Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to comply with OSHA’s lockout/tagout standard.
Lockout/tagout, the Occupational Safety and Health Administration’s (OSHA) standard that’s more formally known as “control of hazardous energy,” addresses the hazards posed by equipment and machinery during cleaning, maintenance, repair, or service.
The machine guarding standard protects workers from the hazards that machines pose while operating. The federal lockout/tagout and machine guarding standards both aim to protect workers from mechanical hazards.
OSHA’s lockout/tagout and machine guarding standards regularly show up on the agency’s list of its top 10 most frequently cited standards. In fiscal year (FY) 2023, OSHA cited 2,554 violations of 29 Code of Federal Regulations (CFR) §1910.147, making lockout/tagout the agency’s sixth most cited standard. The machine guarding standard (§1910.212) is OSHA’s tenth most cited standard, cited 1,644 times in FY 2023.
Is your facility fully compliant with the lockout/tagout and machine guarding standards?
Massive settlements
OSHA’s enforcement is robust, and even settlements with the agency can be costly.
Food processor Zwanenberg Food Group USA Inc. recently settled lockout/tagout and machine guarding violations, agreeing to pay $1.7 million in federal OSHA penalties and invest $1.9 million in making safety improvements at its Cincinnati plant. Zwanenberg’s products include cooked ham, chili, luncheon meat, soups, stew, corned beef hash, and pasta marketed under the Halal, Southgate, Vietti, and other private-label brands.
OSHA cited Zwanenberg in September 2022, April 2023, and December 2023 after investigating the cause of injuries suffered by two temporary workers at the plant. The agency cited Zwanenberg in December with repeat, serious violations of the lockout/tagout and machine guarding standards, marking the fourth time since 2017 that OSHA inspectors found the company violated lockout/tagout safety standards.
In 2017, OSHA placed Zwanenberg in its Severe Violator Enforcement Program (SVEP).
Safety improvements that were agreed to as part of the settlement included the following:
- An analysis of all equipment by an independent third-party auditor;
- Developing and rewriting lockout/tagout procedures for all equipment;
- Enhancing machine guarding;
- Training employees on the new machine safety procedures, including lockout/tagout;
- Ensuring that each employee uses and applies their own HASP lock during third-shift sanitation;
- Transitioning most of the workforce from temporary to permanent employment within six months;
- Meeting with OSHA at least quarterly to discuss safety and health issues;
- Retaining a third-party consultant to audit all personal protective equipment (PPE), hazard communication, and lockout/tagout programs;
- Continuing the company’s recently adopted “Pre-Startup Safety Review” procedure;
- Conducting an independent audit of the company’s safety training programs;
- Continuing the company’s “Near-Miss Reporting Program,” with daily discussions of issues at production meetings;
- Implementing a learning management system for all employees and scheduling mandatory monthly computer-based safety training; and
- Developing a corporatewide safety and health management system that includes input from management and workers and the creation of a safety committee.
Earlier this year, a Camden, New Jersey, auto recycler and auto parts supplier agreed to pay $868,628 in OSHA penalties for violations that included inadequate lockout/tagout procedures, exposing workers to machine operation hazards, and failing to control flammable liquids. The agency identified inadequate protections from fall, electrical, and noise hazards.
In addition to paying the safety and health penalties, the employer agreed to implement a comprehensive safety and health program to protect its employees. Program elements will include safety audits by a third-party consultant, safety training programs based on audit findings, and opportunities for workers to participate in safety efforts without fear of retaliation, including a safety management committee that will review audit findings and evaluate the progress of the company’s safety programs.
OSHA inspections, penalties
As with Zwanenberg, OSHA penalties can be steep. Following a worker’s death at a Phenix City, Alabama, sawmill, the agency cited the employer with 22 willful violations, one repeat violation, and five serious violations, proposing fines that totaled $2,471,683.
A 67-year-old sawmill supervisor had climbed on top of an auger to access a difficult-to-reach area to unclog a woodchipper. The employee was caught in the machinery and was fatally injured after the machine started while the employee was on top of the auger.
Agency investigators found the employer failed to:
- Ensure employees used energy control (lockout/tagout) procedures to prevent the unexpected start-up of machines while performing maintenance and servicing activities, such as clearing jams.
- Ensure the use of lockout/tagout devices on machinery when performing maintenance.
- Provide employees with training on the purpose and function of an energy control (lockout/tagout) program, and ensure they have the knowledge and skills required for the safe application of energy control measures.
- Maintain guarding of machines that pose amputation hazards to employees.
- Ensure an electrical disconnect was in the line of sight of the equipment being locked out.
OSHA added the sawmill employer to the agency’s SVEP in 2020.
Late last year, the agency cited a Florence, Wisconsin, sawmill following a 16-year-old worker’s fatal injuries, proposing $1.4 million in penalties. Citations included eight willful, six repeat, 29 serious, and four other-than-serious safety and health violations, including violations of the lockout/tagout and machine guarding standards.
OSHA also determined that the sawmill’s management allowed several underage workers to perform maintenance on equipment without training or following required safety procedures.
A 16-year-old worker became trapped in a stick stacker machine as he tried to unjam it. The worker remained trapped until he was found and freed and then transported to the hospital, where he passed away two days later.
OSHA investigators found that minors were exposed to dangerous hazards—federal regulations that bar young workers from operating dangerous machinery. OSHA’s investigation immediately led to a separate investigation by the Department of Labor’s (DOL) Wage and Hour Division, which enforces child labor laws.
Since 2019, at least five company employees have suffered serious injuries due to lockout failures, including a fatality at another facility when a worker suffered fatal injuries while servicing a trailer.
OSHA has cited manufacturers across the country with lockout/tagout and machine guarding violations over the past year, often with six-figure penalties, including:
- An El Paso, Texas, machine shop and precision parts manufacturer was fined $596,221 and cited with 58 workplace safety and health violations, including two willful safety violations and one willful health violation. Safety and health violations included not installing lockout/tagout systems to prevent machines from sudden start-ups or movement, failing to train employees on energy control (lockout/tagout) procedures, and failing to enclose vertical or inclined belts and gears with required guards.
- A Sandusky, Ohio, pork processing facility was fined $528,441 and cited with 43 safety violations. The company was cited with a repeat violation for exposing employees to amputation and other serious hazards due to inadequate point-of-operation guarding of a meat saw. The agency also cited the employer for its lack of both lockout/tagout procedures and lockout devices.
- A Vineland, New Jersey, food manufacturer was cited for one willful, two repeat, and four serious violations and fined $463,224. Violations included failures to develop and follow a lockout/tagout program, train workers on lockout/tagout procedures, and conduct annual lockout/tagout audits.
- An Ohio industrial hose manufacturer was cited following the agency’s eighth investigation since 2013. The investigation resulted in one willful, 11 serious, and two other-than-serious violations and fines totaling $321,489. Cited violations included the lack of adequate machine guarding and training in lockout/tagout procedures to prevent sudden machine start-ups or movement.
This spring, OSHA opened an investigation into an employee’s disabling injuries at a Sun Prairie, Wisconsin, commercial bakery. The agency cited Pan-O-Gold Baking Company with two repeat, six serious, and two other-than-serious violations. (The employer failed to record injuries in its OSHA 300 log or report an employee’s work-related hospitalization.)
An earlier OSHA investigation into how workers suffered amputation and laceration injuries at the same facility determined that the company exposed employees to hazards by failing to use and follow lockout/tagout procedures. The company’s average days away, restricted, or transferred (DART) rate for 2020 to 2022 was more than 160% higher than the Bureau of Labor Statistics’ (BLS) 2021 nationwide average for commercial bakeries.
Even well-known manufacturers have found themselves facing OSHA fines for mechanical hazards in their facilities, including:
- 3M found itself facing $312,518 in OSHA penalties after an employee at its Prairie du Chien, Wisconsin, facility became caught in a machine’s rotating rollers, suffering a fatal injury. The agency cited 3M with willful, serious violations of the lockout/tagout and machine guarding standards.
- OSHA cited snack food maker Hostess Brands after a 29-year-old worker suffered the amputation of a fingertip while reassembling a pump at a Hostess facility in Chicago. The agency cited Hostess with repeat and willful violations of the lockout/tagout standard and serious violations of the machine guarding standard. OSHA proposed fines totaling $298,010.
Your lockout/tagout, machine guarding compliance
“Control of hazardous energy,” or lockout/tagout, is aimed at protecting workers from many hazards posed by equipment or machines—amputation, burns, and electrocution, as well as crushed, cut, fractured, or lacerated body parts. To prevent unauthorized start-ups, you need policies and procedures for locking and tagging machines or equipment before cleaning, maintenance, repair, or service.
Your employees authorized to lock out machines or equipment for cleaning, maintenance, repair, or service must be trained to recognize all sources of hazardous energy in your facility. They must know the type and magnitude of energy found in your facility and the means and methods of isolating and/or controlling energy as part of your company’s lockout/tagout procedures.
You must also ensure your employees only use the lockout/tagout devices authorized for specific equipment or machinery in your facility. Lockout/tagout devices must be durable, standardized, and substantial. Devices must identify the individual who locked out or tagged out a machine or piece of equipment.
The hazardous parts of operating machinery include ingoing nip points, rotating parts, flying chips, and sparks. Types of machine guarding include barrier guards, light curtains, and two-hand operating devices. Machine guards must be attached to the machine where possible but may be attached elsewhere when guards can’t be connected directly to a machine.
For example, revolving barrels, containers, and drums may be guarded by an enclosure that interlocks with the drive mechanism, ensuring machinery can’t operate unless the guard enclosure is in place.
Equipment and machines can cause serious or even fatal injuries to your employees during normal operations or during cleaning, maintenance, repair, or service. Revisit your lockout/tagout and machine guarding compliance to protect them from injury and yourself from substantial OSHA fines.