CAUTION! Watch Out for Most Commonly Cited Lockout/Tagout Violations

The lockout/tagout regulations are perennially ranked among OSHA’s top 10 violations. Last year, for example, there were more than 3,000 violations of the standard, with penalties mounting to nearly $4 million.

These are the sections of the lockout/tagout standard that were most often cited last year:

§1910.147(c)(4)(i) Lockout/tagout procedures
703 violations
Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

§1910.147(c)(6)(i) Inspection of energy control procedure
521 violations
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)(1) Energy control program
516 violations
The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

§1910.147(c)(7)(i) Employee training
379 violations
The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees.

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§1910.147(d)(4)(i) Role of authorized employees
174 violations
Lockout or tagout devices shall be affixed to each energy-isolating device by authorized employees

§1910.147(c)(4)(ii) Details of procedures and enforcement
161 violations
The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance.

§1910.147(c)(6)(ii) Certification of periodic inspections
124 violations
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.

§1910.147(c)(7)(i)(A) Training requirements for authorized employees
105 violations
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.

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Where Do You Stand?

What shape is your energy control program in? Does it include the following elements?

• A list identifying all energy sources that required lockout/tagout
• Procedures to ensure that energy is fully drained before powered equipment is serviced or maintained
• Procedures to prevent machines from being turned on or restarted accidentally
• Assignment of lockout responsibilities to specific, authorized employees
• A plan to test procedures annually and correct any problems

Are your employees divided into three different categories and does each group receive appropriate training?

• “Authorized” (qualified) employees must receive thorough training and are the only ones permitted to perform lockout procedures or remove locks or tags.
• “Affected” employees are those who work with and around this equipment. They must be trained to know the purpose and use of the energy control procedure and to call authorized employees for any maintenance or repair.
• “All other” employees are those who may be in the area. They must be trained to understand the purpose of lockout/tagout and that they must never remove or ignore lockout/tagout devices.

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