OSHA's standard for the control of hazardous energy, also known as lockout-tagout or LOTO, is 1910.147. As the regulation explains in 1910.147(a)(1)(i), "This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy."
In 1910.147(c)(1), the regulation explains that "the employer shall establish a [energy control] 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."
So the energy control program required by OSHA's Control of Hazardous Energy/Lockout-Tagout regulation requires the employer's program to have three parts: (1) energy control procedures; (2) employee training; and (3) periodic inspections.
We'll look at each of those three required parts of an energy control program more closely in this article.
As we do, we'll draw some materials from two of our online safety training courses related to lockout-tagout:
We've already covered the fact that in 1910.147 OSHA requires employers establish a hazardous energy control program and that the program must include energy control procedures, employee training, and periodic inspections. And that's what this article will focus on.
But before we begin, it's a good idea to step back and remind ourselves the purpose of controlling hazardous energy. Here's how OSHA puts it in 1910.147:
...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.
The first requirement is to have a set of energy control procedures for employees to follow.
As OSHA explains in 1910.147, employers must develop and document these procedures. In addition, employees must utilize these procedures to control the release of hazardous energy at any time when they're engaged in the type of work activity described in the 1910.147 standard.
The energy control procedures must "clearly and specifically" outline the:
Techniques to be utilized for the control of hazardous energy.
In addition, the employer's energy control procedures must explain the means by which the employer will enforce compliance, which may include the following and other compliance methods:
OSHA and 1910.147 provides an exception in which the employer does not need to document the required procedure for a specific machine or equipment if all of the following exist:
The second part that OSHA requires for an energy control program is employee training, including training, retraining, and associated communication about the hazardous energy control program.
As explained in 1910.147(c), the employer must provide training so that employees understand both the purpose and the function of the energy control program. In addition, training must help employees develop the knowledge and skills necessary to safely apply, use and remove energy controls.
OSHA breaks down the energy control training that workers must receive based on their role in the energy control process as explained below.
All authorized employees must be trained to recognize sources of hazardous energy, to know the type and type and magnitude of the energy in the workplace, and to know the methods and means necessary for energy isolation and control. (Note: OSHA defines an authorized employee as "An employee who locks or tags machines or equipment in order to perform servicing or maintenance.")
Here's a short sample of our online safety training lockout-tagout for authorized employees course (below).
All affected employees must be trained in the purpose and use of the energy control procedure. (Note: OSHA defines an affected employee as "An employee who is required to use machines or equipment on which servicing is performed under the Lockout/Tagout standard or who performs other job responsibilities in an area where such servicing is performed.")
Here's a short sample of our online safety training lockout-tagout for affected employees course (below).
All other employees whose work operations are or may be in an area where energy control procedures may be utilized, must be trained about the hazardous energy control procedure, and about the rule against attempting to restart or reenergize machines or equipment that are locked out or tagged out.
When tagout systems are used, employees must also be trained about the limits of tags, including:
In addition, in 1910.147 OSHA spells out the following requirements for retraining of employees in regards to hazardous energy control programs:
The purpose of the retraining is to re-establish the employee's proficiency in the energy control program/procedures and/or to introduce new or revised control methods and procedures.
As explained in 1910.147(c)(7)(iv), the employer must certify that employee hazardous energy control training(a) has been completed and (b) is being kept up to date. The certification must include each employee's name and the date(s) of training.
The third and final requirement of an energy control program at work is an ongoing series of periodic inspections of the energy control procedures in operation.
Employers must periodically inspect the energy control program and energy control procedures to ensure that the requirements of 1910.147 are being followed.
OSHA spells out the specific requirements for periodic energy control procedure inspections in 1910.147(c)(6). They include:
The employer must certify that these periodic inspections of the energy control program and its procedures have been performed. The certification must identify the equipment/machine for which the energy control procedure is used, the date of the inspection, the name of the employees included in the inspection, and the name of the person performing the energy control procedure inspection.
You may also find the following resources helpful:
We hope you found this article about energy control programs and OSHA's requirements for them helpful. Let us know if there's anything more we can assist with.
Otherwise, have a great day and we'll see you soon, we hope!