Industrial Manufacturing lockout/tagout (LOTO) procedures are a cornerstone of preventing injuries and fatalities from unexpected energy release during maintenance or servicing. However, even the most well-intentioned LOTO programs can become dated over time, so it’s important to make sure you’re regularly checking them.

The Occupational Safety and Health Administration (OSHA) specific standard for lockout/tagout is CFR 1910.147. This “covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.”

Here are five key questions to ask yourself to make sure your LOTO program is robust and effectively protecting your workforce:

1. What Safety Procedures Are Currently in Place? Do They Include Visual Aids?

A successful LOTO program starts with clear and comprehensive procedures. They should be readily available, written in a clear and concise manner, and be specific to the machinery in your facility. Visuals are a powerful way to show how to safely and successfully perform LOTO. Include visuals of your machines with corresponding lockout points to clearly identify and enhance understanding and adherence.

2. Who is in Charge?

Make sure you assign a clear leader of your LOTO program. This person is typically a safety manager or supervisor and is responsible for ensuring procedures are up-to-date, training is conducted regularly, and proper lockout devices are readily available.

3. Is Your Workforce Trained?

You can have the best LOTO program in the world, but if your workforce isn’t properly trained on the implementation, it can still be disastrous. Recurring training and refreshers will go a long way to ensure continued understanding and competency. Consider incorporating scenario-based training to simulate real-world situations often encountered during maintenance or servicing.

Additionally, training is a requirement of OSHA’s lockout/tagout standard, which includes, but isn’t limited to:

147(c)(7)(i)(B) - Each affected employee shall be instructed in the purpose and use of the energy control procedure.
147(c)(7)(i)(C) - All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.

Note: “Affected employees” are the ones specifically performing lockout/tagout, but all employees who interact with the machine must also be trained appropriately.

4. What is Your Existing Safety Policy?

LOTO is only one piece of the safety puzzle. It should be seamlessly integrated with your overall safety policy, reinforcing a culture of safety awareness throughout your organization. Routinely examine your safety policy to ensure it clearly outlines LOTO procedures, consequences for non-compliance, and the importance of reporting any deficiencies in the program.

5. What Would You Change About Your Current Program?

Asking questions is also an important part of a robust LOTO program. Regularly evaluate your existing procedures, training methods, and overall program effectiveness. Gather feedback from your teams and stay up to date on industry best practices to find areas for improvement. In the unfortunate event someone is hurt from a LOTO incident, carefully review what happened and build new processes into your LOTO program to help prevent it from happening again.

Don’t be afraid to seek guidance from external safety experts or leverage resources provided from regulatory bodies like OHSA.

By proactively addressing these questions, you can take a significant step toward strengthening your industrial manufacturing LOTO program. Remember, preventing accidents not only protects your workforce; it also develops a more productive and efficient work environment. Investing in safety is an investment in the future of your company.

Consider a Professional Safety Assessment

There’s a lot of value in bringing in an objective perspective to your LOTO program. Consider engaging a professional safety consultant to conduct a comprehensive assessment.

Benefits of a Professional Assessment:

Safety consultants have extensive expertise and experience evaluating LOTO programs. They can identify possible blind spots or areas of improvement that your internal teams might have missed.
A thorough assessment makes sure your program aligns with current OSHA regulations and industry best practices.
Safety consultants can go beyond helping develop your LOTO program and evaluate its overall effectiveness. They can identify areas where clarity or engagement might be lacking and where more training is needed.
After your assessment is completed, you’ll receive a detailed report outlining specific recommendations for improvement, including any updates to procedures, training methods, or resource allocation.

Rexel’s team of safety experts have the knowledge to make your LOTO program the best it can be. Contact us today to learn more or get started.

5 Critical Lockout/Tagout Questions for Industrial Manufacturers