Lock Out – Tag Out: A Fundamental Rule of Safety

Safety Brief

Even though hazardous energy is dangerous, it can be controlled. Having and following proper Lock Out – Tag Out procedures will ensure that workers are safe when working on trucks, equipment and machinery.

By Will Flower

Trucks, equipment and waste processing systems use a lot of energy. These machines may also store energy, which, if released, can be hazardous to workers. Some types of energy that can cause serious injury or death include electricity, hydraulic, pneumatic, gravity, thermal, kinetic and steam.

Some common examples of hazardous energy that workers will face at waste and recycling organizations include:

• An electrical system, which may remain energized even when a machine is in the off or idle position.
• A cylinder holding up a roll off box may have stored energy in the form of hydraulic power.
• An air tank containing pressurized air has pneumatic energy.

Stored energy is especially dangerous if it is unexpectedly released. The Department of Labor’s Occupational Safety and Health Administration (OHSA) states that almost 10 percent of serious accidents involve a failure to control hazardous energy.

To prevent injury, “locking out” or disabling the vehicle or equipment to prevent the release of hazardous energy and to prevent movement or a startup while workers are cleaning, repairing or maintaining a vehicle or piece of equipment must control every machine, vehicle and system.

The process of disabling a piece of machinery is known as “Lock Out – Tag Out”, which requires that hazardous energy sources be isolated and locked to make them inoperative before work begins on a piece of equipment. Power sources can be physically locked with a padlock and a tag can be placed on the lock identifying the worker who locked out the machine.  Importantly, the worker who installed the lock holds the key and is the only person who can remove the lock allowing a machine to be restarted. This Lock Out – Tag Out procedure prevents accidental startup of a machine while a worker is in or on a piece of equipment.

The specific requirements for Lock Out – Tag Out depend on the machinery and the type of hazardous energy that is being controlled. The Lock Out – Tag Out standards established by U.S. Department of Labor identify the employer’s responsibility to protect employees from hazardous energy sources on machines and equipment during service and maintenance. Some of the most critical aspects of the standards require employers to:

• Develop, implement and enforce a hazardous energy control program.
• Use Lock Out – Tag Out devices for equipment that can be locked out. Tag Out devices may be used in lieu of Lock Out devices only if the Tag Out program provides employee protection equivalent to that provided through a Lock Out program.
• Ensure that new or overhauled equipment is capable of being locked out.
• Develop, implement and enforce an effective Tag Out program if machines or equipment are not capable of being locked out.
• Develop, document, implement and enforce energy control procedures.
• Use only Lock Out – Tag Out devices authorized for the particular equipment or machinery and ensure that they are durable, standardized and substantial.
• Ensure that Lock Out – Tag Out devices identify individual users.
• Establish a policy that permits only the employee who applied a Lock Out – Tag Out device to remove it. (Note: there are exceptions to this standard—see 29 CFR 1910.147(e)(3))
• Inspect energy control procedures at least annually.
• Comply with the additional energy control provisions in OSHA standards when machines or equipment must be tested or repositioned, when outside contractors work at the site, in group lockout situations, and during shift or personnel changes.

Training for Lock Out – Tag Out is required

The OSHA standard also requires employers to provide effective training for all employees covered by the Lock Out – Tag Out standard. Workers must be properly trained to recognize hazardous energy and know, understand and be able to follow the procedures to control hazardous energy. Such training is a requirement and the OSHA standard for Lock Out – Tag Out training can be found in The Control of Hazardous Energy (Lock Out – Tag Out) (29 CFR 1910.147).

Most importantly, employees must be clearly instructed and trained to never start or energize machines or other equipment that are locked or tagged out. Regular training and retraining of the Lock Out – Tag Out procedures will help to maintain proficiency and give both employers and employees a chance to review changes in hazardous energy control procedures.

Lock Out

In practice, Lock Out is the isolation of energy from the system (a machine, equipment, or process), which physically locks the system in a safe mode. The energy-isolating device can be a manually operated disconnect switch, a circuit breaker, a line valve or other device that can be locked to a stationary item in a safe position (de-energized position). When the system’s energy sources are locked out, there are specific guidelines that must be followed in order to ensure that the lock cannot be removed, and the system cannot be inadvertently operated. These guidelines include:

• Each lock should only have one key (no master keys are allowed).
• There should be as many locks on the system as there are people working on it. For example, if a maintenance job requires three workers, then three locks should be present—each of the individuals should place their own lock on the system.
• Locks can only be removed by those who installed them.

Tag Out

Tag Out is a labeling process that is always used when lockout is required. The process of tagging out a system involves attaching or using an indicator (usually a standardized label) that includes the following information:

• Why the Lock Out – Tag Out is required (repair, maintenance, etc.).
• Time of application of the Lock Out.
• The name of the authorized person who attached the tag and lock to the system.

Again, it is important to stress that only the authorized individual who placed the lock and tag onto the system is the one who is permitted to remove them. This procedure will ensure that the system cannot be started up without the authorized individual’s knowledge.

Shared Responsibility

Employees, supervisors and employers have serious responsibilities for Lock Out – Tag Out programs. In general, employers are responsible for:

• Drafting, reviewing, updating and enforcing a written Lock Out – Tag Out program.
• Identifying employees, machines, equipment and processes included in the program.
• Providing the necessary protective equipment, hardware and training.
• Monitoring compliance and enforcing the program.

Supervisors are responsible for:

• Distributing protective equipment, hardware and ensuring its proper use by employees.
• Ensuring that equipment-specific procedures are established for the machines, equipment and processes in their area.
• Ensuring that only properly trained employees perform service or maintenance that require Lock Out.
• Ensuring that employees under their supervision follow the established Lock Out procedures where required.

Employees are responsible for:

• Assisting in the development of equipment-specific procedures.
• Following the procedures that have been developed.
• Reporting any problems associated with those procedures, the equipment or the process of locking and tagging out.

Hazardous energy is dangerous however it can be controlled. Having and following proper Lock Out – Tag Out procedures will ensure that workers are safe when working on trucks, equipment and machinery.

Next month’s safety tip will focus on pre-trip and post-trip inspections.

Will Flower is the Vice President of Corporate and Public Affairs at Winters Bros. Waste Systems (Long Island, NY). Will has 33 years of experience in the area of solid waste management and environmental protection. He has held operational and executive leadership positions at the Director’s Office of the Illinois Environmental Protection Agency, Waste Management, Inc., Republic Services, Inc. and Green Stream Recycling.