How to Effectively Use Lockout/Tagout Devices in Your Energy Control Program
When the release of energy is not properly controlled, everyone suffers
First and foremost, controlling hazardous energy is necessary to protect workers from serious injury and death. Machine operators, laborers and craft workers can face electrocution, burns, lacerations, amputation and/or crushed/fractured body parts when energy is not properly controlled.
Secondly, OSHA standard 1910.147 (commonly referred to as the lockout/tagout standard) closely regulates controlling hazardous energy. OSHA non-compliance penalties range from $13,494 per violation to $13,494 per day beyond the abatement date up to $134,937 per violation.
Lockout/tagout devices are an important component within the procedures for controlling the release of hazardous energy. This article will walk you through how to effectively use lockout tagout devices in your energy control program.
What does lockout/tagout mean?
“Lockout/tagout” is the common way to refer to procedures for disabling machines and equipment so that they don’t accidently turn on while workers are executing repairs or maintenance. These procedures are often referred to, or written as LOTO, lockout tagout or lock out tag out interchangeably.
However, lockout and tagout are also individual actions within the system of procedures. Lockout (LO) is when you place a physical lock onto an energy isolation device so that the equipment can’t be energized. Tagout (TO) is when you use a tag to indicate that a piece of equipment should not be operated until the tag is removed.
When to use lockout devices
Between lockout devices (locks) and tagout devices (LOTO tags), lockout devices provide more protection for employees. When LOTO procedures are correctly followed and a lockout device is properly applied, machinery or equipment physically cannot be energized without a key or forcefully removing the device.
Lockout is the OSHA-preferred method for protecting workers from accidental energization. However, it is considered best practices to use lockout and tagout together as part of a comprehensive energy control program.
When to use tagout devices (LOTO tags)
Tagout procedures do not physically prevent equipment from being energized, but rather act as a prominent warning device. LOTO tags are used to clearly communicate the status of equipment and/or potential hazards to affected employees and all other employees who may be working in a nearby area.
In general, it is not considered best practices to rely solely on LOTO tags for your energy control program. However, OSHA standard 1910.269(d)(2)(ii), does outline two specific instances in which an employer may use tagout alone:
1) If a lock physically can’t be used on the isolating device
2) If the facility’s tagout program is comprehensive enough to provide the employee with protection equal to a lockout program
Lockout/tagout device requirements
Part 1910.147(c)(5) of the lockout/tagout standard covers lockout/tagout device requirements. Many of the lockout/tagout requirements apply to both types of devices. These are the specific rules for both locks and LOTO tags:
1) The employer must provide locks, LOTO tags and all other hardware for isolating, securing or blocking machines (for example, chains, wedges, etc.).
2) Singular use. Locks and LOTO tags must only be used for lockout/tagout procedures.
3) Durability. Both locks and LOTO tags must be durable enough to withstand the environment they’re used in, for as a long as it takes to complete lockout/tagout procedures.
4) Standardization. Locks and LOTO tags should be uniform color, shape or size within a facility.
5) Identification. The identity of the authorized employee applying the locks and LOTO tags should be displayed and/or indicated on both devices.
Additionally, locks must be substantial enough that, without a key, they can’t be removed without “excessive force or unusual techniques.” For example, using bolt cutters or picking the lock.
Specific LOTO tag requirements
LOTO tag OSHA requirements are unique from locks because the material durability, print stability and the way they attach to equipment are all regulated.
Not only do LOTO tags have to be materially durable (as listed above) but the way they attach to equipment must equally substantial so they’re unlikely to be accidentally removed. Additionally, the print has to be stable so the message doesn’t deteriorate.
In addition to all of the shared requirements, here are the specific rules for LOTO tags that must be followed in order to achieve OSHA compliance:
1) Attachment. Nylon cable ties (zip ties) are the preferred method and any other means of attachment must be at least equivalent. The basic characteristics preferred LOTO tag attachment means are: “non-reusable, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds.”
2) Pull strength. When attached, LOTO tags must resist 50 pounds of pull force to be removed. That means that the zip ties (or other means of attachment) should stay locked when pulled with 50 pounds force and the hang hole of the LOTO tag itself must also withstand at least 50 pounds of pull force.
3) Print stability. LOTO tags must remain intact and the print must remain legible in wet, damp and corrosive environments.
4) Hazardous warnings. The entire purpose of LOTO tags are to warn against the hazardous conditions that will occur if the equipment is energized. The warnings on LOTO tags must have a legend (header) that describes the warning.
OSHA-suggested LOTO tag headers: Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate.
5) Standardized print/format. The print and format of LOTO tag headers and other information must be standardized. It’s considered best practices to use OSHA/ANSI warning colors, formatting and headers.
Standardizing LOTO tags for your facility
OSHA specifically mandates standardization of both locks and LOTO tags in the lockout/tagout standard, so it must be done in order to achieve compliance. However, there are a couple other really great reasons to standardize LOTO tags in your facility.
Firstly, standardizing LOTO tags makes it easier for employees to learn how to identify locked out machines and equipment. Employee training is a big part of creating a comprehensive energy control program.
Secondly, standardized LOTO tags that follow general OSHA/ANSI guidelines for hazard warnings are more likely to be recognizable to all employees in general. Even if they don’t work in the area and are not specifically trained in lockout/tagout procedures.
There are several ways you can standardize the LOTO tags used in your facility:
Preprinted LOTO tags. Preprinted boxes of LOTO tags with OSHA/ANSI headers are a convenient and well-suited to average use. The most important features to look for are the pull strength and the writing tools that can be used on them.
Custom LOTO tags. You may find that more detailed information on LOTO tags or additional identification requirements (for example an employee photo) benefit your energy control program in terms of increased safety and efficiency.
In such cases, creating your own custom LOTO tags onsite with a standard laser printer greatly increases efficiency. Avery Industrial provides both print-and-go LOTO tag options as well as a print-and-assemble option for extra heavy duty use.
Our free safety and LOTO tag design templates can be modified to suit the specific needs of your facility and energy control program. As an added bonus, all your saved designs remain in the cloud and can be accessed any time you’re signed into your Avery account, which makes it easier to reprint as needed.
More lockout/tagout resources
Effectively using lockout/tagout devices within your broader energy control program helps protect workers from the truly dire hazards that can occur when the release of powerful energy is not controlled.
Read more about the lockout/tagout standard in our free LOTO overview white paper. Inside you’ll find:
- A full overview of OSHA standard 1910.147 and breakdown of the six lockout tagout steps
- The components needed to build an effective energy control program
- Tools and resources like our free LOTO steps poster download
Learn more about Avery Industrial tagging solutions available for standardizing custom safety and LOTO tags or shop tagging solutions now.