More Questions (and Answers) About OSHA’s LOTO Rules

Q. If equipment has a safety interlock and it’s own safety disconnect built in the unit, would it still need to be included in a lockout/tagout policy?

A. According to 1910.147(c)(4)(i), procedures must be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

An employer need not document the required procedure for a particular machine or equipment, however, when all of the following elements exist:

• The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees;
• The machine or equipment has a single energy source that can be readily identified and isolated;
• The isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment;
• The machine or equipment is isolated from that energy source and locked out during servicing or maintenance;
• A single lockout device will achieve a locker-out condition;
• The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
• The servicing or maintenance does not create hazards for other employees; and
• The employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

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Q. Is the written instruction for LOTO required to be posted and hung at each machine? Or does the regulation allow the written instructions to be filed away for easy access and training on how to access?

A. OSHA’s lockout/tagout rule does not require the written LOTO instructions to be posted on the machines. 29 CFR 1910.147(c) says that the employer “shall establish a program consisting of energy control procedures, employee training and periodic inspections,” but the rule does not specify where the program or lockout procedures must be kept.

We suggest you use OSHA’s electrical rule at 1910.133(b)(2), Locking and Tagging section, for guidance. It says “[T]he employer shall maintain a written copy of the [lockout/tagout] procedures and shall make it available for inspection by employees…” and OSHA inspectors. It is up to you the employer to determine the best way to “make it available for inspection…” Online access may be part of “make it available” but OSHA has issued statements under the hazard communication rule requiring employers to have a reliable backup system for document access in case the electronic (online) system fails. If you use the online system, it would be prudent to have a backup such as a paper copy available for inspection.

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