Unfolding Lockout/Tagout (LOTO)!

An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.


DANGER - This energy source has been locked out - proper machine safety methods save life and limb, says the Control Engineering Machine Safety blog.Hazardous energy must be controlled when employees are servicing and maintaining machines in order to prevent serious physical harm or even death. To address this hazardous issue OSHA created The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147. As a reference source, OSHA used ANSI Z244.1-1982 in the creation of this regulation and continues to reference Z244 on their web site. Since LOTO was created OSHA has issued several letters and Circulars of interpretations for application of the requirements and ANSI has also updated Z244.1 to the current 2003 issue. With all this said, why do you suppose levels of uncertainty seem to exist regarding “my requirements” vs the level of requirements simply laid out by OSHA, ANSI, and other consensus standards.

J.B. Titus, machine safety bloggerDo you think Richard E. Fairfax, Director, OSHA Directorate of Enforcement Programs, in his interpretation letter on this subject confused anyone when he brought the term “de minimis into the mix? Has anyone come across an OSHA regulation that describes the full legal interpretation of “de minimis”? How does industry properly and accountably apply this term to employee training and their company “Safety Policy” manual?


After further research I found an OSHA Fact Sheet. This two page summary on LOTO is a great summary. However, in my opinion it begins to get a little fuzzy in the section, What do employees need to know? See below:

“The training must cover at least three areas: aspects of the employer’s energy control program; elements of the energy control procedure relevant to the employee’s duties or assignment; and the various requirements of the OSHA standards related to lockout/tagout.”

Oh oh, this now begins to sound like a subject I’ve blogged on before titled, “Machine Safety and Your Safety Culture”. In my opinion, the last point in OSHA’s advice above unmistakably is about the LOTO regulation, 1910.147. Yet, the first two points sound more to me like parts of a company’s overall safety culture peppered with a little energy management to the chef’s taste. Does this begin to explain why there might be some traces of uncertainty regarding “my requirements”? What is measureable about these two points vs compliance to 1910.147?

An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.  


Submit your ideas, experiences, and challenges on this subject in the comments section below. Click on the following text if you don't see a comments box, then scroll down: Unfolding Lockout/Tagout (LOTO).

Related articles:  

Machine Safety and Lockout/Tagout

Machine Safety And Your Safety Culture

Updating Minds About Machine Guarding

Contact: www.jbtitus.com for “Solutions for Machine Safety”.

No comments
The Engineers' Choice Awards highlight some of the best new control, instrumentation and automation products as chosen by...
The System Integrator Giants program lists the top 100 system integrators among companies listed in CFE Media's Global System Integrator Database.
The Engineering Leaders Under 40 program identifies and gives recognition to young engineers who...
This eGuide illustrates solutions, applications and benefits of machine vision systems.
Learn how to increase device reliability in harsh environments and decrease unplanned system downtime.
This eGuide contains a series of articles and videos that considers theoretical and practical; immediate needs and a look into the future.
Choosing controllers: PLCs, PACs, IPCs, DCS? What's best for your application?; Wireless trends; Design, integration; Manufacturing Day; Product Exclusive
Variable speed drives: Smooth, efficient, electrically quite motion control; Process control upgrades; Mobile intelligence; Product finalists: Vote now; Product Exclusives
Machine design tips: Pneumatic or electric; Software upgrades; Ethernet advantages; Additive manufacturing; Engineering Leaders; Product exclusives: PLC, HMI, IO
This article collection contains the 5 most referenced articles on improving the use of PID.
Learn how Industry 4.0 adds supply chain efficiency, optimizes pricing, improves quality, and more.

Find and connect with the most suitable service provider for your unique application. Start searching the Global System Integrator Database Now!

Cyber security cost-efficient for industrial control systems; Extracting full value from operational data; Managing cyber security risks
Drilling for Big Data: Managing the flow of information; Big data drilldown series: Challenge and opportunity; OT to IT: Creating a circle of improvement; Industry loses best workers, again
Pipeline vulnerabilities? Securing hydrocarbon transit; Predictive analytics hit the mainstream; Dirty pipelines decrease flow, production—pig your line; Ensuring pipeline physical and cyber security

(copy 5)