Under the rules and regulations of the Occupational Health and Safety Administration (OSHA) it is the responsibility of an employer to provide relevant training in the application and enforcement of lockout/tagout procedures.
Under section (c)(7)(i) of 1910.147 it states:
“The employer shall provide training to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. The training shall include the following:”
The first thing you need to remember when thinking about LOTO training is that it is not acceptable to just train the team who may be carrying out service/maintenance. Instead, it is a legal responsibility to provide training to absolutely anyone who is an ‘affected employee’ which means any potential employee who is affected in any way by the enforcement of energy control must receive the training as well.
By doing so, you ensure everyone within a working environment knows exactly what is going on when lockout/tagout is being utilised, and help prevent unnecessary accidents as a result of miscommunication.
Section (c)(7)(i)(a) states:
“Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control.”
Section B states:
“Each affected employee shall be instructed in the purpose and use of the energy control procedure.”
And Section C states:
“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.”
Tags/Tagout Training
The next section of OSHA’s guidelines provides extensive information about providing training for tagout procedures, which are just as important as lockout/
Section (c)(7)(ii) states:
“When tagout systems are used, employees shall also be trained in the following limitations of tags:”
Understanding
The first step is to make employees understand what the tag signifies, and the employer is responsible to make sure that employees understand that:
“Tags are essentially warning devices affixed to energy isolating devices, and a do not provide the physical restraint on those devices that is provided by a lock.” (Section C, 7, II, A)
Restraints
The next step involves making sure an employee understands that it is not acceptable to touch a tag unless they are authorised to do so and it is completely safe. The employer must ensure that the employee knows that:
“When a tag is attached to an energy isolating means, it is not to be removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated.” (Section C, 7, II, B)
Legibility
The tags used during lockout/tagout must also be legible, and provide clear instructions of what they are there for. It is therefore the employer’s responsibility to ensure employees know that:
“Tags must be legible and understandable by all authorized employees, affected employees, and all other employees whose work operations are or may be in the area, in order to be effective.” (Section C, 7, II, C)
Durability
The tags used during lockout/tagout procedures must be constructed of materials that are durable enough to survive the environment which they are placed in. This means that areas with dangerous environments must ensure that their tags are durable enough to remain legible and fixed in place, and that outside factors such as chemical damage or other harsh elements such as outside weather cannot be used to make the tag not acceptable.
OSHA’s description states:
“Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace.” (Section C, 7, II, D)
False Sense of Security
The vast majority of the time, only using a tagout procedure is not acceptable as a means of protection against the energisation of an isolated point. This means that it is important that employees realise that tagout is not a fully safe procedure, and they must be educated that this is the case.
OSHA states:
“Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall energy control program.” (Section C, 7, II, E)
Attachment
The final section references the importance of making sure that tags are durable enough to be not accidentally removed at any point, and employees must know that it is required. Employers need to make sure they provide the equipment that adheres to this standard and all the standards above at all points during the energy control program. It is also important to regularly carry out periodic inspections of programs and the equipment used to ensure that anything used is adequate for the job.
Under this section, OSHA describes it as:
“Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use.” (Section C, 7, II, F)
Retraining
Once an energy control program is in place, being followed and all training is completed, it may also be required to retrain employees in the future because of a number of changing factors.
Under this section of OSHA’s guidelines (which begins with C, 7, III), it outlines firstly that:
“Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. “ (Section C, 7, III, A)
Inadequacies/Deviations
As part of the periodic inspection of an organisations’ energy control program it may be possible that certain elements of the procedure are deemed inadequate, or the discovery of employee’s not enforcing the energy control procedure correctly may prompt retraining.
Under the next section OSHA describes this as:
“Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c, 6) reveals, or whenever the employer has reason to believe that there are deviations from of inadequacies in the employee’s knowledge or use of the energy control procedures.” (Section C, 7, III, B)
Introduction of New Procedures/Proficiency/Certification
Perhaps the mpst important part of the retraining process is to ensure any changes made within the scope of an energy control program are understood by employees and it is important to monitor their progress after the introduction of these new elements.
By doing so, the employer makes sure that the employees are safe and are following the procedure exactly how they are meant to be, which above all should be safely.
OSHA’s section of this states:
“The retraining shall re-establish employee proficiency and introduces new or revise control methods and procedures, as necessary.” (Section C, 7, III, C)
And:
“The employer shall certifiy that employee training has been accomplished and is being kept up to date. The certification shall contain each employee’s name and dates of training.”(Section C, 7, III, D)
Communication
As well as the enforcement of all relevant training, it is also the employer's responsibility to ensure that any changes are communicated effectively to staff and that energy isolation is performed by the correct people.
OSHA states:
""Energy isolation." Lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance." (Section, C, 8).
And:
"Affected employees shall be notified by the employer or authorized employee of the application and removal of lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment." (Section C, 9)
