Does OSHA require employees to receive lockout/tagout training?
The procedure of lockout/tagout (LOTO) is meant to ensure that dangerous machines are literally on "lock-down" and are rendered inoperative while employees perform servicing or maintenance work on these machines or materials. If such machinery or equipment is not properly turned off, energy sources could be released and cause serious injury to employees. Therefore, OSHA takes necessary precautions by requiring respective employee training and certification. In 1910.147, OSHA specifically spells out the steps that employers must take to control hazardous energy and thus eliminate hazards and prevent injuries at the worksite. In accordance to 1910.147(c)(1): "The employer shall establish a program consisting of energy control procedures, employee training, and periodic inspections, to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup, or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative."
Which employees are required by OSHA to receive lockout/tagout training?
Every employee who is authorized to use the lockout/tagout procedure must be adequately trained by the employer, whose job it is to ensure that all said employees understand both the purpose and the function of the energy control program. Each authorized employee must be educated in regards to: (1) the recognition of potentially hazardous energy sources; (2) the type and magnitude of the energy at the worksite; and (3) the means for energy isolation and control. Each affected employee must also be instructed in the purpose and use of the lockout/tagout procedure.
How often is refresher lockout/tagout training required?
Refresher training shall be provided in the case of: (1) a change in employee job assignments; (2) a change in machinery, equipment, or processes; (3) a change in the energy control procedures; or (4) if the employer has reason to believe that employee knowledge or use of the energy control procedures is inadequate or flawed.
Are regular inspections of the energy control procedures required?
Yes. The employer must conduct an annual (at minimum) inspection to ensure that the procedures and regulations issued by OSHA’s standard are being followed; furthermore, an authorized employee (other than the one(s) utilizing the respective equipment) must perform periodic inspections.
Does our lockout tagout procedure need to be documented in writing?
Yes. Procedures must be developed and documented. Exceptions exist when: (1) the machine/equipment has no potential for potentially hazardous stored/residual/re-accumulating energy after shutdown; (2) there is a single energy source that can be identified and isolated; (3) isolation and lockout/tagout will completely de-energize/deactivate the machinery or equipment (or remove it from the energy source); (4) a single lockout device achieves a locked-down condition; (5) the employee performing service/maintenance on the machine or equipment has exclusive control of the lockout device; (6) serving/maintenance of machine or equipment does not create hazards for other employees; and (7) employer (utilizing this exception) has had no accidents due to activation/re-energization of the respective machine or equipment during servicing/maintenance.
Are independent contractors responsible for using their own lockout/tagout procedures when working at our facility?
Yes. In addition, the on-site employer and outside employer are mutually responsible for informing each other of their respective procedures. According to 1910.147(f)(2)(ii): "The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer’s energy control program."
Are we required to lockout machines that will no longer be used?
Yes. Machines or equipment must be turned off or shut down by an authorized or affected employee using the procedures established for that particular machine or equipment; stored energy must be dealt with accordingly. 1910.147(d)(5) states: "Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe."
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