Why Lockout Is Consistently a Top 10 OSHA Violation

Proper lockout/tagout (LOTO) practices and procedures safeguard workers from hazardous energy releases. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry outlines measures for controlling different types of hazardous energy. The standard establishes the employer’s responsibility to protect workers from hazardous energy, but sadly it is one of the most violated standards. Bill Belongea, Safety Services Program Manager at The Master Lock Company shared his insights into why this is the case.

Q: Why is lockout/tagout consistently among the top 10 OSHA violations?

Belongea: Experts estimate 30% of companies have no lockout/tagout (LOTO) strategy in place, and as many as 90% of companies use inadequate or ineffective measures. Those statistics are especially problematic, knowing that lockout/tagout was ranked #6 in most frequently cited standard violations, with nearly 1,700 violations reported in 2021 alone.

There are a variety of reasons that LOTO is consistently ranked as one of the top-cited OSHA violations, but most often, it’s due to the lack of awareness and complexities of the 1910.147 OSHA standard and the belief from businesses that safety procedures and equipment are costly and may reduce productivity.

What’s important for businesses to understand is that when LOTO procedures are written and applied correctly, it can improve efficiency and mitigate the risk and cost of employee injuries.

Q: What challenges do businesses face in complying with the 1910.47 standard?

Belongea: Each business is different in the application of lockout. Operators, maintenance, task-based and group are just a few different types of lockout. Understanding what lockout activities occur in your facility will help overcome the roadblocks that prevent buy-in from leadership and turn it into support for lockout. The most common roadblocks that we have encountered include:

  • Lack of Knowledge/Experience: The early stages of lockout program development and implementation can be challenging as it is, but especially if the company and/or its employees aren’t experienced or are simply unfamiliar with OSHA’s LOTO standard (1910.147). Traditionally, fewer people participate in LOTO procedures in non-industrial settings like hospitals or office buildings, meaning there may be fewer qualified experts, on-site resources for training and a lack of equipment-specific procedures for the staff to follow. Education and training are key components to the process of implementation of a functioning lockout program to ensure that all parties understand both the safety and legal requirements for 1910.147 compliance.
  • Understanding of Hazardous Energy: While some hazardous energies are apparent, such as electrical and pneumatic, not all can be seen, such as gravity and thermal energy. It takes an understanding of the types of hazardous energies that can exist on a piece of equipment and how to translate an equipment-specific procedure to fully comply with the 1910.47 standard. Having a third-party evaluate the type of equipment is important to ensure all hazardous energies are well-documented and appropriate LOTO procedures are in place.
  • Perceived Efficiency Barriers: Some companies may view LOTO as an activity that negatively affects their employees’ productivity. However, we’ve found that most productivity concerns can be overcome by 1) implementing comprehensive and visual lockout procedures at the point of application, 2) training management on their roles and responsibilities to the lockout standard, as well as both authorized and affected personnel effectively and, 3) having the right lockout equipment so you can execute efficient deployment strategies that maximize access to lockout equipment by authorized personnel.

For businesses that need assistance in 1910.47 compliance and developing LOTO programs, third-parties like Master Lock’s Professional Safety Services offer end-to-end solutions to ensure: OSHA compliance; proven LOTO procedures; and, employee training is adequately implemented, providing both businesses and employees peace of mind.

Q: Why is lockout important for employee safety?

Belongea: It’s critical to understand that LOTO is not just a best practice to prevent worker injury—it’s the law. Failure to meet current standards could result in catastrophic incidents, injuries, and in extreme cases, fatality. Operating complex and often powerful machinery is extremely dangerous, and it’s the duty of safety managers and other business leaders to ensure employees aren’t being put in harm’s way.

In addition, a commitment to safe work practices such as step-by-step zero energy isolation lockout procedures will eliminate the potential of production downtime reacting to serious incidents because of not locking a piece of equipment out prior to servicing and maintenance. Incorporating lockout in preventative and predictive maintenance activities is a great way to incorporate a culture of safety throughout your organization.

Q: When referring to lockout, what are the types of hazards that workers can be exposed to?

Belongea: The term “hazardous energy” encompasses all energy sources, including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources like gravity, in machines and equipment that can be hazardous to workers.

To ensure compliance under 1910.147, all types of hazardous energy sources must be properly isolated to a zero-energy state through a series of shutdown steps documented by a LOTO procedure. This is essential for employees to control potential dangers and prevent mechanical motion through power generation, or residual pressures during service and maintenance activities.

Q: What industries or types of businesses do you see consistently having the most lockout incidents?

Belongea: While the 1910.147 standard applies to many types of work environments, formal lockout practices of paramount importance in any facility where maintenance activities, complex machinery and potential environmental or mechanical hazards abound.

Lockout compliance and procedures are needed in a variety of industrial settings – including manufacturing, food processing, oil & gas, utility, and healthcare facilities, to name a few.

Q: What is the relationship between mechanical and electrical lockout?

Belongea: While the lockout of energy-isolating devices is local to equipment when servicing and maintaining equipment, 1910.147 is a critical resource to understand the responsibilities of the authorized person and organization. When working within electrical devices such as control panels, disconnects, breaker panels and MCC’s, the “qualified” worker needs to understand their responsibilities under the NFPA 70E standard.

In most cases when servicing electrical devices, only one hazardous energy source is present – the electricity. This eliminates the requirement of a lockout procedure for that electrical device. However, strict adherence to the incident energy, PPE requirements and having the skill, knowledge, and training to perform electrical tasks should be part of your electrical safety program. Incorporating lockout requirements for electrical tasks should also be part of your lockout policy.

Understanding the differences between locking out a piece of equipment for mechanical means vs. working on electrical devices puts additional requirements for the worker and the organization.

Q: Do you typically find businesses looking for lockout guidance as a proactive measure or a reactive measure when an incident occurs?

Belongea: While we have worked with some companies who proactively seek to develop their own custom LOTO program, it’s not as common as those who approach us reactively. Many companies will often prioritize other elements of the business and wait until an incident occurs to take their safety procedures and compliance seriously.

At Master Lock, we help customers find the solutions that will allow organizations to understand the importance of lockout. The team consists of safety practitioners, safety managers, and field technicians (that are in many cases ex-Navy Nuclear Electricians) to create the procedures, processes, and trainings within an organization to promote safe lockout and work practices. Because when it comes to safety, there are no second chances.

Bill Belongea, Professional Services Program Manager at The Master Lock Company, has nearly 20 years of experience in the safety industry. Belongea has an expansive knowledge in a best practice safety management approach and utilizes his expertise to help facility and factory managers all over the world including Europe, Australia, China, and Mexico. The Master Lock Company offers a broad range of innovative security, safes and safety solutions for consumer, commercial, and industrial end-users (www.masterlock.com).

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