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Top 5 LOTO Procedure Mistakes to Avoid

Top 5 LOTO Procedure Mistakes to Avoid

Energy sources including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment can be hazardous to workers. During the servicing and maintenance of machines and equipment, the unexpected startup or release of stored energy can result in serious injury or death to workers.

Machine-specific Lockout/Tagout (LOTO) procedures are implemented to avoid such mishaps. They provide mandatory safety standards that companies must follow during maintenance.

OSHA standards must be followed when developing robust LOTO procedures. On the other hand, some businesses seem to make frequent blunders when creating and implementing these procedures.

What are LOTO Procedures?

Proper Lockout/Tagout (LOTO) practices and procedures safeguard workers from the release of hazardous energy. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry outlines specific actions and procedures for addressing and controlling hazardous energy during servicing and maintenance of machines and equipment. LOTO procedures also standardize how personnel accesses crucial components which will help execute their tasks.

LOTO Procedures: Top Mistakes to Avoid

Employers are obligated to develop LOTO procedures specific to the needs of their business. There are general safety guidelines; however, they must form the basis of these rules.

The most common blunders involve failure to meet OSHA standards and improper equipment tagging.

1. Not Following OSHA Standards

OSHA mandates employers to implement standardized LOTO methods to safeguard technicians during maintenance tasks. General requirements include:

  • Locking out components
  • Disconnecting energy sources
  • Releasing stored energy

All employees who work in an area where energy control procedure(s) are utilized need to be instructed in the purpose and use of the energy control procedure(s), especially against attempting to restart or reenergize machines or other equipment that are locked or tagged out.

2. Failing to Properly Tag Equipment 

Equipment that has been properly locked and tagged out should guarantee that the machine remains shut down until maintenance is completed.

Verification requires:

  • Checking whether machinery and components have been locked out
  • Checking whether hazardous energy has been locked out
  • Ensuring that any stored energy is released
  • Verifying that the machine will not start up when the Lockout/Tagout device is in place
  • Confirm Suspended parts are lowered to a resting position or blocked to prevent movement

LOTO procedures are not effective if they are not being followed. Therefore, the authorized employee should communicate to all affected staff members what will be locked/tagged out, why it is being locked/tagged out, how long the system will be unavailable, who is responsible for the Lockout/Tagout, and who to contact for more information.

3. Not Verifying That Machines Are Turned Off

It is essential to verify that machinery has been locked and tagged out before performing work on equipment. If equipment has not been properly isolated, other technicians or affected employees may mistakenly believe that a machine is safe when it continues running or inadvertently restart a system that was never properly shut down. This situation can result in serious injury or loss of life since workers will be unaware of the imminent hazard when they remove their lockout device from the machine.

Verification can take place in several ways:

  • The machine, equipment, or process controls (push buttons, switches, etc.) are engaged or activated, and the result is observed. No response means isolation is verified. Return controls to the safe position (off).
  • Visual inspection of:
    • Electrical connections to make sure they are open.
    • Suspended parts are lowered to a resting position or blocked to prevent movement.
    • Other devices that restrain machine or process movement.
    • Valve positioning for double block and bleed (for pipes or ducts) – closing two valves of a section of a line and then bleeding (or venting) the section of the line between the two closed valves.
    • The presence of a solid plate is used to absolutely close a line – called line blanking (for pipes or ducts).
    • Any other acceptable method of energy isolation.
  • Testing of the equipment:
    • Test circuitry (should be done by a certified electrician)
    • Check pressure gauges to make sure hydraulic and pneumatic potential energy has been removed.
    • Check temperature gauges to make sure thermal energy has been discharged.

4. Not Properly Training Employees On LOTO Procedures

Effective employee training prevents mistakes, accidents, and injuries. Employers are required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures. Workers must be trained in the purpose and function of the energy control program and have the knowledge and skills required for the safe application, usage, and removal of the energy control devices.

There are three categories of training based on the degree of a worker’s involvement in the LO/TO process:

  • Authorized employees are those who will perform maintenance or service work under circumstances that require LOTO. These employees will need to use locks and tags to protect themselves and must be trained to recognize sources of hazardous energy, the kinds and magnitudes of energy available in the facility, and the steps needed to isolate and control that energy safely.
  • Affected employees are those whose work may be affected by having equipment or machinery locked out or tagged out. While these workers will not perform the maintenance work themselves and will not generally need to apply locks or tags in their own work, they may need to adjust their normal work procedures to account for the LOTO process. They need to be trained on the purpose and general use of the LOTO procedures.
  • Other employees are generally unaffected by the actual practice of LOTO. However, if they might work near equipment that is locked or tagged out, even these employees need to be aware that a LOTO procedure is in place and how to recognize when it is being used. All workers should be prohibited from attempting to restart or re-energize equipment that is locked or tagged out.

5. Allowing Unauthorized Personnel Access To Restricted Areas

To prevent injuries from occurring, companies must enforce LOTO policies and procedures at all times. All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to prohibit access to hazardous zones from unauthorized personnel and ensure that locks, tags, and signs are used in these areas at all times.

Lockout/Tagout Best Practices for Workplace Safety

The following are some of the best practices that you can adopt to provide safety while carrying out Lockout/Tagout procedures:

  • Employers, at least once per year, are to check each LO/TO procedure in use in their facilities. These inspections are intended to confirm that the procedures are effective and are actually being followed, with the goal of correcting any problems. Involving personnel in the Lockout/Tagout review process will encourage them to think critically about the different aspects of these protocols, which can help prevent potentially hazardous situations from occurring.
  • Encourage employees to report failures of Lockout/Tagout procedures.
  • The timely identification of deficiencies in LOTO procedures can often help prevent injuries before they occur, making it easier to make improvements without needing a major revision.
  • Make sure that all LOTO devices are regularly checked for proper functionality. Without being aware of potential safety issues, workers may use faulty equipment and cause even greater safety problems.
  • Ensure that the correct Lockout/Tagout device is always used for a specific job.

On-Site LOTO Safety Training

The success of a LOTO program relies on the clarity of operating procedures, simplicity of comprehension, and the assignment of Lockout/Tagout operations to authorized staff.

Therefore, employers should not stop at generic lockdown instructions alone when developing machine-specific LOTO rules. Instead, they should consider enforcement methods, review tools, and a report-keeping procedure for recording complaints, comments, and audit findings.

At AOTC, we provide on-site Safety & Compliance Training to protect your employees and your business. Contact us today to schedule your courses.


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