SAFETY SOLUTIONS: Is Your Lockout & Tagout Program Working?
In 2011, failure of employers to properly ensure that
their employees are following OSHAŐs 1910.147
Lockout & Tagout standards is still on the top ten
items for OSHA citations. As a matter of fact, two of
these citations are for failure to conduct the periodic
audit at least annually and with each employee and failure
to have machine/equipment specific lockout and
Are you in compliance with these OSHA standards? As
a business owner, do you know what these standards
It is 2011 and it is not the small mom and pop companies
that fail to have these mandatory programs in place.
As a matter of record, the majority of large companies do
not have a good program in place to protect their workers.
Some large companies state they did not want to
waste the money to put this mandatory program in place.
Perhaps after reading this OSHA document, employers
will understand the OSHA regulation and their responsibility
WASHINGTON -- The U.S. Department of LaborŐs
Occupational Safety and Health Administration (OSHA)
today proposed $2.78 million in penalties against Ohiobased
Cintas Corp. following an inspection into the March
2007 employee death at the Cintas laundry facility in
Tulsa, Oklahoma. The employee was killed when he fell
into an operating industrial dryer while clearing a jam of
wet laundry on a conveyor that carries the laundry from
the washer into the dryer. Cintas is the largest uniform
supplier in North America, with more than 400 facilities
employing more than 34,000 people. The facility in Tulsa
has 160 employees.
ŇPlant management at the Cintas Tulsa laundry facility
ignored safety and health rules that could have prevented
the death of this employee,Ó said Assistant Secretary of
Labor for OSHA Edwin G. Foulke Jr. Forty-two willful,
instance-by-instance citations allege violations of the
OSHA lockout/tagout standard for the failures to shut
down and to lock out power to the equipment before clearing
jams, and to train four employees responsible to clear
jams that lockout/tagout applies and how to perform the
operations. One repeat citation alleges the failure to protect
employees from being struck or pinned by the conveyor.
Three serious citations allege the failures to protect
employees from falls, to have a qualified person inspect
the lockout/tagout procedures and to certify the procedures
In a separate case, OSHA issued five repeat and two
serious citations with penalties totaling $117,500 for violations
of the lockout/tagout and machine guarding standards
found at the Cintas Columbus, Ohio, facility. OSHA
also has opened investigations in Arkansas and Alabama.
Washington, an OSHA State Plan state, has issued four
citations with proposed fines totalling $13,650, alleging
violations for similar hazards at the Yakima Cintas facility.
The Control of Hazardous Energy Source Standard (29
CFR l9lO.l47), which is more commonly known as the
Lockout/Tagout Standard, is a Federal Occupational
Safety and Health Administration (OSHA) program, It is
designed to prevent the unexpected start-up, or energizing,
of machinery and equipment during service and maintenance
operations which could cause injury to employees.
It is also designed to prevent the release of stored energy
which could cause injury to employees. Industry has been
obligated to comply with the Lockout/Tagout Standard
since January 3, l990.
The lockout standard applies if:
Standard provided they are
- The employee is required to remove or bypass a guard
or other safety device during service and maintenance.
- An associated danger zone exists during a machine
- The employee is required to place any body part into
an area of the machinery or equipment where work is
actually being performed upon the material being
- Minor tool changes, adjustments, and other minor
service activities, which take place during normal production,
are not included in the Lockout/Tagout
- routine, repetitive, and integral to the use of the
that they are performed using alternative measures
which provide effective protection for the employee.
Most people immediately think of electricity as a potentially
hazardous energy source. There are other sources of
energy, though, that can be just as hazardous. These energy
sources include thermal, chemical, pneumatic,
hydraulic, mechanical and gravity, It is important to
remember that all sources of energy that have the potential
to unexpectedly start-up, energize or release must be
identified and locked, blocked or released before servicing
or maintenance is performed.
Written Lockout/Tagout Program
In order to comply, a company must prepare a written
Lockout/Tagout Program which includes the scope, purpose,
authorization, rules and techniques to be utilized in
the control of hazardous energy. Training must also be
provided to all employees who are affected by the
The written program must have:
A specific statement as to the intended use of the program.
Specific steps for shutting down, isolating, and blocking machinery and
equipment in order to control hazardous energy.
- Specific procedures for the placement and removal of lockout/tagout
devices as well as the method of identifying an individual's locks or tags.
- Requirements for verifying the effectiveness of the lockout/tagout device
by testing procedures for machinery and equipment.
- A detailed training program for employees who perform the service and
maintenance and for employees who are indirectly affected by those
- Descriptions of company lockout/tagout policies regarding multiple lockout/
tagouts, outside personnel, shift changes, and training of employees.
The basic equipment needed for a lockout/tagout procedure are locks
and/or tags. Locks are to be utilized whenever possible. Both locks and tags
must clearly indicate the identity of the employee who applied the device.
This provides positive identification as to who is servicing the machinery
and equipment. The identification will also indicate who may not have finished
working in a multiple lockout/tagout situation. The locks and tags
must be durable enough to withstand the environment in which they will be
used. Information on the locks and tags must remain legible, Locks must be
substantial enough to prevent removal without the use of excessive force.
Tags must be substantial enough to prevent accidental or inadvertent
removal. Both locks and tags are to be standardized by either color, shape
or size. Tags must have a standard print and format, If an energy isolating
device is not capable of being locked out, a tag is to be used. An energy
isolating device is simply a mechanical device that physically prevents the
transmission or release of energy. All machinery and equipment must be
designed to accept a lockout device when major replacements, repairs, renovations,
modifications of machinery or equipment are performed, or whenever
new machinery is installed.
An audit should be conducted on all machines and equipment to identify
all potentially dangerous energy sources and all energy isolating devices.
By doing this, employers will be able to establish all appropriate
Should you need additional information on this mandatory
regulatory requirement, please feel free to contact me
or visit my website at www.podojilconsulting.com. OSHA
has many publications, including specific topics for small
businesses that are available or can be ordered online.
Additional resources of information on safety-related
topics and programs include:
- National Institute for Occupational Safety & Health -
- Canadian Center for Occupational Health & Safety -
- National Safety Council - www.nsc.org
- American Society of Safety Engineers - www.asse.org
- Podojil & Associates (www.podojilconsulting.com) also
has free safety topics, training materials, monthly toolbox
talks, safety checklists and PowerPoint programs
that you can download free.
For more information, click on the author biography at the top of the page.