Do Lockout/Tagout Procedures Keep Workers Safe?

Lockout/tagout procedures are designed to keep workers safe from the unforeseen startup of machinery or equipment, including a sudden release of electrical, mechanical, hydraulic, thermal, pneumatic, or chemical energy. These unexpected events can result in serious or fatal injuries, including amputations, crush injuries, electrocution, burns, exposure to hazardous chemicals, and severe lacerations. Understanding how to use each type of procedure correctly can help workers avoid serious injuries.

What is the Difference Between Lockout/Tagout?

Although lockout/tagout procedures share the same purpose, they employ different means for accomplishing that goal. A lockout device is essentially a special-purpose lock. It is designed to hold a piece of machinery or equipment safely in an off position by virtue of the following:

• Isolating the energy of the equipment with a physical restraint
• Employing a key and lock to secure the restraint

Once a machine or piece of equipment is locked out, the restraint can be removed only by using the required key or some extraordinary measure, such as bolt cutters. Energy-isolating devices on lockout programs may include circuit breakers, line valves, safety blocks, and disconnect switches. Tagout devices include warning labels, which are fastened to energy-isolating devices to warn workers that the machine or equipment is currently being serviced and must not be used or energized until maintenance activities are finished. Tagout devices offer less protection than lockout devices because they do not employ a physical restraint and are easier to remove.

Employers are responsible for supplying lockout and/or tagout devices where needed. These devices should never be used for any other purpose. They must be durable enough to perform well and refrain from deteriorating due to the conditions that exist in that particular workplace.

When Should Employers Implement Lockout Procedures?

Employees should use a lockout program whenever they perform service or maintenance on machinery or equipment that, if energized unexpectedly, could expose the worker to hazardous levels of energy. To implement a lockout device, the machinery or equipment must support one of the following:

• A lockable electric disconnect switch
• A hasp, which is a slotted hinged metal plate that forms part of a fastening for a door or lid
• A built-in locking mechanism
• The ability to be locked without dismantling the energy-isolating device or permanently altering its energy-control capability

For example, lockout devices can be implemented on machinery or equipment with lockable valve covers or circuit breaker block outs.

When Should Employers Use Tagout Procedures?

The Occupational Safety and Health Administration (OSHA) views lockout devices as superior and more effective in protecting workers than tagout devices. Therefore, tagout devices should be used only when it is not possible to implement a lockout program on a machine or piece of equipment.

Tagout warnings should be securely fastened as safely as possible to the circuit breaker, disconnect switch, valve, or other energy-isolating device. Tagout devices should also be immediately obvious to workers who may want to use the equipment. The wording on tagout devices should be standardized and legible to all workers. Tags should be attached using a strong, one-piece nylon cable or equivalent.

Who Benefits Most from Lockout/Tagout Programs?

All workers are safer when employers implement lockout/tagout programs where needed. However, these programs deliver the biggest benefit to maintenance workers and other employees who must service machinery and equipment with the power to the equipment completely shut off. Although machine operators are protected by machine guards, maintenance workers must often remove these guards to service the equipment.

According to the National Institute for Occupational Safety and Health (NIOSH), maintenance workers can be caught in machinery and suffer amputations, fractures, or fatal injuries if machines start up unexpectedly during maintenance or service. Other types of injury can occur when maintenance workers are servicing systems with pressurized valves or pipes that contain dangerous chemicals or substances kept at extreme temperatures.

Role of Authorized Employees in the Implementation of Lockout/ Tagout Systems

In accordance with OSHA guidelines, only authorized employees should use lockout/tagout devices. To achieve the designation of an authorized employee, a worker must be thoroughly trained on several topics that include the following:

• How to recognize the hazardous energy sources on the job site
• The type and magnitude of the energy onsite
• Procedures for isolating and controlling hazardous energy
• The steps involved in executing a lockout/tagout procedure

Proper use of lockout/tagout devices require workers to follow certain procedures when servicing or performing maintenance on equipment or machinery. Guidance issued by OSHA stipulates that authorized employees follow a six-step process in sequence when performing maintenance or service activities:

• Prepare for shutdown by notifying other workers that maintenance is about to begin.
• Shut down the machine or equipment.
• Disconnect or isolate the equipment from the hazardous energy source.
• Apply the lock and/or tag.
• If there is stored energy, release or block it appropriately.
• Confirm that workers are cleared from the area and that locking devices are secure before performing maintenance.

Regarding the fifth step, examples of releasing stored energy include venting gases, draining fluids, releasing springs, blocking elevated parts that may drop, and bringing moving parts to a complete stop. According to OSHA, workers do not need to follow this six-step process if unplugging equipment from an electrical outlet will completely control exposure to hazardous energy, as long as the authorized employee has exclusive control over the plug. Also, if shutdown of the system is impractical or continuity of service is essential, employees must follow other documented procedures and use equipment that will afford them proven protection.

What Should Workers Do After Maintenance is Complete?

First and foremost, only authorized workers should remove lockout/tagout devices before re-energizing machinery or equipment. After maintenance is complete, OSHA recommends that workers complete the following steps before removing lockout/tagout devices:

• Inspect machinery or equipment to confirm that it is intact.
• Remove nonessential items from the area.
• Confirm that other workers are at a safe distance from machines.

After removing the lockout/tagout devices, the authorized employee should communicate to other workers nearby that the devices have been removed and the machinery or equipment can now be energized and used.

Consequences of Ignoring Lockout/Tagout Procedures

Properly de-energizing machinery and equipment is an essential component of lockout/tagout procedures. According to a multi-year investigation conducted by NIOSH, failure to completely de-energize, block, or dissipate energy before conducting maintenance was a factor in 77 percent of fatalities related to equipment or machine maintenance.

Failure to lockout/tagout energy control devices after de-energization was a factor in 17 percent of those accidents. These accidents may have been entirely preventable. Failing to apply lockout/tagout procedures is often the most cited OSHA violation in manufacturing. One OSHA study revealed that lockout/tagout procedures were not attempted in more than half of the cases investigated. NIOSH recommends the following to prevent machine-related injuries:

• Comply with OSHA regulation 29 CFR 1910.147, which governs the control of hazardous energy.
• Document a hazardous energy control program that includes comprehensive lockout/tagout procedures.
• Develop procedures that are specific to each machine or piece of equipment.
• Ensure that there is sufficient hardware and labels to implement the program.
• Provide employee training on the program and procedures.

While employers are responsible for planning and conducting training on lockout/tagout procedures, sometimes those procedures are only necessary because the machine manufacturer did not safely design the machine. Machine manufacturers must design their products to be safe and employers must monitor workers to ensure that they are following best practices. Doing so can prevent injuries and keep workers safe.

Philadelphia Workers’ Compensation Attorneys at Galfand Berger LLP Advocate for Safety in the Workplace

Lockout/tagout procedures save lives and prevent injuries. However, lockout/tagout regulations are among OSHA’s top 10 cited violations each year. When employers fail to act responsibly, workers get hurt. Likewise, when manufacturers design a machine and require workers to lockout or tagout the equipment rather than incorporating practical safety features, workers are the ones who pay the ultimate cost. Whether the employer failed to act responsibly or the machine manufacturer failed to design the machine safely, Galfand Berger attorneys are here to help.

For more than 70 years, the Philadelphia Workers’ Compensation attorneys at Galfand Berger LLP have advocated for injured workers. For a free consultation, fill out our online contact form or call 800-222-8792. From our offices in Philadelphia, Bethlehem, Lancaster, and Reading, Pennsylvania, we proudly help injured workers throughout Pennsylvania and New Jersey, including Allentown and Harrisburg.