A Comprehensive Guide to Lockout Tagout (LOTO)

What is the Difference Between Lock Out and Tag Out?

The difference between lock out and tag out is the device used. The lockout device stops employees from operating the equipment while the tagout device informs them that the equipment should not be operated. Essentially, a tagout device is the second layer of protection against unsafe equipment operation while a lockout device is the first layer.

Lockout Tagout and Machine Guarding

Though the machine guarding standard covers exposure to hazardous energy during normal production operations, it is important to remember that the OSHA lockout tagout standard (instead of the machine guarding standard) will apply during normal production operations if:

• the employee is required to bypass or remove machine guarding
• the employee could be injured due to the sudden energization of equipment

OSHA Lockout Tagout Standard

The OSHA lockout tagout standard generally applies to any activity in which the sudden energization or startup of equipment and machinery could harm employees. 

OSHA Lockout/Tagout Exceptions

• Construction, agriculture, and maritime operations
• Oil and gas well drilling and servicing 
• Installations under the exclusive control of electric utilities
• Work on cord-and-plug-connected electrical equipment in which equipment is unplugged and the authorized employee has exclusive control of the plug
• Servicing, maintenance, minor tool changes or adjustments, and hot tap operations wherein employees are sufficiently protected by other safeguarding measures

OSHA Lockout/Tagout Violations

From October 2020 to September 2021, the OSHA lockout tagout standard has had 1,440 citations amounting to a total penalty of $9,369,143. This means that the average penalty for a lockout tagout citation is $6,506. To avoid incurring such penalties for one of the most violated OSHA standard, safety supervisors need to be aware of common OSHA lockout/tagout violations such as:

• Failure to identify and isolate all energy sources
• Failure to shutdown 
• Failure to de-energize
• Failure to drain residual energy
• Failure to provide lock out tag out training
• Failure to create equipment-specific LOTO procedures
• Failure to conduct periodic LOTO inspections
• Failure to establish a lockout tagout program
• Failure to develop and enforce a lock out tag out policy

Who is Involved in a Lockout Tagout?

Aside from the safety supervisor who is responsible for lockout tagout, other key personnel involved are authorized and affected employees. 

• Authorized employees in a lockout/tagout are those who lock or tag equipment so that they can safely perform the servicing or maintenance.
• Affected employees in a lockout/tagout are those who operate the equipment on which servicing is performed or who work in the area where the servicing is performed.

Lockout Tagout Devices

Employers are required by the OSHA standard to provide lockout tagout devices that are durable, standardized, substantial, and identifiable. LOTO devices cannot be reused. The following information is primarily based on the OSHA lockout tagout standard:

What is an Energy Isolating Device?

An energy isolating device is a mechanical device that physically prevents the transmission or release of hazardous energy. Examples of energy isolating devices are:

• manually operated electrical circuit breaker
• disconnect switch
• manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors and no pole can be operated independently
• line valve

Energy isolating devices DO NOT INCLUDE push buttons, selector switches, and other control circuit type devices.

What is a Lockout Device?

A lockout device is a device that utilizes a positive means to hold an energy isolating device in a safe position and prevents the energization of equipment and machinery. Examples of lockout devices are padlocks, blank flanges, and bolted slip blinds.

A LOTO padlock should only have one key. Lockout locks should not be keyed alike, in which multiple padlocks can be opened with one key. If the use of keyed alike locks cannot be avoided, limit their distribution among employees.

What is a Tagout Device?

A tagout device is a prominent warning device that can be securely fastened to an energy isolating device and indicates that both the equipment and the energy isolating device cannot be operated. The only example of a tagout device is a tag and its means of attachment to the energy isolating device.

What is a LOTO Box? 

Also known as a lockbox or a group lockout box, a LOTO box is used when equipment has several isolation points that need to be secured (with their own energy isolating, lockout, and tagout devices) before it can be locked out. This is referred to as a group lockout or a group isolation.

How Does a Lockout Box Work?

After completing a LOTO procedure on an isolation point, the employee will place the key to the lockout device in the lockbox and then attach their own personal padlock to the lockbox. After all personal padlocks have been attached to the lockbox, the group isolator will then place an orange or blue lock and an orange tag on equipment to indicate that all isolation points have been secured.

Colors of Lockout Locks and Tags

Though OSHA has not yet provided a standardized color coding system for lockout locks and tags, typical color codes are:

• Red tag = Personal Danger Tag (PDT)
• Orange tag = group isolation or lockbox tag
• Yellow tag = Out of Service Tag (OOS)
• Blue tag = commissioning and test tag
• Red lock = used by an authorized employee to lockout equipment during servicing
• Orange lock = used by a group isolator to indicate that servicing is safe to perform
• Yellow lock = used by an affected employee to lockout equipment before servicing
• Blue lock = used instead of an orange lock for lockboxes with more than 6
  isolation points

Lockout Tagout Steps

Authorized employees must complete the 15 lockout tagout steps in order.

1. Notify all affected employees that a lockout/tagout is about to begin.
2. Prepare for shutdown by ensuring that you have knowledge of the following:
   • the type and magnitude of energy
   • the hazards of the energy to be controlled
   • the method or means to control the energy
3. Shutdown equipment using the procedures established for it.
4. Locate and operate the energy isolating device.
5. Attach the lockout device and the tagout device.
6. Relieve, disconnect, restrain or render safe all potentially hazardous stored and residual energy. If there is a possibility of reaccumulation of such energy to a hazardous level, continue verifying isolation until servicing is finished.
7. Verify that hazardous energy has been isolated and equipment has been de-energized.
8. Perform the intended activity (such as servicing and maintenance) on equipment.
9. Remove non-essential items such as tools and spare parts.
10. Check if all equipment components are operationally intact.
11. Check if all employees are in safe positions or have cleared the area.
12. Notify all affected employees that the lockout tagout devices will be removed
13. Remove the lockout tagout devices if you were also the one who attached them. If not, do not attempt removal and notify the safety supervisor.
14. Notify all affected employees that equipment will be re-energized.
15. Restore energy to equipment and/or begin equipment startup.

What to Do if An Employee is Not Available to Remove the Lock?

The safety supervisor can remove the lock, provided that:

• they have verified that the employee is not in the facility
• they have received specific training on how to remove the device
• the specific removal procedure for the device is documented and included in the
  facility’s lockout tagout program

After removing the lock, the safety supervisor must also contact the employee to inform them the lock has been removed and must confirm that the employee is aware of this before they resume work at the facility.

Establishing a Lockout Tagout Program 

To be OSHA-compliant, a lockout tagout program must have 3 core components:

Lockout Tagout Procedures

Safety supervisors need to create equipment-specific LOTO procedures that outline the scope, purpose, authorization, rules, techniques, and means to enforce compliance. Each lock out tag out procedure must include the following, at the minimum:

• a specific statement of the intended use of the procedure
• specific procedural steps for:
  • shutting down, isolating, blocking, and securing equipment
  • placement, removal, and transfer of lockout tagout devices
• a description of who has responsibility for lockout tagout devices
• specific requirements for testing equipment to verify the effectiveness
  of lockout tagout devices

Periodic LOTO Inspections

A LOTO inspection can only be conducted by a safety supervisor or authorized employee who is NOT involved in the lock out tag out procedure being inspected. To conduct a LOTO inspection, the safety supervisor or authorized employee must do the following:

1. Identify the equipment or isolation point that the LOTO procedure is for
2. Specify the date of and the employees included in the LOTO inspection
3. Identify and correct the deviations and inadequacies of the LOTO procedure
4. Review the responsibilities of authorized and affected employees for lockout, tagout,
   and training
5. Verify that you have conducted the LOTO inspection by adding your name and signature

LOTO inspections must be conducted at least annually or more often if necessary.

Lock Out Tag Out Training

Since lockout tagouts have different levels of access, there are also different levels of training required for each type of access:

• For authorized employees, training must include hazardous energy sources, the type and magnitude of hazardous energy, and methods for energy isolation and control
• For affected employees, training must include the purpose and use of LOTO procedures
• For other employees who are or could be in the area that LOTO procedures are being applied, training must include prohibition rules on restarting equipment that is locked out

There is no OSHA requirement for the frequency of training, though retraining is necessary under certain conditions. Both lock out tag out training and retraining require certification.

LOTO Safety 

To go beyond compliance and truly build a robust lockout tagout program, safety supervisors must actively promote and sustain LOTO safety by doing the following:

Clearly define and communicate the lock out tag out policy

Develop a lock out tag out policy by coordinating with the head of the facility and asking employees for their input. While primary collaboration is with the head of the facility or your employer, you should also obtain clarification from employees regarding their concerns, especially about equipment safety. 

Once the lock out tag out policy has been formalized and established, ensure that all employees working in the facility have received copies of it. Hold an orientation to discuss the details of the policy and answer any questions that the employees may have.

Create a system for submitting and receiving LOTO reports

Aside from official LOTO inspection reports, informal LOTO reporting is also useful for promoting LOTO safety. Employees should have the means to inform you if lockout tagout devices are missing or if equipment’s energy levels remain hazardous. At the same time, you should also find a way to confirm that LOTO procedures are being followed and respond to urgent issues quickly.

Perform frequent LOTO audits

Unlike a LOTO inspection which is done at least once a year and focuses on a specific LOTO procedure, a LOTO audit is an evaluation of the LOTO safety of the facility. This can include inspecting the various equipment and machines to which the OSHA lockout tagout standard applies and the lockout tagout devices used in the facility.

Enforce lock out tag out documentation

Ensure that everything related to lockout tagout is documented. This includes the lock out tag out policy, procedures, inspections, training, reports, and audits. For a centralized database of all lockout tagout information, consider using digital documents instead of paper. Though paper may be what you are used to, it is highly inefficient to use paper documents in the long-term, especially if you want to form a sustainable lockout tagout program.

Lockout Tagout Software: SafetyCulture

SafetyCulture (formerly iAuditor) is a digital safety platform with features for lockout tagout:

• Safety supervisors can create equipment-specific LOTO procedures with the Templates feature. Employees can access and use these templates on any mobile device to ensure their compliance with each procedure.
• Safety supervisors can conduct periodic LOTO inspections and perform regular LOTO audits to assess the effectiveness of procedures and of the lockout tagout program.
• Employees can submit timely LOTO reports to safety supervisors with a few taps. They can briefly describe the issue at hand as well as attach a photo and a 3-minute video to explain the situation more clearly.

Get started with SafetyCulture for free.

Lockout Tagout Templates