Lock-Out/Tag-Out: Beyond the Written Procedure

Blair Brewster (blair@electromark.com)
Allen Clapp (allen@clappresearch.com)

The lock-out and tag-out requirements of OSHA, the National Electrical Safety Code, NFPA Standard 70E and other national standards are based upon a two-part, simple premise.  First, LOCK-OUT- make sure that inappropriate levels of mechanical or electrical levels of mechanical or electrical energy cannot get to you before you work on mechanical or electrical devices and consider them benign: cut the energy off from its source and, if practical, lock it out.  For some items, this means locking a valve in the closed position.  For others, it means locking a switch in the off position.  Second, TAG-OUT – warn others who have access to the switches, valves, etc., (so that they will not inadvertently re-energize the devices) by placing appropriate temporary accident prevention tags at all sources of control.  These specific, strict rules and regulations have been developed over a century of good and bad behavior.  For example, consider the following accident.

In a power plant, several main and auxiliary steam lines were taken out of service to add equipment and reroute some lines.  One of the workers involved in installing a new piece of equipment turned the steam on to test the new equipment.  Unfortunately, he turned on the wrong line and four people were seriously burned (scalded).  Had a proper lockout/tag-out system been in place, each of the valves would have been properly identified with accident prevention tags meeting ANSI Z535.5 to assure that they were not turned back on until all crews had been cleared. 

Inadequate personal protective equipment, poor worker training, deficient equipment design and non-conformance with established safety work policies are all to often contributory factors in accidents like these.  But, there is a little question that safety locks, tags and signs work toward overriding such factors.  They can be your last line of defense.  A well-designed program of safety tags, locks and personalized training can help save lives.

Lock Out/Tag-Out Regulations

Lock-Out/Tag-Out , Or “LOTO” is the second most cited OSHA regulation violation.  The primary regulations are OSHA (S) 1910-147 Lock-Out/Tag Out, (S) 1910.269 for Electric Power Generation, Transmission and Distribution and (S) 1910.268 for Telecommunications.  These rules require that all energy sources be turned off and either locked-out while service or maintenance work is being performed.  By protecting the worker from accidental release of energy (electrical shock, mechanical action, heat, etc.), the rule is saving hundreds of lives.  These rules when coupled with an aggressive enforcement effort by OSHA, larger fines and, increasingly, criminal liability for the utility, mean that few companies can remain uniformed. 

In some ways, the work rules of the National Electrical Safety Code (NESC) and NFPA Std. 70E are more strict on locking and tagging than OSHA.  The NESC is adopted by law or regulation (or otherwise used by the courts and regulatory commissions) in every state.  Where locks are practical, tags are also required to identify those requesting the de-energization.  Tags are allowed without locking only in specific situations.  NFPA 70E is the standard from which the recent (S) 1910.333 and related regulations for electricians were taken; it has been the mainstay of manufacturing plant-operating routines since the early 1970’s.

LOTO Procedures & Continuing Failures

A Lock-Out/Tag-Out program has three elements: written procedures, employee training, and locks and/or tags.  By now, most utilities already have well-established written procedures with clear goals, specific procedural steps to take when working on an energized project, an inventory of potential hazards, group lock-out programs and descriptions of the manager’s auditing and control responsibilities.

Now, we must turn out attention to how written procedures can be implemented more effectively.  The outside plant environment is unique and, to be effective, a LOTO procedure must address the following trends in the outside plant environment.

Expanding Diversity of Workforce.  Utilities are struggling with higher turnover and greater numbers of entry-level trainees than ever before.  Many utilities respond by hiring outside contractors and this brings yet another level of complexity and uncertainty over lines of communication an authority.

Technological Acceleration.  Today’s outside plant is far more sophisticated than a decade ago.  For example, activation of a circuit may occur a control center that is miles away from the actual maintenance work.  The work may overlap several shifts and involve teams of electricians.  May of the current LOTO training programs built around the needs of a manufacturing environment and directed to simple nearby repair.  The “one-person-one-lock” scenario suitable for cleaning a simple machine is unworkable when you have dozens of control points.  Similarly, asking CATV employees, for example, to endure a training session on machine guarding is inappropriate.

Deregulation.  There is a greater pressure than ever to increase worker productivity – i.e., to get the linemen out of the classroom and back out on the job as fast as possible, while asking them to do more things faster.

Greater reliance on Tag-Out and Tag Durability.  In comparison to general industry, utilities are more likely to rely upon tags alone, since locks are not practical for many pieces of equipment.  And, unlike manufacturing environments, safety tags used in outside plant must be able to withstand rain, sunlight and wind.

A written program can only go so far.  Documenting that employees have all been subjected to the annual viewing of 20 minute LOTO videotape is not enough.  The limiting factors too often remain: (1) the execution of the training program and, (2) the quality of the tag itself.

Engage Employees to Make LOTO Training More Effective

The trick with any training program is getting workers to buy into the program.  Training cannot be too static. To be effective, support materials need continual change.  Many utilities now use their own video recorders to personalize the training.  Everyone has gone through orientation training, but how many times do you see colleagues working on your actual equipment?  Case histories that are relevant to your workplace are important.  Overcome apathy by discussing accidents that are relevant to your work environment.  Understand that it may take longer to follow the lock-out steps and to complete the tag than to make the actual repair.  Training has to emphasize that there are no shortcuts.

Finally, it’s helpful to understand how enforcement may be needed.  OSHA writes in the preamble to 1910.147, “…it is the fourth element, discipline, which appears to be the most critical to the cusses of these programs; the companies with effective tag-out programs apply various types of disciplinary action to both supervisors and employees who violate the tag-out procedures.”  A common line on Lock-Out tags is “You will be fired if you remove this tag without authorizations.”  Allowing violations to occur without penalties is inviting apathy and will provoke disrespect for your program.  Obviously, as in any case of work safety rules violations, the punishment should be commensurate with the level of hazard created.  In the case of serious, life threatening violations, it is better for a person to lose his job than to lose his arms and legs.

Use of Tags Vs. Locks

Although tags are generally used in conjunction with a lock, many utilities still use tags alone.  This approach works only when the company’s training and tracking program is well established and effective.  In writing the OSHA 1910.147 rules, the issue of tags versus locks was debated extensively.  Ultimately, OSHA decided that lock-out was the preferred and safer way to ensure that equipment remains de-energized.  Yet, they also recognized tags alone could be used when an energy isolating device was not capable of being locked-out.  Tags could also be used when the employer can “demonstrate that the tag-out program will provide a level of safety equivalent to that obtained by using a lock-out program” 1910.147 (a)(3)(c)(3).  This more flexible approach is fraught with pitfalls, if training, supervision and disciplinary programs do not match the level of seriousness of the hazards involved.

Many users acknowledge that tags are much easier and faster to use and hence more likely to be implemented than a program relying only on locks.  Indeed, there are occasions when using a lock is impractical and even more dangerous than a tag.  But, in developing your own program, you must honestly assess the effectiveness of your training, your written procedures, and capabilities of your work force, and then you must match them with the equipments being worked on and the work procedures involved.

Expect More From your Tag

Increasingly, companies are integrating their work order procedures with their lock-out tags.  Detailed instructions, information on control pints and even simple diagrams are being printed on the lock-out tags.  After all, a tag is usually only part of the work flow that starts with a work or maintenance request.  Many companies find it useful to attaché a stub from the actual tag to the work papers.  The sub is often used to indicate that the work has been completed and traces back to the individual performing the work.  Similarly, a paper carbon or NCR copy of the tag can provide this record.

Finally software programs can now be used to store detailed LOTO instructions, allowing users to print job-specific tags on laser and desktop thermal printers.  Highly readable laser-printed tags help reduce the problems on handwritten instructions, which are frequently difficult to read.  Often, the personnel writing tags are confronted with the need to make hundreds of tags.  Importantly, they are often performing this task under time pressures, such as a storm-related emergency.  These are situations during which, time and accuracy are of critical importance.  Laser printed tags help eliminate the human error.  Now that laser printers have dropped below the $500 threshold, they are a remarkable affordable solution.

Tags Should be Durable

The tags, themselves, can be upgraded from paper to plastic.  Investment in safeguarding equipment and training will be lost if the lock-out tag is not durable.  The tag is after all, the last line of defense against a potential lethal mistake.

Plastic tags resist oil, sunlight and water attack.  In contrast, paper tags mildew, rip, and become illegible in the rain.  Putting a paper tag into a plastic bag is even worse – the bag creates the greenhouse condition what can accelerate the tag’s deterioration.  Tags should have a ½” hole, so that they can accommodate the width of a lock shank.  OSHA”s guidelines define that the tag-out device shall have “an unlocking strength of no less than 50 pounds” 1019.147 (S symbol) (c) (5) (C) (2).  When used with a non-conductive plastic snap-grommet, these plastic tags exceed a 50 pound pull test.  On the other hand, tags need to be easily removable at the end of the work cycle.  Old, redundant tags con corrupt the integrity of your program.  Having a small slot or perforation allows personnel to rip it in half and remove it when the job is complete.

Attaching And Then Discarding A Tag

Historically, there have been many ways to attach a tag: cotton string, nylon cords, wire, ball chain and ties.  OSHA 1910.147 is quite clear though, “the employer is required to provide a means of tag-out device attachment having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie” OSHA 1910.1477 (c)(5)(ii)(C)(1).  When asked to rule on the suitability of using a cord, an OSHA officer writes, “Neighbor the cords nor the tag appear to be all environment-tolerant, that is, if wet, neither would hold up.”

Also, remember that tags should be temporary.  The integrity of your LOTO program depends on old tags being discarded or logged out.  Some users request a perforated section on the tag so that the tag stub can be sent back to the office to record a completed job.

A Tag Should Not Be a Wallflower

Above all, make the tag conspicuous.  Remember that the tag is guarding, someone’s life and must stand out.  Fluorescent colors or a striped border can be used to help the tag stand out.

Recent changes to the ANSI Z535.1-1997 standards that define Lock-Out tag designs.  The simple Danger header using the signal alert triangle is emphasized, instead of the traditional Danger design using the read and white oval shapes.

Make tags large enough to read.  A blocking tag must be filled out completely.  Leaving too little room to complete the information on the tag will frustrate the operator.  In a hurry, he will often sloppily complete the tag.  The next worker, who is then deciding which switch to energize may, for example be too vain to admit that he needs bifocals.  Obviously, this is a recipe for disaster.  Larger tags allow the Danger header to be sized big enough to meet the OSHA 1910.145 requirement, the signal word should be “readable at a distance of five feet or such great distance as warranted by the hazard.”

Lastly, it is important not to forget the back of the tad.  The best tags give instructions on the back of the tag on how to follow your LOTO procedures.

Warnings on Tags

The tag is often protecting someone’s life.  Make sure that your message is clear and direct.  The primary message of the tag should give the necessary action to take (for example, “ Do not Operate”).  Make this primary message large and bold.  Other common messages are:  Do Not Connect, Do Not Energize, Do not Open, Do Not Reclose, Do Not Start, Keep your Hands Off, Hold Tag, Lock Out and My Life Is On the Line.

The use of symbols is also encouraged by the new ANSI standards.  An appropriate symbol conveys the danger quickly and powerfully, even to workers who do not read English well or cannot read small print.

Many plants even add a photograph to the tag.  Some use digital cameras to take a picture and then instantly translate it to an electronic form.  Others scan a regular photograph.  With such a record, you can translate your personnel photos for inclusion in the LOTO procedures and the tags.  A personalized lock-out tag not only helps you find someone, especially when you have many contractors on a project, but helps convey the singular immediacy of the danger.

Conclusion

Many LOTO programs have not fulfilled their promise, due to lack of follow-through by supervisors and trainers.  Employees too often like bystanders to an arbitrary management procedure, because the procedures and training they receive do not adequately reflect their needs and work procedures.  Training programs tailored to your work environment will help change these attitudes.  Durable, easy to fill out and understandable tags that are integrated with your procedures reinforce the importance of your LOTO program and empower the employee.  Both initiatives signal a fundamental respect for the employee’s safety and that means fewer accidents.

Regulations   

OSHA 1910.147, Control of Hazardous Energy Source (Lock-Out/Tag-Out), 1989

OSHA 1910.269, Electric Power Generation, Transmission and Distribution; Electrical Protective Equipment, 1994

OSHA 1910.145, Specifications for Accident Prevention Signs and Tags, 1971.

National Electrical Safety Code (ANSI C2), Part 4: Work Rules.

ANSI Z244.1, For Personnel Protection- Lockout/Tagout of Energy Sources- Minimum Safety Requirements, 1992.

ANSI Z535.5, American National Standards. Accident Prevention Tags (for Temporary Hazards), 1997.

NFPA Std. 70E Standard for Electrical Safety Requirements for Employee Workplaces.

Authors

Blair Brewster, President Electromark, a manufacturer of safety signs, labels and lock-out tags; member of ANSI Z35 main committee, subcommittee 2 on Environmental and Facility Safety Signs and Chair of ANSI Z535 Subcommittee 5 on Safety Tags and Barricade Tapes.  blair@electromark.com

Allen Clapp, President of Clapp Research Associates, P.C., Consulting Engineers; member and Past Chair National Electrical Safety Code Committee; member ANSI Z535 main committee and Chair ANSI Z535.2 Subcommittee on Environmental Facility Safety Signs.  allen@clappresearch.com .