required, by paragraph (c)(7)(iii), if a periodic inspection reveals, or an employer has reason to believe, that there are deviations from the application of the energy control procedure or inadequacies in an employee’s knowledge of or use the energy control procedure.
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Additionally, retraining must be provided for all authorized and affected employees whenever there is a change in:
- Job assignments;
- Energy control procedures; or
- Machinery, equipment, or processes that present a new hazard.
The retraining must reestablish employee proficiency and, if relevant, address new or revised energy control procedures. The scope and content of all the retraining must be based upon the severity of the problems encountered and must be directed toward the elimination of those problems. Unless employees are retrained whenever deviations or inadequacies are discovered (or when the employer has reason to believe a problem exists), the overall effectiveness of the energy control program will diminish over time. Properly trained employees, who are proficient in their energy control responsibilities, are critical to the success of the energy control program.
Q. If my factory does not operate 24/7 and we are in the middle of a LOTO maintenance procedure that another crew will complete the next day, how do you pass off the keys/locks/tags/etc. so the new crew is protected?
According to the OSHA lockout/tagout rule section on shift changes (29 CFR 1910.147[f][4]), it’s up to you to develop procedures for shift changes to ensure continuity of protection for all employees. OSHA does not provide specific procedures for the changeover.
There should be a physical hand-off of keys/master key and documentation that such transfer took place. OSHA requires you to create procedures for accountability where an authorized person places the locks and then a different person removes them.
Check in tomorrow for more questions and answers about lockout/tagout.