EHS Management

Powered Down? Special Requirements for Electrical Lockout/Tagout

When workers will be de-energizing electrical equipment so that they can safely work on or near it, they must use lockout/tagout procedures to protect themselves from unexpected energization or startup of the equipment. But not all of OSHA’s applicable requirements are in one place.

Most lockout/tagout requirements are found in 29 CFR 1910.147, however, a few additional requirements are found in OSHA’s standard for Electrical Safety-Related Work Practices, 29 CFR 1910.333.

Electrical Lockout/Tagout

Exposed electrical parts and conductors must be de-energized before employees work on or near them. It’s not enough just to de-energize them, though; if they have not been locked or tagged out, they must be treated as if they are energized.

In order to be in compliance with all applicable lockout/tagout requirements, electrical lockout/tagout must be conducted according to both the requirements of the lockout/tagout standard (29 CFR 1910.147) and the requirements of 1910.333(b)(2)(iii)(D) and (b)(2)(iv)(B).

Those requirements address:

The use of tags without locks. In situations where a lock either cannot be used, or where a tag can provide as much security for workers as the use of a lock, employees can use a tag without a lock. This is also allowed under the lockout/tagout standard, however, the electrical standard additionally requires that employers supplement that use of a tag with at least one additional safety measure in order to ensure that the level of safety provided is equivalent to that provided by a lock. Examples of additional safety measures include:

  • The removal of an isolating circuit element
  • Blocking of a controlling switch
  • Opening of an extra disconnecting device

Verification of de-energization. Before a circuit or equipment can be considered and treated as if it is de-energized, its status must be verified. The lockout/tagout standard also requires this, but the electrical standard specifies that verification must be performed by having a qualified person:

  • Try to turn on the equipment and operate it, or otherwise determine that the equipment cannot be restarted.
  • Use test equipment to test the circuit elements and electrical parts of equipment to which employees will be exposed, to verify that the circuit elements and equipment parts are de-energized. The test must determine if any inadvertently induced voltage or unrelated voltage backfeed exists in the system. If the circuit being tested is over 600 volts, the test equipment must be checked to make sure that it is operating properly immediately after use.

Written procedures

The lockout/tagout standard requires employers to document their lockout/tagout procedures. The electrical standard also requires employers to have a written copy of their lockout/tagout procedures. But here’s a piece of good news for employers: according to 1910.333, a copy of 1910.333(b) is sufficient and can be used as a “written copy” of the lockout/tagout procedure.

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