The Seven Deadly Lockout/Tagout Sins

These seven most commonly issued citations for lockout/tagout can be problem areas for companies.

Lockout/tagout is the no. 1 citation in general industry, and knowing whether a company’s current policies ensure compliance could be a difficult task.
Colin Warren, partner at Fisher Phillips, presented his “seven deadly sins of  lockout/tagout” to attendees at the Safety Leadership Conference 2017 in Atlanta in the session titled, “Lockout/Tagout: Avoiding the Legal Pitfalls.”

An employer must know if the standard applies to machinery, update maintenance and LO/TO policies as needed and have a solid training program in order to remain compliant and keep employees safe. When these things are not addressed under OSHA’s standards, the agency will hand out violations during inspection.

View the slideshow to learn more about machine-specific standards and how many companies are failing when it comes to complying with lockout/tagout.

1. Lack of Machine-Specific Procedures

An employer should not have the same lockout/tagout policy for all machines. All panels must be identified, and policies must specific to say which electrical breakers close. Any written instructions and training must be updated with any changes in machine setup, Warren said.

2. Lack of Training and Communication of Policies

In order to comply with 29 CFR 1910.147 (c7), all workers must be able to prove to OSHA that they recognize all potential energy sources. Workers also must know the types and magnitudes of those sources.

3. Citations for De¹cient Program Audits

Many companies who are not in compliance have the wrong person conducting lockout/tagout audits or don’t even follow the standard. Audits must be conducted annually and must be completed by an “authorized employee” other than the workers utilizing the lockout/tagout procedure being inspected, Warren said.

4. Improperly Using Tags

Another common violation involves incorrect tag usage. This covers tags where locks should be used, using tags improperly and using the wrong tag for the equipment.

5. Lack of Employee Retraining

During inspection, employers must be able to prove their workers are proficient in lockout/tagout procedures. Companies also should that workers are being retrained and familiarized regarding the policies, especially with a change in equipment or processes, Warren said. 

6. Not Identifying All Potential Energized Energy Sources

Many lockout/tagout incidents are caused by the release of stored energy (mechanical, air, steam or other). Employers should address unexpected mechanical energy from things such as spring-loaded hinges, Warren said.

7. Not Knowing If Lockout/Tagout Applies

Employers should be well-versed on whether lockout/tagout applies and also should know the difference between between service and maintenance of machines and tool changes, minor adjustments and normal operations.


EHS Today – Translated by Achison

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