Why are LOTO procedures important?
Lockout/tagout (LOTO) procedures shut down energy sources in electrified equipment so technicians can safely perform maintenance. Having reliable, consistent LOTO procedures is key to worker safety because they:
- Prevent accidental machine startup during maintenance, ensuring employee protection
- Reduce the risk of serious injuries or fatalities
- Ensure compliance with safety regulations and OSHA standards
- Protect equipment from unintended damage during servicing
Implementation can seem tricky, especially in large facilities with diverse equipment. However, getting it right is critical for minimizing the risk of worker injuries and OSHA penalties.
This guide gives you a ready-to-use LOTO checklist, plus our tips and best practices for compliance with OSHA requirements.
Key Takeaways
- LOTO procedures are the first line of defense against preventable workplace injuries and OSHA penalties.
- A standard LOTO procedure includes identifying energy sources, informing affected employees, powering down equipment, disconnecting energy sources, applying lockout/tagout devices, releasing stored energy, and verifying the procedure.
- Following best practices makes your LOTO procedures more effective. Regular inspections, hands-on training, and strict enforcement help prevent complacency and OSHA violations.
- Pay attention to OSHA standard 29 CFR 1910.147. It sets various requirements you must follow to avoid fines when creating LOTO procedures. The requirements include written procedures, proper lockout/tagout devices, periodic inspections, and more.
- A CMMS makes LOTO procedures easier to manage and audit. It helps digitize hazardous energy control procedures, assign and track lockout tasks, and create audit trails to satisfy OSHA inspectors.
Download your printable lockout/tagout procedure checklist template
Step-by-step lockout/tagout procedure
If you’re looking to implement lockout/tagout procedure, here’s a step-by-step guide. Feel free to modify steps based on your needs.
Lockout/tagout best practices for compliance
Even the most experienced maintenance teams are occasionally tempted to take shortcuts. Best practices ensure that everyone fully follows lockout/tagout procedures and goes back home safe at the end of the day. Here are three LOTO best practices you should follow to ensure compliance and occupational safety:
Periodic inspections and recordkeeping
Audit your LOTO program at least once a year. Sooner if equipment is upgraded or procedures change.
During inspections, verify that:
- Locks and tags are in proper condition
- Isolation points are clearly marked
- Stored energy has been safely released
At every inspection, use a computerized maintenance management system (CMMS) to maintain detailed logs of which employees conducted the inspection, what devices were used, what anomalies were discovered, and what corrective action was taken.
For example, suppose the inspection records show that residual pressure remains in the hydraulic lines even after the machine is properly locked out. This pressure occasionally causes the press ram to drift slightly, which is a potential pinch hazard.
Since this record shows a recurring issue, you can proactively check if hydraulic lines have been fully bled to prevent injuries during future inspections.
Invest in training and enforcement
Hands-on training sessions help employees practice on the machines they’re going to maintain before they perform any maintenance.
For example, you can show them how to identify hidden energy sources, properly apply locks and tags, and release stored energy. You can also help them practice responding to scenarios that might arise. For instance, what if a co-worker forgets to remove a tag or equipment starts unexpectedly?
Combine training with clear enforcement. Communicate that sticking to lockout/tagout procedures is non-negotiable.
Verify compliance during audits and recognize teams or individuals who consistently follow protocols. And if you notice any near misses, treat them as opportunities to retrain workers.
Avoid common mistakes
Here are some common mistakes to watch out for:
- Skipping steps in the procedure to save time
- Assuming someone else has already locked or tagged the equipment
- Using makeshift devices (like zip ties) instead of proper lockout hardware
- Forgetting to release residual or stored energy
- Placing tags where they’re hard to see or easy to ignore
- Overlooking secondary energy sources on complex machines
OSHA lockout/tagout requirements
Lockout/tagout isn’t just an internal safety practice. It’s a compliance requirement.
Following OSHA’s Control of Hazardous Energy standard (29 CFR 1910.147) helps ensure worker safety and avoid hefty penalties.
What does OSHA require for LOTO?
OSHA has outlined various LOTO requirements. These requirements apply depending on your equipment portfolio, whether contract or temporary workers are involved in maintenance, and other factors.
If you’re creating a LOTO checklist or tweaking our template, read these requirements to ensure your LOTO procedure checks all OSHA compliance boxes.
Here’s what OSHA requires:
- Written energy control program: Establish and maintain a written energy control program, including responsibilities and coverage of hazardous energy control procedures (29 CFR 1910.147(c)(2)).
- Detailed energy control procedures: Develop procedures outlining steps to shut down, isolate, block, secure, and verify the effectiveness of lockout or tagout measures for each machine or piece of equipment (29 CFR 1910.147(c)(3)).
- Training for authorized, affected, or other employees:
- Authorized employees (people who actually perform the lockout/tagout procedures) must understand how to recognize hazardous energy and apply control methods.
- Affected employees (workers who operate the equipment in question) must understand the purpose and use of LOTO procedures.
- Other employees (everyone else in the workplace) must know not to tamper with locked or tagged equipment. Retraining is required when procedures, equipment, or the workforce changes (29 CFR 1910.147(c)(7)(i)–(iii)).
- Annual periodic inspections and corrective follow-up: A qualified authorized employee (not the one completing the procedure) must conduct annual inspections to ensure compliance and correct deficiencies. The results of this inspection must be documented (29 CFR 1910.147(c)(6)(i)–(ii)).
- Verification of isolation before servicing: Test the equipment before work begins (29 CFR 1910.147(d)(5)–(6)). This could include trying to start equipment, testing voltage, releasing residual energy, etc.
- Protection of contract and temporary workers: Coordinate LOTO procedures with outside contractors or temporary staff, sharing procedures and verifying that equipment protections are in place (29 CFR 1910.147(f)(2)(i)).
- Limited exceptions: Minor and routine servicing during normal operations may be exempt from LOTO if specific conditions are met (29 CFR 1910.147(c)(4)(i) & Appendix).
Most people stop at 29 CFR 1910.147. However, LOTO requirements are sprinkled across several other OSHA standards 29 CFR 1910.333, 29 CFR 1910.179, 29 CFR 1910.269, and 29 CFR 1910.217.
It’s best to work with an internal expert and scan through applicable standards to make sure you don't miss out on any requirements. If you’re a small or medium-sized business, consider contacting OSHA to sign up for their free on-site consultation program and understand all requirements.
Using a CMMS to manage LOTO procedures
Lockout/tagout is only effective if it’s consistent. However, consistency is tough when multiple teams—staff from different crews or shifts, or contractors—work on the same assets, or when procedures change because you installed new equipment.
That’s where a CMMS can help. A CMMS lets you create standardized digital LOTO checklists, schedule periodic inspections, track training records, and document every lock and tag applied.
With a CMMS, your team doesn’t have to spend hours chasing paper logs. They can use their mobile devices to access data in a centralized system that keeps your LOTO program compliant and your workers safe.
If you’re ready to start implementing LOTO procedures and wave goodbye to compliance headaches, check out our comprehensive lockout/tagout guide.
FAQs
What’s the best way to track and manage lockout devices across multiple sites?
The best way is to use a CMMS. A CMMS lets you assign devices to specific assets and standardize procedures across multiple locations. This reduces confusion, improves accountability, and ensures compliance with OSHA standards.
How can digital tools like safety software improve lockout/tagout recordkeeping and workflow?
Digital tools automate recordkeeping by logging lockout events and inspections in a centrally accessible digital location. They also streamline workflows with digital checklists and mobile access for technicians, speeding up audits and making compliance easier to prove.
What are the best practices for training employees on lockout/tagout responsibilities?
Here are some lockout/tagout training best practices:
- Tailor training for specific job roles
- Use real-world scenarios during training
- Conduct ongoing audits post-training
- Retrain team members after incidents
The MaintainX team is made up of maintenance and manufacturing experts. They’re here to share industry knowledge, explain product features, and help workers get more done with MaintainX!
