Lockout/tagout (LOTO) is a General Industry OSHA standard that applies to “the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.”
The General Industry LOTO standard and its appendix are about 5,000 words long, which is an indication of just how important this issue is. If an industrial machine starts up while an employee is working on (or inside) it, then the incident is likely to result in a fatality or serious injury.
Given the severity of these events, it’s not surprising that OSHA gives little leeway to employers over LOTO violations – and the monetary penalties can be punitive.
LOTO Regulations Applicable to the Construction Industry
Technically, lockout/tagout doesn’t apply to construction activity. It would be highly unusual for construction workers to service the types of industrial devices that require LOTO procedures. Conveyor belts in a pretzel factory, sure. Milling machines in an engine block plant as well. But not the tools used by the people showing up to the construction site.
When devices and machines that require LOTO are involved, they’re operated by machine operators and serviced by repair professionals. There’s no need for OSHA to apply universal LOTO requirements to construction.
Still, that doesn’t mean there are no LOTO guidelines that apply to the construction industry.
The 29 CFR 1910.147 lockout/tagout standard doesn’t regulate construction activity, but OSHA does have some universal precautions for construction that address the control of hazardous energy, which can be found at 1926.417. Because construction activity doesn’t involve the types of industrial machinery found in factories, the standards applicable to the control of hazardous energy in construction activity are far less expansive – less than 100 words. It can be summarized as follows:
If a control that governs the delivery of electrical power to equipment or circuits is required to be deactivated in order to do the work on the equipment (or circuits), then the control needs to be tagged. The tag signals to others that the control is deactivated, and that the equipment is out of commission.
It’s important to note that de-energizing the equipment (or circuits) isn’t enough – it must also be “rendered inoperative.” OSHA used this particular wording to indicate that methods other than lockout are permissible (as long as they’re effective). In a letter of interpretation, OSHA used removing a fuse or disabling a plug as two examples of rendering a device inoperative. Communication is key, so tags must also be attached at all points where the electrical equipment or circuits can be energized.
In-House LOTO Programs
The 1926.417 standards apply to electrical equipment and installations used to provide electric power and lighting at construction sites, not electrically-powered tools. So, there’s no requirement to tag a circular saw that needs repair, though there’s nothing stopping you from using tags as an extra precaution.
If you go above and beyond the OSHA standards and use an in-house tagging system, your procedure needs to be understood by everyone on site. Uniformity in your lockout/tagout practice is essential.
Locks and tags may only be removed by the employee who placed the lock and tag on the equipment. In the event an employee were to forget to remove his or her lock, there must be a very specific Lockout/Tagout procedure as to how, and who can remove that person’s lock. Moving another person’s lock should only be performed after all efforts for removal by the lock, by the lock owner have been fully exhausted.
State OSHA Standards
Also, be aware that State OSHA programs can write standards that reach beyond those of Federal OSHA. When you have a construction project in a state that has its own OSHA program, take the time to review their standards to see if you’ll need to comply with any additional provisions – for lockout/tagout or anything else.
Template LOTO Program and Toolbox Talk for Signatory Contractors
The FCA Safety Manual includes a lockout/tagout program, and is available to all FCA members as part of their FCA membership.
- FCA Toolbox Talk: Lockout/Tagout – Affected Persons
- Lockout/Tagout Program Template download
- Click here to request your complete FCA Safety Manual if your company hasn’t done so yet!
Safety is for Everyone – Amerisafe Group
This content is provided by the Amerisafe Group, which is FCA International’s safety partner. Amerisafe believes safety is more than just finding solutions to unsafe behavior by responding to workplace accidents. Safety is about identifying and preventing hazards from happening. Your FCA membership includes access to a Toolbox Talk library (click here to request your company’s access), and click here for more Amerisafe safety blogs.