Oklahoma State University Program for Control of Hazardous Energy
Issue Date: 03-14-12
Expiration Date: 03-14-13
in accordance with the OSHA Control of Hazardous Energy (Lockout/Tagout) Standard, 29 CFR 1910.147 and
Electrical, 29 CFR 1910.133
To ensure the safety of employees by establishing appropriate lockout/tagout (LOTO) procedures for equipment that is capable of storing hazardous energy, including but not limited to: electrical, chemical, mechanical, hydraulic, pneumatic, and thermal. Also to ensure compliance with the requirements of Federal 29 CFR 1910.147, Control of Hazardous Energies and Federal 29 CFR 1910.133, Electrical.
Each campus shall implement a LOTO program that meets the minimum requirements of this document and any applicable Federal, State or Local laws.
This program will apply to University employees during servicing and/or maintenance of equipment or machines and at other tiems when LOTO of energy is required to ensure the safety of those working on or near hazardous energies, if a release of this energy could cause injury to the employee. LOTO is required when the work requires any faculty, staff member or student to place any part of their body into an area where a danger zone exists.
For the purpose of this program, the term "employee" is intended to mean faculty, staff or student.
NOTE: Contractors are required to follow all Federal, State and Local laws and the expectations of the University. Contractors are required to meet the intent of this guideline but shall train and certify their own employees. OSU and the contractor are required to inform each other of their respective programs.
Assessments shall be performed on each tool/equipment set to identify
potential hazardous energies and to document the Energy Control Procedures
(ECP). The energy control procedures shall be written in preventive maintenance,
modification or other relevant procedures (See Appendix
8.2 -- Energy Control Procedure Checklist).
Equipment-specific Energy Control Procedures shall be written for each
equipment type that covers:
- Specific procedural steps for shutting down, isolating, blocking and
securing machines or equipment to control hazardous energies.
- Specific procedural steps for the placement, removal, and transfer of locks and tags and the responsibility for placing them.
- Specific requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO and other energy control measures.
- Energy Control Procedures need not document the required procedure for a particular machine or equipment, when all of the following elements exist:
- The machine or equipment has no potential for stored or residual energy, or re-accumulation of stored energy, after shut down that could endanger employees.
- The machine or equipment has a single energy source, which can be readily identified and isolated.
- The isolation and locking out of the energy source will completely de-energize and deactivate the machine or equipment.
- The lockout device is under the exclusive control of the authorized "employee" performing the servicing or maintenance.
- The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
- A single lockout device will achieve a locked-out condition.
- The servicing or maintenance does not create hazards for other "employees."
- OSU, in utilizing this ECP exception, has had no accidents involving the unexpected activation or re-energization of the machine or equipment during service or maintenance.
Each Energy Control Procedure (ECP) must be reviewed annually.
If a change to an ECP happens, the equipment owner must:
- Identify the change and update the ECP.
- Define who will be impacted/affected by the change.
Communicate through any effective means to all Authorized Employees. Examples include the following: Team/Staff Meeting, 1:1's with individuals.
Locks and tags used for Control of Hazardous Energy must be standardized at each campus and must not be used for any purpose other than the control of hazardous energy.
- Locks used for LOTO must be RED in color.
- Tags used for LOTO must contain the language: "DANGER--DO NOT OPERATE."
Tags used for other applications shall not duplicate LOTO tags in color or verbiage.
Transfer of LOTO between the outgoing and oncoming personnel shall require:
- Personnel to meet at the point of lockout.
Oncoming employee shall apply LOTO devices prior to outgoing employee removing their device.
No individual shall interfere with another person's LOTO or try to start any equipment/tools under someone else's LOTO.
To remove another person's LOTO device, removal protocol requires that both a Supervisor, or designated representative, and an Authorized Employee complete the "Abandoned Lock Removal Procedure." (See Appendix
8.3 -- Control of Hazardous Energies Abandoned Lock Removal Form.)
- Need for lock and tag removal is identified to person's supervisor.
- Attempts to contact the person who placed the lock are documented on the Abandoned Lock Removal Form.
- An evaluation of the entire system must be made to ensure that an injury cannot occur before the lock is removed. (Names are documented on the form.)
If contact cannot be made with the employee who placed the lock, the employee AND their supervisor must be made aware of the removal and state of the system before beginning his/her next workday.
Periodic inspections of Authorized Employees shall be conducted annually to ensure compliance with LOTO operation requirements. The inspections shall include (See Appendix
8.4 -- Periodic Inspection Checklist for Control of Hazardous Energies):
- A review, between the inspector and each "authorized employee," of that employee's responsibilities under the energy control procedure being inspected. The inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected.
- The inspection shall document:
- The identity of the machine or equipment on which the Energy Control Procedure was being utilized.
- The date of the inspection.
- The names and job title of employees who were included in the inspection.
- the person who performed the inspection.
- The inspector needs to:
Observe a representative number of such employees while implementing the procedure.
Each employee shall use locks for which only they possess keys.
Each person whose work exposes them to a potential danger zone,
regardless of length of time, shall apply their own lock and tag to the
energy-isolating device before entering that zone.
If using a lock box, the following steps shall be adhered to:
- Tool owner, project manager, or person supervising the lockout shall:
- Apply lock and tag to each hazardous energy control point.
- Place the key(s) to the locks in a lock box.
- Affix his or her own lock and tag to the lock box.
- The authorized employee(s) working on the locked out systems shall:
- Affix their lock and tag to the lock box when beginning work.
- Verify that the system(s) they are working on are de-energized and verify the lock is on the correct isolation device.
- Remove their lock and tag when they have completed their work.
Stop work and inform the person supervising the task of start and stop times and any issues found.
The lockout of energy must be a true isolation, without possible override.
NOTE: Unacceptable means for controlling or isolating hazardous energies include the use of interlocks, push buttons (EMO's), selector switches, software controls, and control circuit devices.
Normal Production Operations (NPO): An exception when LOTO is not required for activities that must be accomplished WHILE THE MACHINE OR EQUIPMENT IS UTILIZED TO PERFORM ITS INTENDED PRODUCTION FUNCTION. LOTO is not required in this instance if it can be demonstrated that alternative means enable employees to service the machine without being exposed to an unexpected activation of the equipment or release of stored energy. An NPO exception must be documented, reviewed by EHS, and ratified by the NPO/Alternative Methods Review Board before the alternative procedure not requiring LOTO can be implemented. The NPO exception cannot be utilized for electrical hazardous energies.
- Normal Production LOTO Exception Process:
- The alternative procedure shall be reviewed by the requestor and an EHS representative.
- If applicable, the alternative procedure shall be documented within the NPO exception template/form.
- The alternative procedure shall be presented by the requestor to the NPO/Alternative Methods Review Board.
- The NPO Review Board will either accept or reject the alternative procedure as an approved NPO exception.
- If approved, the alternative procedure will be implemented and LOTO for that specific activity WILL NOT be required.
If rejected, the alternative procedure will not be implemented and LOTO WILL be required before work can be completed.
CoHE Alternative Method: An Exception when LOTO is not requried or is impracticable on a machine or piece of equipment DURING MAINTENANCE ACTIVITIES. This deviation from LOTO procedures must be reviewed and approved. As an example, LOTO may not be required in the instance if it can be demonstrated that an alternative means enable employees to service the machine without being exposed to an unexpected activation of the equipment or release of stored energy. Like a NPO exception, a CoHE Alternative Method must be documented (Appendix 8.5B), reviewed by Site EHS, and ratified by the NPO/Alternative Method Review Board before the alternative procedure not requiring LOTO can be implemented.
- CoHe Alternative Method Process:
- The specific alternative procedure shall be created by engineering and a designated Site EHS representative and must include:
- Determine if task is routine and repetitive.
- Determine why power is required.
- Establish why lockout is impracticable.
- Are employees exposed to hazards?
- Are guards being removed?
- Are interlocks bypassed?
- Perform a Risk Assessment, which includes:
The alternative procedure shall be documented within the CoHE Alternative Method template/form.
The Alternative Method shall be presented to the NPO/Alternative Method Review Board.
The NPO/Alternative method Review Board will either accept or reject the alternative procedure as an approved CoHE exception.
If approved, the Alternative Methods will be implemented and LOTO for the specific activity WILL NOT be required.
- Identification of the task's related hazards
- Qualitative estimation of exposure and severity to determine the level of risk
- Assessment and evaluation of the risk
- Identification of control actions selected as the best protective alternative
- Verification of effectiveness of the selected alternative
- Documentation of the Risk Assessment Process
If rejected, the Alternative Method will not be implemented and LOTO WILL be required before work can be completed.
When an employee is working in an area with potential exposure to electrical energy, they are required to use LOTO. If there is a compelling reason to work on the system energized, refer to the Energized Electrical Work (EEW) program for additional requirements.
Dual valve isolation is required for pressurized (>15psi) Hazardous Materials (HM's). This requires that one valve be locked/tagged out and a second valve to be closed between the source of hazard and the authorized employee. NOTE For a valve to be considered locked/tagged out, you must use a lockable valve, a locking valve cover or a valve cover that prevents the pneumatic line from being reconnected during lockout.
Lockout/Tagout (LOTO) is not required for equipment that has only one electrical energy source and is capable of being unplugged, provided that the plug is under the direct control and immediate supervision of the employee performing the work for the duration of the task. The plug is under the exclusive control of the employee if it is physically in the possession of the employee, or in arms reach and in line of sight of the employee. NOTE: This does NOT apply when more than one employee is working on the tool/system.
Use both locks and tags unless the system will not physically accept a lock. If a particular piece of equipment does not have a device allowing it to be physically locked out, then only a tag will be used.
- Where a tag cannot be affixed directly to the energy isolating device, the tag shall be located as close as safely possible to the device, in a position that will be immediately obvious to anyone attempting to operate the device.
- Additional means to ensure equivalent to safety lockout are required
as necessary. (An example would be to remove a valve handle or unland
Notify your safety representative within 24 hours of any equipment that will not accept a lock so that it can be modified, if possible.
Custodial Lockout and Tagout
A lockout procedure is intended to provide protection to systems, equipment, and/or machinery -- NOT EMPLOYEES. If an employee is required to place any part of his/her body into an area where a danger zone exists, he/she must utilize LOTO procedure for that system, equipment or machinery.
Custodial LOTO is used in the following circumstances:
- System, equipment, or machine is secured to prevent its operation when a component is missing.
- System, equipment, or machine is secured to prevent its operation when demolition is scheduled.
- Installation is complete or in progress, but the system, equipment or machine has not been qualified and, therefore, not released for use.
To secure valves/controls that are set in a prescribed position to maintain system integrity.
- Obtain the LOTO devices and tags.
- Affected employees shall be notified by the employer or authorized employee of the application and removal of the lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment.
- Read and understand the equipment-specific energy control procedures.
- Locate each energy control point on the equipment.
- Power down the equipment.
Isolate the equipment from all hazardous energies sources
- Apply the LOTO device so that it locks the energy-isolating device in the SAFE position. Affix the tag directly to each lock.
- Dissipate, drain, or safely release any stored or residual energy in the system after Lockout.
- Verify that all sources of hazardous energies have been isolated. This should be done by measuring the energy with a meter or gauge and by trying to start the equipment. Prior to using the meter/gauge, ensure it is functioning properly. Be sure to return all switches to the SAFE position after testing.
Note: For electrical, a qualified person shall use test equipment to test the circuit elements and electrical parts of the equipment to which employees will be exposed and shall verify that the circuit elements and equipment parts are de-energized. The test shall also determine if any energized condition exists as a result of inadvertently induced voltage or unrelated voltage backfeed even though specific parts of the circuit have been de-energized and presumed to be safe. If the circuit to be tested is over 600 volts, nominal, the test equipment shall be checked for proper operation immediately after the test.
- Perform a Three-Point-Check to ensure your Volt-Meter is working properly:
- Set Voltage Scale to appropriate voltage and test on a known-voltage source.
- Check Danger Zone voltage with Meter -- Confirm to be Zero.
Check meter with a known voltage again to confirm proper operation of the meter.
LOTO Preparation for Re-Energization
- Inspect the work area to ensure that all nonessential items, tools, etc., have been removed from the danger zone.
- Check that all the guarding and safety controls have been properly replaced.
Notify "Affected Employees" and ensure that all personnel are in a safe location before re-energization.
LOTO Lock and Tag Removal
- Remove the LOTO locks and tags.
Re-energize the equipment/system according to start-up procedures.
LOTO Lock and Tag Temporary Removal
- Clear equipment of tools and materials.
- Remove "Affected Employees" from equipment area.
- Remove LOTO devices.
- Energize and proceed with testing or positioning.
De-energize all systems and reapply energy control measures in accordance with procedures.
Note: In situations in which LOTO devices must be temporarily removed from the energy isoalting device and the equipment energized to test or position the equipment, follow the steps above.
LOTO Equipment Used
- Do not proceed with the task unless the correct LOTO equipment is available.
- Lockout and Tagout devices have been standardized at each campus and must not be utilized for other purposes.
- Durable and uniquely identified locks, with a single key, shall be available for all authorized employees. The key will remain at all times with the individual who places the lock. Locks (as described above) can be available for use by a number of people and stored in a central location. Persons can take locks to use for LOTO as long as they control the key for the duration of that LOTO. Locks and keys can be returned to a central location afterwards.
- These locks are not to be used for any other purpose (e.g., locking tool, custodial locks, boxes, lockers, chaining equipment, etc.).
- LOTO Tags:
- Durable tags, which will not deteriorate under work conditions, shall be used whenever a lock is placed.
- The tags must contain, at a minimum, the following information:
- Employee's name
- Warning against hazardous conditions if the machine or equipment is energized.
Wires, tie wraps, or cords shall be used for securing the tags to the energy control point and must be able to withstand 50 lbs. of force.
- Ensure that only authorized employees, who are qualified and trained, apply and remove locks and tags. Ensure that employees who are found to have insufficient skills or understanding of LOTO requirements do not perform LOTO and are retrained.
- Designate a program owner for the Control of Hazardous Energies Program.
- Implement, manage, and audit personnel for conformance with the Control of Hazardous Energies Program.
- Ensure that all safety equipment is stocked, stored, and maintained in a state of readiness and is available for employee use.
Ensure that any deficiencies or deviations found in the working procedures are corrected.
- Shall perform LOTO activities that are in conformance with OSU's requirements.
- Retain control of the equipment, system or machinery while a LOTO is in progress and work only under their own lock and tag.
- Maintain LOTO hardware and tags in good condition.
Complete all training required to be authorized to work with specific equipment, tool(s) or machinery.
- Be aware and knowledgeable of the intent and requirements of the Control of Hazardous Energies Program.
- Complete required training.
Be knowledgeable of energies associated with the equipment.
- Ensure that a site and/or group implementation program is documented, implemented, and complies with the minimum requirements of this document.
- Works with management to ensure compliance with this document and all other local requirements.
- Remains current with campus-specific requirements.
- Ensures a system is in place to properly train "Affected Employees."
- Audit campus program annually to ensure the content of this document and employee practices are current with OSHA regulations and maintain audit documentation.
- Audit campus contractors' training programs and practices for compliance.
Communicates the expectations of this guideline to contractors as appropriate.
- Must initially attend and complete OSU's Control of Hazardous Energies Training course.
- Will receive equipment-specific training and certification, as applicable.
- Authorized employees must be retrained by completing the Control of
Hazardous Energy course if:
Authorized employees shall be coached/receive hands-on training if:
- The employee uses blatant disregard of CoHE procedures during periodic inspection.
- There is a change in job assignment, a change in machine, equipment
or processes that present a new hazard, or there is a change in the
energy control procedure.
- The periodic inspection reveals, or whenever there is reason to believe, there are inadequacies in the employee's knowledge or use of the energy control procedure.
If employee is observed and found to be proficient during the periodic inspection, they are not required to attend the Control of Hazardous Energy course. If employee is not observed during the periodic inspections, they shall attend the Control of Hazardous Energy course to ensure proficiency.
- Affected employees working in areas where LOTO may be used must be trained in the purpose and use of the Control of Hazardous Energies.
- Affected employees must be retrained if a significant OSHA regulation or OSU LOTO guideline change has been made (i.e., new requirement, change in locks or tags).
Affected employee retraining can be delivered through awareness campaigns.
8.1 -- Definitions
8.2 -- Energy Control Procedure Template
8.3 -- Control of Hazardous Energies Abandoned Lock Removal Form
8.4 -- Periodic Inspection Checklist for Control of Hazardous Energies
8.5A -- Normal Production Operation (NPO) Process
8.5B -- Normal Production Operation Evaluation Form
8.6A -- CoHE Alternative Method Process
8.6B -- CoHE Alternative Method Evaluation Process Form
Any person (faculty, staff, employee, or student) who operates or maintains equipment that may be locked/tagged out. Also, any person who works in an area where equipment is being serviced.
An exception when LOTO is not required or is impracticable on a machine or piece of equipment DURING MAINTENANCE ACTIVITIES. This deviation from LOTO procedures must be reviewed and approved. As an example, LOTO may not be required in the instance if it can be demonstrated that alternative means enable employees to service the machine without being exposed to an unexpected activation of the equipment or release of stored energy. Like a NPO exception, a CoHE Alternative Method must be documented, reviewed by Site EHS, and ratified by the NPO/Alternative Method Review Board before the alternative procedure not requiring LOTO can be implemented.
Any person (faculty, staff, employee, or student) who locks/tags out machines or equipment in order to perform servicing or maintenance. Authorized Persons must initially attend and complete OSU's Control of Hazardous Energies training course and will receive equipment-specific training and certifications, as applicable.
An authorized employee who has been trained and has demonstrated proficiency to perform servicing and maintenance on the machine or equipment to be inspected. They must also be given the authority and responsibility to perform the inspections by OSU management.
Capable of Being Locked Out:
An energy-isolating device is capable of being locked out if it has a hasp or other means of attachment to which, or through which, a lock can be affixed or it has a locking mechanism built into it. Other energy-isolating devices are capable of being locked out, if lockout can be achieved without the need to dismantle, rebuild, or replace the energy-isolating device or permanently alter its energy control capability.
A lockout procedure intended to provide protection to systems, equipment, and/or machinery--NOT EMPLOYEES!!!! If an employee is required to place any part of his/her body into an area where a danger zone exists, he/she must utilize LOTO procedures for that system, equipment, and/or machinery.
The area or workspace where, if the hazardous energy was inadvertently released, the energy could potentially cause injury.
Examples of danger zones include:
Electrical work -- areas where a person could receive an electric shock if the electrical energy inadvertently became re-energized.
Hazardous chemical line of work -- areas where a person could be exposed to the hazardous liquids, vapors, gases, or mists if the line is inadvertently opened and chemical leaks out.
Mechanical work areas with the potential for crushing, pinching, cutting, snagging, or puncturing.
Parts are de-energized when the working potential is completely depleted, discharged, or has returned to a non-hazardous state.
Energy: (Includes, but is not limited to)
Energy Control Point:
The single point at which hazardous energy flow can be effectively and positively blocked so that it can no longer cause injury or loss of resources. There may be more than one Energy Control Point on a tool.
Mechanical motion -- moving links, bars, chains, belts, sliders, wheels, shafts, gates, rams, blades, pistons, etc.
Potential or stored energy -- pressure (above ambient pressure) vacuum (below ambient pressure), gravity, springs, batteries, or capacitors.
Electrical energy -- potentially hazardous voltage (>50 volts), hazardous static electrical potentials, or may be stored in a capacitor.
Radio frequency energy
Ultraviolet light sources, x-ray sources, or high-level magnetic fields.
thermal energy -- very hot or very cold temperatures (e.g., <32F/0 C or >140F/60 C).
Chemical energy -- reactive, corrosive, flammable, radioactive, poisons, oxidizer materials, or other Hazardous Production Materials.
Energy Control Procedure:
Specific Steps for shutting down and isolating hazardous energies.
Procedures for applying, removing, and transferring lockout/tagout devices. Requirement for testing a machine/piece of equipment to determine and verify the effectiveness of lockout/tagout procedures.
A mechanical device that physically prevents the transmission or release of energy. Examples of energy-isolating devices are a manually operated circuit breaker, a disconnect switch, a valve, a mechanical blocking device, or any similar device used to block or isolate hazardous energy.
Connected to an energy source or containing residual or stored energy.
A LOTO that cannot be performed due to equipment, engineering or work environment difficulties that would increase the potential hazard to employees who perform the LOTO or equipment or process design that does not allow for isolation of hazardous energy. This does not include convenience or production impact.
≥5 psi (HPMS)
≥psi other liquids/gases
The placement of a physical restraint energy-isolating device, which ensures that the equipment cannot be operated or release a hazardous energy.
Lockout Device: A device that utilizes a positive means such as a lock to hold the energy-isolating device in the safe position and prevent the energization of a machine or equipment. Included are blank flanges and bolt slip blinds. The Federal OSHA regulation specifies that the lockout device must be substantial so that it cannot be easily removed or defeated without excessive force or unusual techniques. (e.g. bolt cutters, hacksaw).
Normal Production Operation (NPO):
An exception when LOTO is not required for activities that must be accomplished while the machine or equipment is utilized to perform its intended production function. LOTO is not required in this instance if it can be demonstrated that alternative means enable employees to service the machine without being exposed to unexpected activation of the equipment or release of stored energy. An NPO must be documented, reviewed by Site EHS, and ratified by the NPO Review Board before the alternative procedure not requiring LOTO can be implemented. The NPO exception cannot be utilized for electrical hazardous energies.
Lockout: A device that attaches to a hazardous energy control point that provides the lockout function of an actual locking device, yet enables multiple users to attach their individual locks. Typical devices have the capability to attach 6 or more additional locks.
Lock Box: An approved box or container into which a key or set of keys could be placed. Lock boxes shall be substantial enough to prevent entry without the use of excessive force or unusual techniques; such as with the use of bolt cutter or other metal cutting tools. Lock boxes must be capable of being locked out with a hasp or other means of attachment to which, or through which, a lock and/or lockout scissors can be affixed.
Servicing and Maintenance:
Any scheduled or unscheduled activity that, when complete, will enable the machine to perform its intended function; such as constructing, installing, setting up, adjusting, inspecting, demobilizing, modifying, and maintaining and/or servicing machines or equipment.
The placement of a warning/identification tag on an energy-isolating device to indicate that the equipment must not be operated. Identifies the person who applied the lock/tag. (Check training)
Must include Employee's Name, warning against hazardous condition if the machine or equipment is energized and a legend such as the following: "Do Not Start, Do Not Open, Do Not Close, Do Not Energize, Do Not Operate Wires, tie wraps, or cords shall be used for securing the tags to the energy control point and must be able to withstand 50 lbs. of force."
- Model No.:
- ID No.:
Task(s) to be Performed:
Name of Person Performing Assessment:
A. ENERGY FORM(S): (Check all that apply)
Chemical/Explosion, pressure, extreme heat, fire, corrosive, reactive, oxidizer, toxic
- a. Low Voltage (50-600V)
- b. High Voltage (>600V)
Mechanical - capable of crushing, pinching, cutting, snagging, striking.
Thermal - High Temperature, Surface Temperature, Hot Liquids, steam
Thermal - Cryogenic - contact with super cold surface or with dryogenic liquid.
- a. Pneumatic
- b. Hydraulic
Stored - Flywheels, springs, differences in elevation, elevated parts that could drop, capacitors, batteries.
- a. Ultraviolet
- b. Infrared
- c. Rf/Microwave
- d. Laser
- e. Magnetic Fields
B. BASIC PROCEDURES
- Notify all affected personnel of LOTO.
- Turn off power at disconnect points listed in C.1.
- LOTO each energy control point listed in C.1.
- Dissipate/disconnect any stored energy (if applicable).
- Block any mechanical parts, remove any mechanical links. Lock blocking
in place. (If applicable) (NOTE: Two physical blocks required to secure
any gas/liquid line)
- Verify personnel are clear of hazards.
- Verify no hazardous energy remains. Use circuit tester/meter if electrical
energy is involved. See C.4.
- Attempt to re-start machinery or re-energize equipment through normal
means. NOTE: Return switch back to OFF position.
- Perform required work.
- Procedure to Return Device to Operation:
- Verify Danger Zone is clear of equilpment, workers, tools, and test equipment.
- Unlock and remove any blocking devices; remove linkages.
- Reposition any safety devices.
- Warn workers to stay clear of area.
- Remove all locks and tags from energy control points.
- Verify area is clear of personnel.
- Re-start/re-energize the equipment.
- Notify all affected personnel and other persons that the lockout has
C. SPECIFIC PROCEDURES
- Hazardous Energy (Specify form & Values, including
names of chemicals) (list)
- C.1 Specific Lockout Locations (list)
- C.2 Dissipate Stored Energy At these Points (list)
- C.3 Block These Parts/Remove Linkages (list)
- C.4 Verify Residual Energy By These Methods (list)
If this procedure lasts beyond one work shift, the relief crew will apply their locks and tags before the departing shift removes their locks and tags. If this does not happen, the new crew must start with a new ECP.
This form is to be used anytime a Lockout/Tagout (LOTO) device
is to be removed by someone other than the person who placed the
LOTO device. The person removing the LOTO device must be directed
to do so by management. Failure to follow and document the appropriate
steps to remove a LOTO device can result in disciplinary action up
to and including termination.
- Name of LOTO device owner whose lock/tag is to be removed:
- LOTO device owner's extension/pager
- LOTO device owner's First-Line Supervisor or On-Shift Supervisor:
- Document attempt to contact LOTO device owner.
Reason for removing lock (e.g. LOTO owner called in sick, LOTO device owner forgot to remove lock before leaving site, etc.)
Evaluate the entire affected system to ensure employee's safety before LOTO device is removed.
- Method of attempted contact
Document LOTO device(s) removal by:
Removed by: (print) _______
Observed by: (print) _______
Supervisor's (or designee) Signature: ________, Date/Time: _______
Authorized Employee's Signature: _______, Date/Time: _______
EHS Representative informed (i.e., email or phone call/message)
that a LOTO device has been removed within 24 hours of removal.
EHS Representative Notified: ___________, Date: _____, Time: _____
Authorized Employee Observed: __________
Equipment: __________, Date: ________
Procedure: __________, Location: __________
Periodic Inspector: ____________
Hazardous Energies Involved:
- Electrical: Voltage: ________
- Pressure (pneumatic/hydraulic)
- Thermal: High Temp: _____, Cryogenics: _____
- Ionizing Radiation
- Non-Ionizing Radiation
To Lock Out the Equipment
- Notified Affected Employees of LOTO (Yes) (No)
- Identified all power disconnect points (list specific points) (Yes) (No)
- Stopped or powered down equipment (Yes) (No)
- Isolated equipment from all hazardous energies sources.
(List number of isolation points). (Yes) (No)
- Applied LOTO device(s) energy isolating device locked in OFF position. (Yes) (No)
- Attached LOTO Tag to Lock (Yes) (No)
- Dissipated, drained, or safely released stored or residual energy. (Yes) (No)
- Blocked mechanical parts or removed mechanical links
- Attempted to re-start machinery or re-energize equipment through normal means.
Returned switch to OFF position. (Yes) (No)
- Verified no hazardous energies present or isolated.
Identify test equipment/meters. (Yes) (No)
To Re-Energize the Equipment
- Inspected work zone to ensure it is clear of equipment, workers,
tools and test equipment. (Yes) (No)
- Unlocked and removed any blocking devices
and replaced mechanical linkages. (Yes) (No)
- Repositioned safety valve(s) left open to
prevent re-buildup of pressure. (Yes) (No)
- Checked all guarding and safety controls properly replaced. (Yes) (No)
- Warned workers to stay clear of area. (Yes) (No)
- Removed all locks and tags from energy control points. (Yes) (No)
- Verified area clear of personnel. (Yes) (No)
- Restarted/re-energized equipment. (Yes) (No)
- Notified Affected Employees LOTO completed. (Yes) (No)
The results of this inspection were discussed between the Authorized Employee being Observed and the Inspector.
Signature of Authorized Employee Observed: ______________
Normal Production Operation Lockout/Tagout Exceptions: The CoHE standard was developed to protect workers from potential hazards associated with performing servicing and maintenance activities. (Servicing and maintenance activities are defined to include constructing, installing, setting up, adjusting, inspecting, maintaining, repairing, and servicing.) OSHA has a special exception for activities that must be accomplished while the machine or equipment is in a production mode, which is referred to as a Normal Production Operation (NPO) Lockout/Tagout exception. OSU’s position is that use of this exception requires an alternate means of protection to control the hazardous energies. CoHE must be complied with for any servicing or maintenance activities in a danger zone where unexpected release of hazardous energies could cause injury unless a NPO Lockout/Tagout exception has been approved by the NPO review board. It is important to note that the NPO LOTO exception cannot be utilized for Electrical Hazardous Energies.
Q. What if I feel that the work/service to the tool can only be done while the tool is operating and cannot be performed if the tool is locked out in compliance with OSU's CoHE procedure?
A. Refer to the appropriate source to see if a NPO exception has already been approved for the tool and task in question. If one has been approved, work can proceed in accordance with the approved NPO. If no NPO has been approved, work must be done in compliance with CoHE requirements or a NPO exception must be obtained.
Q. How do I obtain a NPO exception?
A. Answer the following question and proceed accordingly:
Are there tasks being performed (pm, production operations, troubleshooting, inspecting, clearing jams, etc.) where the employee is being protected from hazardous energies with alternate methods other than lockout/tagout (i.e., software or mechanical interlocks, or light curtains etc.)?
The Tool owner should contact the safety engineer and complete a NPO Evaluation Form (Appendix 8.5B). The Safety Engineer will submit the completed NPO Evaluation Form to the appropriate NPO Review Board and request a review meeting by contacting the NPO Review Board Chair.
Lockout/Tagout is used and the NPO process does not apply.
Date: _________, Originator/Site: __________
Safety Engineer: ____________, Task Title: ____________
Equipment: __________, Tool: __________, System: __________
- Provide explanation as to why this task needs to be performed while tool is energized.
- Identify separately each type of hazardous energy, current method of control, and type of injury that could result if controls failed and the machine became operational:
Examples: Engineering Controls: Equipment modification, redesign, hard interlocks
List the specific steps to perform the task.
- Type of energy:
- Engineering Controls:
- Administrative Controls:
- Potential Injury:
- Type of energy:
- Engineering Controls:
- Administrative Controls:
- Potential Injury:
Focus on steps where hazardous energy controls are removed/bypassed or employee places body part in danger zone.
What is the frequency of task (i.e., per hour, per shift, per week, etc.)?
Has the worker been trained for this specific task? (Yes) (No)
Do other sites with the same tool perform LOTO during this task? (Yes) (No)
If yes, why is this tool being evaluated differently?
Have there been any previous incidents or injuries within OSU relating to this tool and the task being evaluated? (Yes) (No)
If yes, briefly explain (i.d., behavioral/equipment-related).
Does supplier maintenance manual require LOTO for this particular task? (Yes) (No)
CoHE Alternative Method: An exception when LOTO is not required or impracticable on a machine or piece of equipment DURING MAINTENANCE ACTIVITIES. LOTO may not be required in the instance if it can be demonstrated that alternative means enable employees to service the machine without being exposed to an unexpected activation of the equipment's release of stored energy.
Impracticable means that LOTO cannot be performed due to equipment, engineering or work environment difficulties that would increase the potential hazard to employees who perform the LOTO. This does not include convenience or production impact.
Q. How do I obtain a CoHE Alternative Method?
A. Answer the following question and proceed accordingly:
Discuss situation with University EHS to determine if the situation meets the criteria. If Yes, complete the proper form (Appendix 8.6B) and submit through EHS department to the NPO/Alternative Method Board that is appropriate for your situation.
Date: _________, Originator/Site: __________
Safety Engineer: ____________, Task Title: ____________
Equipment: __________, Tool: __________, System: __________, Platform: __________
- Is This task routine and repetitive? (Yes) (No)
- Why is the hazardous energy required to be "on" to perform this task?
- Why is the LOTO impracticable?
- Are employees exposed to hazards? (Yes) (No)
If YES, please explain what type.
- Are guards being removed? (Yes) (No)
- Are interlocks bypassed? (Yes) (No)
- Describe task:
- Identify all task-related hazards:
- Provide qualitative estimation of exposure and severity to determine level of risk:
- Provide assessment and evaluation of risk:
- Identify potential control actions considered to reduce the rask of each hazard:
- Identify control actions selected as the best protective alternative:
- Provide verification of effectiveness of the selected alternative:
End of Manual