OSHA Announces Lockout/Tagout and Standards Improvement Project Developments | JD Supra (2022)

OSHA Announces Lockout/Tagout and Standards Improvement Project Developments | JD Supra (1)

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OSHA published a final rule in the Federal Register on May 14, 2019 revising several existing standards. The revisions apply to the recordkeeping, general industry, maritime, and construction standards. OSHA made the revisions as part of the Standards Improvement Project (SIP). As part of the SIP, OSHA seeks to revise standards and remove duplicative or unnecessary requirements in the standards. The latest rulemaking represents Phase IV of the SIP. The revisions therein become effective on July 15, 2019.

Lockout/Tagout Standard

Perhaps the most significant part of the final rule is a change that OSHA did not make. It had proposed making changes to its lockout/tagout (LOTO) standard at 29 C.F.R. § 1910.147. The LOTO standard applies to maintenance and servicing operations “in which the unexpected energization or startup of the machines or equipment, or the release of stored energy could cause injury to employees.” 29 C.F.R. § 1910.147(a)(1)(i) (emphasis in original). In the preamble to the final rule, OSHA stated its belief that the courts and employers had misinterpreted the word “unexpected” to exclude certain operations where employees were subject to injury from startup or the release of stored energy. It proposed removing the word “unexpected” from § 1910.147(a)(1) and several other places where the term appears in the standard.

OSHA’s proposed change was the result of a ruling by the Occupational Safety and Health Review Commission (OSHRC) that the Sixth Circuit Court of Appeals later affirmed. Secretary v. Gen. Motors Corp., Delco Chassis Div. (GMC Delco), 17 BNA O.S.H. Cas. (BNA) 1217 (1995), aff’d, 89 F.3d 313 (6th Cir. 1996). The decisions found that the LOTO standard did not apply when a machine’s startup procedure provided a warning to a worker servicing it that the machine was about to start. OSHRC and the Sixth Circuit held that because the machine’s features would warn servicing employees that the machines were about to start, the startup could not be “unexpected.” OSHA believes that the GMC Delco decision misconstrued the “unexpected” language of the LOTO standard. It has suggested that this misinterpretation has allowed employers to use warning and delay systems as alternatives to following the requirements in the standard. During the comment period, OSHA received some 150 comments against the proposed revision and only seven comments in favor of the revision. Many of the comments in opposition cited complications with the issue because of technological advancements. Based on the comments received, OSHA decided not to finalize the proposed revision, but to further consider the issue.

Lockout/Tagout Request for Information

On May 20, 2019, OSHA issued a Request for Information from employers on a possible update to the LOTO standard. It seeks information regarding two areas where it believes modernizing the standard might better promote worker safety without additional burdens to employers: control circuit type devices and robotics.

Currently, the LOTO standard requires all sources of energy, including energy stored in the machine itself, to be controlled during the maintenance and servicing of machines and equipment that use an energy-isolating device (EID). Excluded from OSHA’s definition of EID are control circuit type devices. Thus, they are not a compliant method for controlling hazardous energy during service and maintenance activities. Technological advances since 1989, when OSHA issued the standard, suggest that in some circumstances, control circuit type devices may be at least as safe as EIDs.

OSHAis requesting information, data, and comments on how employers have used control circuit devices. Additionally, OSHA may consider changes to the LOTO standard that address hazard energy control for new robotics technologies. It is requesting information on the hazards and benefits of robotics and robotic components in the workplace with regard to the control of hazardous energy, safeguards employers can use, increased efficiencies that result, and any additional information related to ensuring employee safety when interacting with robots. Comments are due by August 19, 2019.

Standards Improvement Project Final Rule

The majority of the revisions to health and safety standards that OSHA did make are to the General Industry, Shipyard, and Construction Standards (29 C.F.R. Parts 1910, 1915 and 1926). A brief summary of the revisions follows:

  1. Recording Criteria for Cases Involving Occupational Hearing Loss (29 C.F.R. § 1904.10). OSHA revised 29 C.F.R. § 1904.10(b)(6) to include a cross-reference to 29 C.F.R. § 1904.5, which requires considering an injury or illness (i.e., hearing loss) to be work-related if an event or exposure in the employee’s work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.
  2. Standards Concerning Occupational Exposures to Asbestos (29 C.F.R. § § 1910.1001, 1915.1001 and 1926.1101), Inorganic Arsenic (29 C.F.R. § 1910.1018), Cadmium (29 C.F.R. §§ 1910.27 and 1926.1127), Coke Oven Emissions (29 C.F.R. § 1910.29), and Acrylonitrile (29 C.F.R. § 1910.1045).


    OSHA made three revisions to these standards. In OSHA’s first revision, it deleted the requirement for periodic chest x-rays from three of these standards: 29 C.F.R. § 1910.1018, Inorganic Arsenic; § 1910.1029, Coke Oven Emissions; and § 1910.1045, Acrylonitrile.

    OSHA also revised the standards to allow, but not require, the use of digital chest x-rays in the medical surveillance provisions of 29 C.F.R. §§ 1910.1018, 1910.1029, 1910.1045, 1910.1001, 1915.1001, 1926.1101, 1910.1027, and 1926.1127.

    In the third revision, OSHA replaced “roentgenogram” with “x-ray,” which reflects current terminology. It also removed references to semi-annual exams for certain employees in the coke oven emissions appendices (29 C.F.R. § 1910.1029, Apps. A (VI) and B(II)(A)).

  3. General Industry Cotton Dust Standard (29 C.F.R. § 1910.1043). To align with current practices and technology, OSHA updated the standard’s lung-function testing requirements.
  4. Shipyard General Working Conditions, Definitions in 29 C.F.R. 1915.80. OSHA removed “feral cats” from the definition of “vermin” in 29 C.F.R. § 1915.80(b)(33).
  5. Construction Medical Services and First Aid Standard (29 C.F.R. § 1926.50). To be consistent with the current status of land-line and wireless-telephone technologies, OSHA revised § 1926.50(f) to update the 911 service-posting requirements. It also revised § 1926.50(e) to ensure that employers are providing an effective communication system to contact ambulance service.
  6. Construction Process Safety Management Standard (29 C.F.R. § 1926.64). OSHA replaced the entirety of the regulatory text for the Process Safety Management (PSM) Standard for construction at 29 C.F.R. § 1926.64 with a cross-reference to the identical PSM Standard for general industry found at 29 C.F.R. § 1910.119.
  7. Construction Safety Belts, Lifelines, and Lanyards (29 C.F.R. § 1926.104). OSHA revised the minimum breaking-strength requirement found in 29 C.F.R. § 1926.104(c) from 5,400 to 5,000 pounds.
  8. Construction Signs, Signals and Barricades Standards (29 C.F.R. Part 1926, Subpart G). OSHA revised Subpart G to update the incorporation by reference of Part 6 of the Manual on Uniform Traffic Control Devices for Streets and Highways (“MUTCD”) (2009 Edition), including Revisions 1 and 2 (2012). It also revised 29 C.F.R. § 1926.200(g)(1) to require employers to use traffic control devices at points of hazard. OSHA revised paragraph (g)(2) to clarify that it covers the design and use of traffic-control devices. OSHA added a list of the devices:signs, signals, markings, barricades, and other devices.It deleted 29 C.F.R. § 1926.202 because the section duplicated the requirements contained in the revisions to 29 C.F.R. § 1926.200(g). OSHA also deleted 29 C.F.R. § 1926.203 because the revisions made it unnecessary.
  9. Construction General Requirements for Storage (29 C.F.R. § 1926.250). 29 C.F.R. Part 1926, Subpart H governs the handling, storage, use, and disposal of construction materials on a work site. OSHA proposed excluding residential construction from the posting requirement in 29 C.F.R. § 1926.250(a)(2). In the final rule, OSHA uses the term “all single-family residential structures and wood-framed multi-family residential structures” in place of “detached single-family dwellings or townhouses that are under construction.” In addition, the Agency renamed the subsection “Load Limits.” It also moved the requirement that the weight of storage materials not exceed safe load limits from the end of the section to the beginning.
  10. Underground Construction Standard (29 C.F.R. § 1926.800). Under § 1926.800(k)(10)(ii), OSHA requires that mobile diesel-powered equipment used in “other than gassy operations” underground be approved by the Mine Safety and Health Administration (“MSHA”) in accordance with the provisions of 30 C.F.R. Part 32. Alternatively, an employer can demonstrate that the equipment is “fully-equivalent” to MSHA-approved equipment. In the final rule, OSHA only requires compliance with 30 C.F.R. § 57.5067, which pertains to underground metal and nonmetal mines. In addition, the final rule contains minor technical changes to the proposed language.
  11. Construction Rollover Protective Structures; Overhead Protection (29 C.F.R. Part 1926, Subpart W). Subpart W contains provisions specifying the minimum performance criteria for rollover protective structures and overhead protection on construction equipment. OSHA revised the existing standards in 29 C.F.R. §§ 1926.1000, 1926.1001, 1926.1002, and 1926.1003 to remove the provisions that specified the test procedures and performance requirements. It replaced the provisions with references to the underlying consensus standards from which they were derived. OSHA also added ISO 3471:2008 to § 1926.1002 and made other technical corrections.
  12. Coke Oven Emissions Standard (29 C.F.R. § 1926.1129). Exposure to coke oven emissions in construction is regulated in 29 C.F.R. § 1926.1129. OSHA deleted § 1926.1129 since the provisions of the coke oven standard do not fit construction work.
  13. Additional Revisions to Paragraphs and Appendices in 29 C.F.R. Parts 1910, 1915 and 1926 to Remove Social Security Number Collection Requirements. OSHA deleted the requirement to include an employee’s social security number from 19 standards. In reviewing forms to remove the social security number requirement, it noted that several forms from older standards did not comply with the OMB’s Standards for Maintaining, Collecting, and Presenting Federal Data on Race and Ethnicity. OSHA revised its older forms to use a combined race and ethnicity format to bring the forms into compliance with OMB’s standards. OSHA will revise the following forms to use the combined race and ethnicity format:Asbestos Standard for General Industry (29 C.F.R. § 1910.1001, appendix D), Construction (29 C.F.R. § 1926.1101, appendix D), Maritime (29 C.F.R. § 1915.1001, appendix D); Cotton Dust (29 C.F.R. § 1910.1043, appendix B-1, appendix B-II, and appendix B-III); and Methylene Chloride (29 C.F.R. § 1910.1052, appendix B).

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FAQs

What 3 words must be on a lockout tagout? ›

OSHA requires three basic elements in a lock-out tag-out program.
...
Think, plan and check.
  • If you are in charge, think through the entire procedure.
  • Identify all parts of any systems that need to be shut down.
  • Determine what switches, equipment and people will be involved.
  • Carefully plan how restarting will take place.
11 Jun 2012

What is the standard in lockout tagout? ›

The lockout/tagout standard establishes the employer's responsibility to protect employees from hazardous energy sources on machines and equipment during service and maintenance.

What is the correct practice for lockout tagout? ›

The basic premise of lockout/tagout (LOTO) is simple: ensure equipment, machinery or vehicles are safe to service or perform maintenance on by locking energy-isolating devices on them (or attaching tags if locking is impossible).

When releasing from lockout/tagout an authorized employee must? ›

Workers must be removed from the machine or equipment area. All lockout or tagout devices may then be removed. Authorized workers may then proceed to energize and test or position the equipment or machinery.

What are the 8 steps of LOTO? ›

The eight basic steps to a LOTO procedure are as follows:
  • Prepare for the shutdown. ...
  • Notify affected employees. ...
  • Shut down the equipment. ...
  • Isolate energy sources. ...
  • Apply LOTO devices to energy sources. ...
  • Release/control all stored energy. ...
  • Verify the lockout. ...
  • Maintain the lockout.
1 Dec 2020

What is the correct order for proper lockout procedures? ›

Turn off power, close valves, block moving parts, or disengage and block lines, etc. Lockout/Tagout – The authorized employee will attach locks and tags to all energy isolating devices in such a way that they are in an off or closed position and cannot be moved or switched on to an unsafe position.

What is an OSHA requirement for tagout devices? ›

Tagout devices must be non-reusable and self-locking. Occupational Safety and Health Administration.

Which action requires an employee to use lockout/tagout procedures? ›

Lockout/Tagout is required when the unexpected energization or start up (or release of stored energy ) of machines, equipment or prime movers could injure workers during cleaning, repairing, servicing, setting-up, adjusting and un-jamming.

Which OSHA standard covers lockout/tagout regulations? ›

1910.147 - The control of hazardous energy (lockout/tagout). Occupational Safety and Health Administration.

What is the first step in a lockout procedure? ›

Lockout/Tagout Step 1: Preparation

The first step of locking and tagging out equipment for service and maintenance is to prepare. During the preparation phase, the authorized employee must investigate and gain a complete understanding of all types of hazardous energy that might be controlled.

Who is responsible for lockout tagout? ›

Under the standard's group lockout/tagout requirements, a single authorized employee must assume the overall responsibility for the control of hazardous energy for all members of the group while the servicing or maintenance work is in progress.

What is the first step when initiating a lockout/tagout procedure? ›

8 Steps of a lockout tagout procedure
  1. STEP 1: Notify affected employees. ...
  2. STEP 2: Identify procedure and hazards. ...
  3. STEP 3: Shut down. ...
  4. STEP 4: Isolate machine from energy source. ...
  5. STEP 5: Apply lockout tagout devices. ...
  6. STEP 6: Check stored energy. ...
  7. STEP 7: Verify isolation. ...
  8. STEP 8: Bring equipment back on line.

Can you lock a disconnect in the on position? ›

Question: Can the disconnect switches be locked in the closed (on) position? Response: There is no provision in the OSHA regulations that prohibits locking the disconnecting means in the closed (on) position.

What do you do if employee is not available to remove the lock? ›

Make all reasonable efforts to inform the absent Authorized Person that his/her lockout or tagout device needs to be removed. Make all reasonable efforts to inform the absent Authorized Person's supervisor that his/her employee's lockout or tagout device needs to be removed.

Is it acceptable to remove a lockout tag if you need to complete your work? ›

The Lockout Tagout devices are finally removed from an energy isolating device, only by the worker who applied it. The removal of employees lock without his knowledge can be dangerous, as a general rule, the Lockout Tagout device should be removed by the employee himself/herself.

How many keys should a lockout have? ›

Lockout boards

Locks have one key that is kept with the installer of the lock. Once the work procedure is completed, the lock and key should be returned to the lockout station.

How many types of LOTO are there? ›

The four main types are gate valves, ball valves, plug valves and butterfly valves.

How many steps does it take to end a lockout tagout? ›

After the six steps of lockout tagout have been completed and maintenance has been performed, the power of the equipment must be restored. To do this, one must ensure all tools and debris has been removed from the area. Personnel must remove the lockout tagout device(s) from the energy isolation location(s).

What are the 7 steps of lock out/tag out? ›

LOTO Safety: 7 Steps of lockout tagout
  1. Prepare for shutdown.
  2. Notify all affected employees of the activities and equipment involved.
  3. Shut down the equipment.
  4. Isolate the equipment from the hazardous energy source.
  5. Dissipate residual energy.
  6. Apply applicable lockout or tagout devices.

What is the most important step in LOTO? ›

Step 4: Lockout/Tagout (LOTO)

Once the equipment or machine has been isolated from its energy source, lockout/tagout is the next step. This step is the most important in the entire six-step process. The authorized or approved employee will attach the lockout, Tagout devices to an energy-isolating device.

What is the final step in the lockout procedure before servicing? ›

Render all stored and/or residual energy safe. Once the lockout or tagout devices have been applied, all potentially hazardous stored or residual energy must be relieved, disconnected, restrained, and rendered safe before the servicing or maintenance can be conducted.

How often does OSHA require lockout/tagout training? ›

Under paragraph 1910.147(c)(6)(i) an employer is required to conduct "a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of the standard are being followed." Under paragraph 1910.147(c)(6)(i)(C), the periodic inspection "shall include a review, ...

What are the exceptions to the lockout/tagout requirements? ›

Some acceptable alternative measures include specially designed tools, remote devices, interlocked barrier guards, local disconnects, or control switches which are under the exclusive control of the employee performing the minor servicing.

What are all the requirements for tagout devices? ›

What are the requirements for the lockout and tagout devices? Must be durable, so that they are capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected [29 CFR 1910.147(c)(5)(ii)(A)(1)]. Must be singularly identified [29 CFR 1910.147(c)(5)(ii)].

What is the primary authorized employee responsible for during a group lockout? ›

Group Lockout/Tagout Procedure:

A primary authorized employee shall be designated to exercise primary responsibility for implementation and coordination of the lockout/tagout of hazardous energy sources and for the equipment to be serviced.

Who must perform LOTO procedure inspections? ›

The periodic inspection must be performed by an authorized employee other than the one(s) who is using the energy control procedures. This individual will be referred to as the "inspector." The inspector must be able to determine: Whether the steps in the energy control procedure are being followed.

Does OSHA require a lock out/tag out log book? ›

Who Needs to Utilize Lockout Tagout PROCEDURES? Lockout tagout procedures and training are necessary for all companies with equipment and facilities with hazardous energy. These are necessary both to meet OSHA guidelines and keep your employees safe.

What Seven 7 types of energy sources are hazardous and must be lockout tagout during service and maintenance of equipment? ›

Lockout/tagout is a hazardous energy control program used to ensure that machines and equipment are totally isolated from all energy sources (electrical, hydraulic, pneumatic, kinetic, potential, thermal, chemical, and radiation).

What are safe work practices regarding lockout and tagout of equipment and machinery quizlet? ›

  • Preparation for shutdown. > Locate all energy sources.
  • Shut down procedures. > Apply authorized locks and tags after shutdown, Check for and release residual energy, Verify locks and tags in place, Try and operate to make sure it's off.
  • Restore to normal operations.

Why lockout/tagout is important? ›

Lockout/tagout is a system that blocks all incoming energy, and discharges all stored energy in the equipment, making it physically impossible for it to run or move. Workers need to be trained over lockout/tagout procedures in their workplace to protect themselves from injury.

What are the six step safety methods? ›

Six Steps to Control Workplace Hazards
  • Step 1: Design or re-organise to eliminate hazards. ...
  • Step 2: Substitute the hazard with something safer. ...
  • Step 3: Isolate the hazard from people. ...
  • Step 4: Use engineering controls. ...
  • Step 5: Use administrative controls. ...
  • Step 6: Use Personal Protective Equipment (PPE)
23 Aug 2016

What are the 4 types of hazardous energy? ›

The BLR report mentions the following sources of potentially hazardous energy that should also be identified when writing LOTO procedures:
  • Mechanical energy. ...
  • Hydraulic energy. ...
  • Pneumatic energy. ...
  • Chemical energy. ...
  • Thermal energy. ...
  • Stored energy.
27 Jan 2016

Who should remove a lockout if the person who put the lockout on is not present? ›

When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented, and incorporated into the employer's energy control ...

How many types of employees are involved with lockout tagout? ›

There are three types of employees which must receive training: authorized, affected, and other.

What are the three different roles one can play in lockout tagout? ›

3 Types of Employees To Train for Lockout Tagout - LOTO Training
  • Shutting it down.
  • Isolating it from its energy source.
  • Preventing the release of hazardous energy while performing maintenance and servicing.
6 Aug 2021

What is an OSHA requirement for tagout devices a tag must? ›

Tagout devices must be non-reusable and self-locking. Occupational Safety and Health Administration.

What is a lockout/tagout policy? ›

Lockout and tagout ensures that all employees are protected from the unexpected activation of mechanical and/or electrical equipment during maintenance, repairing, cleaning, servicing, or adjusting of machinery, or equipment.

How many steps are there in LOTO process? ›

The Eight Steps of Lockout Tagout (LOTO)

What information is required on a LOTO tag? ›

Why the lockout/tag out is required (repair, maintenance, etc.). Time and date of application of the lock/tag. The name of the authorized person who attached the tag and lock to the system.

What is the third step in the OSHA lockout/tagout procedure? ›

Lockout/Tagout Step 3: Isolation

The next step of the lockout/tagout procedure is to isolate the machine or equipment from any source of energy. This may mean any number of things, such as turning off power at a breaker or shutting a valve.

Which of the following should be included in a formal periodic lockout/tagout inspection? ›

The periodic inspections must contain at least two components: 1) an inspection of each energy control procedure, and 2) a review of each employee's responsibilities under the energy control procedure being inspected.

What are the basic steps of locking and tagging out a system? ›

Lockout Tagout Procedure in 8 Simple Steps
  • Find the procedure to be used. ...
  • Notify anyone affected by the lockout tagout. ...
  • Locate all listed energy sources. ...
  • Shut down the machine or equipment. ...
  • Lockout and tag all energy isolating devices. ...
  • Release any stored energy (steam, hydraulic, etc.).
25 Sept 2019

Who is responsible for lockout tagout? ›

Under the standard's group lockout/tagout requirements, a single authorized employee must assume the overall responsibility for the control of hazardous energy for all members of the group while the servicing or maintenance work is in progress.

How often does OSHA require lockout/tagout training? ›

Under paragraph 1910.147(c)(6)(i) an employer is required to conduct "a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of the standard are being followed." Under paragraph 1910.147(c)(6)(i)(C), the periodic inspection "shall include a review, ...

How many types of LOTO are there? ›

The four main types are gate valves, ball valves, plug valves and butterfly valves.

What are the 7 steps of LOTO? ›

LOTO Safety: 7 Steps of lockout tagout
  • Prepare for shutdown.
  • Notify all affected employees of the activities and equipment involved.
  • Shut down the equipment.
  • Isolate the equipment from the hazardous energy source.
  • Dissipate residual energy.
  • Apply applicable lockout or tagout devices.

What is the most important step in LOTO? ›

Step 4: Lockout/Tagout (LOTO)

Once the equipment or machine has been isolated from its energy source, lockout/tagout is the next step. This step is the most important in the entire six-step process. The authorized or approved employee will attach the lockout, Tagout devices to an energy-isolating device.

What is the first step when planning and preparing for a lockout? ›

The first step to completing a proper lockout tagout is preparing the equipment to be powered off. This involves investigating and identifying all power sources used by the machine and understanding the appropriate procedures necessary to disconnect or eliminate them.

What is one method of ensuring lockout/tagout safety during shift changes? ›

Direct hand-over method – With this approach, authorized employees meet at the worksite and change personal lockout devices directly. The oncoming employee applies his device to each lockout point before the departing employee removes his or hers. This is OSHA's highly preferred method.

What is the final step in the lockout procedure before servicing? ›

Render all stored and/or residual energy safe. Once the lockout or tagout devices have been applied, all potentially hazardous stored or residual energy must be relieved, disconnected, restrained, and rendered safe before the servicing or maintenance can be conducted.

Who must perform LOTO procedure inspections? ›

The periodic inspection must be performed by an authorized employee other than the one(s) who is using the energy control procedures. This individual will be referred to as the "inspector." The inspector must be able to determine: Whether the steps in the energy control procedure are being followed.

What are the 10 steps for lock out/tag out? ›

10 key steps for lockout/tagout procedures
  1. Identify the procedure to use. ...
  2. Prepare for the shutdown. ...
  3. Notify all affected employees. ...
  4. Shut down the equipment. ...
  5. Isolate the equipment. ...
  6. Add the individual locks. ...
  7. Check stored energy. ...
  8. Verify the isolation of the machine or equipment.

What is the importance of applying lockout tagout? ›

Lockout/tagout is a system that blocks all incoming energy, and discharges all stored energy in the equipment, making it physically impossible for it to run or move. Workers need to be trained over lockout/tagout procedures in their workplace to protect themselves from injury.

What would you do if an employee is not available to remove the lock? ›

When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented, and incorporated into the employer's energy control ...

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