5 Common Lockout/Tagout (LOTO) Violations and How to Avoid Them

If you’re a company with equipment and machinery being operated in the workplace, lockout/tagout is probably one of your most important programs. Did you know it’s also one of the most cited standards according to OSHA?  In fact, violations of the Control of Hazardous Energy standards (or lockout as it’s also called) have made it onto OSHA’s Top 10 most frequently cited standards list for at least the past 10 years, and last year was no different. For fiscal year , lockout violations came in at number 6 on the list with 2,554 violations which is up 17% over fiscal year . According to the various citations issued to employers last year, there were five main sections of the lockout standards that seem to be violated the most and we’re going to go over each one, offering a few suggestions along the way.  

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1. .147(c)(4): Energy Control Procedures 

29% of the 2,554 lockout citations issued in had to do with energy control procedures. If you’re not familiar, an energy control procedure is a set of written steps or guidelines detailing how to safely isolate and de-energize machinery and/or equipment prior to maintenance or servicing to keep workers from being exposed to harmful stored energy. In other words, it’s an instructional for how to safely perform work on equipment without coming into contact with stored energy.  

While OSHA does not provide a required format for these written procedures, they are quite specific about what must be included in a compliant energy control procedure. Surprisingly, the list is not very long and only includes four things:  

• A specific statement of the intended use of the procedure;

• Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;

• Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; and

• Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures

Unfortunately, missing procedures are the main reason for citations of this section of the lockout standards but that’s not the only thing. The other most common reason for citations involving energy control procedures has to do with energy sources missing from the procedures. Employers sometimes only include the most common energy sources, omitting things like gravitational energy because they either don’t realize it’s a contributing energy source or because they don’t think it’s important or required. If you’re unsure of whether your energy control procedures are adequate or maybe you’re just looking for a new template to use, we’ve got you covered. Our energy control procedure template will help get you moving towards creating compliant energy control procedures.  

2. .147(c)(7): Training and Communication

17% of the lockout citations issued in were related to training and communication. This particular section of the lockout standard is expansive and covers things like training for authorized and affected employees, communication methods involving the use of tags, who’s allowed to perform lockout and how affected employees are to be notified prior to and after lockout has taken place. When it comes to training, it’s not just authorized employees who have to be trained. Affected employees need training too because even though they aren’t physically performing lockout on equipment, they are part of the lockout scenario. Affected employees need to understand what lockout is and to recognize the potential hazards to themselves and their authorized co-workers when lockout is taking place.  

In their quest to simply things, employers will often make the mistake of lumping both types of lockout employees into the same training. While there is a lot of overlap in the content provided to both affected and authorized employees, it’s not a good practice to provide the same training to both camps. In fact, employers should draw a very clear line of demarcation between affected and authorized employees to prevent any misunderstandings where lockout is concerned. Several things employers can do to minimize problems are to do the following:  

• Officially designate workers as either affected or authorized from day one, keeping a detailed list of those designations  

• Provide separate training for affected employees that covers just what they need to know 

• Create an acknowledgement for affected employees to sign stating they understand their lockout responsibilities 

For those companies who want to take things a step further, consider creating a shadow board for authorized lockout users to leave no doubt about who is authorized to perform lockout/tagout activities.  

If you’re looking for a way to better manage your lockout training program, take a look at our Training Management module which offers the ability to deliver your own training but also purchase a complete training library which includes lockout/tagout training topics, among many others.  

3. .147(c)(6): Periodic Inspections

Coming in third with 14% of the lockout citations issued in are violations of the part of the lockout standard that requires periodic inspections. Even though this section of the standard is very small with just six requirements making up the whole section, those six requirements seem to cause a lot of grief for employers. Some of this confusion has to do with a mindset that inspections are for things and not people, which in this case isn’t correct. OSHA is absolutely requiring employers to periodically inspect both the energy control procedures and the authorized employees using them.  

There are three things employers are trying to determine when conducting periodic inspections:  

1. Whether the steps in the energy control procedure are being followed. 

2. Whether the employees involved know their responsibilities under the procedure. 

3. Whether the procedure provides the necessary protection, and what changes, if any, are needed.

The other thing employers seem to miss in this section is a requirement to annually certify the completion of periodic inspections and capture specific information in the process. OSHA requires these written certifications to include the following items:  

• The machine or equipment on which the energy control procedure was used

• The date of the inspection

• The employees included in the inspection

• The name of the inspector who performed the inspection

A great way to complete these inspections is using our Periodic Lockout Inspection Form template. This template will walk you through the process for completing each inspection and provides a place to track deficiencies and signatures. Additionally, to make it easier to keep up with these inspections and to prevent any of them from slipping through the cracks, we’ve also created a Periodic Inspection Log where you can log and track up to three years of periodic inspections.  

4. .147(c)(1): Energy Control Program

10% of the lockout violations issued in dealt with the requirement to develop an Energy Control Program that includes energy control procedures, employee training and periodic inspections, each of which as to satisfy the requirement to ensure before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.2 

This should be the easiest part of the standard to be in compliance with however, if an employer is already lacking energy control procedures, adequate employee training and periodic inspections, it would be impossible to be in compliance with this section of the standard. Avoiding a citation for .147(c)(1) really requires the employer to be up to speed on their current program, how it functions and whether it sufficiently satisfies other parts of the standards. 

5. .147(d): Application of Control

Last but not least, coming in 5th with 9% of the 2,554 lockout citations written in are the application of control violations. If you’re not familiar with what this is, it’s where OSHA specifies what elements must be included in a company’s energy control procedures and the sequence in which they must be performed. There are six elements that must be included in every energy control procedure and those six elements are: 

1. Preparation for shutdown 
2. Machine or equipment shutdown 
3. Machine or equipment isolation 
4. Lockout or tagout device application 
5. Stored energy 
6. Verification of isolation

The reason for so many citations of this part can sometimes be attributed to the wrong people being tasked with lockout procedure creation. Many times it’s the EHS person who is given the responsibility of creating these procedures and while the EHS person may understand lockout, understanding the energy sources and means of controlling them for each piece of equipment is quite another thing. Creating energy control procedures should really be a collaborative effort between EHS and maintenance so that the procedures will be complete from both a maintenance and a regulatory standpoint.  

Final Thoughts 

Being in compliance with federal lockout standards doesn’t have to be difficult. It just requires a good understanding of what’s required and the right tools, like those offered by EHS Insight. Whenever you’re ready to improve your lockout program, we’re ready to help.  

According to the Electrical Safety Foundation (EFSI), electrical accidents account for 6% of workplace fatalities. While the number of fatalities has dropped in recent years, this figure underscores the importance of workplace safety.

Creating a safe work environment should be one of your top priorities as a contractor or business owner. Fortunately, you can implement concrete safety measures to prevent electrical accidents in the workplace.

In this article, we’ll discuss how electrical contractors can ensure safety in the field.

Identifying the Most Common Causes of Electrical Hazards

Understanding the most common electrical hazards is the first step in creating a safe worksite. Stay on the lookout for these common electrical hazards when you’re out in the field:

• Exposed or faulty wiring: Loose, frayed wires are signs that the insulation is damaged. Accidental contact with live wires can cause electrical shocks or lead to fires.
• Wet conditions: Water conducts electricity by absorbing minerals and ions from its surroundings. Wet conditions near your worksite are a safety hazard and could increase the chances of electrocution.
• Damaged tools or equipment: Using defective or damaged tools or equipment exposes you and your crew to electric shocks and injuries.
• Exposed power lines: Overhead power lines carry high voltage. Coming in contact with exposed power lines can be fatal.
• Inadequate grounding: Improper grounding can cause electrical current to seek another way to ground itself. It can travel through random paths, injuring and killing people in its course.

What Are the Main Causes of Electrical Accidents?

A small issue, like a frayed wire or a loose cable, can quickly become a safety hazard, leading to a major accident on the worksite. You can prevent these hazards by staying alert and aware of the most common causes of electrical accidents. Most electrical accidents result from:

• Overloaded extension cords: Daisy-chaining is a common mistake on busy worksites. It happens when multiple pieces of equipment or tools are plugged into a single cord or socket. Doing this can overheat the cord, which could cause an electrical fire.
• Faulty circuit breaker: Circuit breakers cut off power in case of an overload. However, they may become faulty over time. This can lead to a major electrical incident.
• Inadequate Training: If your employees lack proper training, they may mishandle equipment or touch live wires, resulting in accidents.

How to Prevent Electrical Accidents in the Workplace

Electrical hazards on busy worksites can put you and your crew at great risk. Here are 10 ways to prevent electrical accidents in the workplace.

1. Conduct Regular Safety Audits

Research reveals that nearly 60% of businesses will see fewer worksite incidents when they track safety metrics and KPIs through safety audits. Safety audits help electrical contractors stay compliant with the latest regulations. They help you identify gaps or inconsistencies in your electrical systems, personnel training, and equipment.

You can reach out to third-party safety consultants to conduct periodic safety audits as a responsible business. The audit team will typically perform thorough checks to see if your electrical equipment, grounding, and wiring are properly installed and in good working condition. They will also check the site for overloaded circuits and improper installations that could cause electrical mishaps.

Aside from these checks, they may assess your internal workplace safety practices to ensure they comply with the latest safety standards. Based on their findings, the audit team will recommend corrective steps.

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We recommend setting up a schedule of follow-up audits to review the effectiveness of your corrective efforts. Regular safety audits help you catch workplace hazards early, reducing injuries, costs, and downtime.

2. Start a Comprehensive Training Program

Training your employees on safe electrical procedures shouldn’t be a one-off scenario. Your employees should undergo extensive training periodically, where they learn about electrical hazards, regulatory standards, safety policies, and emergency response protocols.

The program should also include hands-on training modules and practical demonstrations of safety protocols. This will prepare your employees to handle specific emergencies. For example, if you or your crew frequently work on construction sites, you can implement a hands-on training program that teaches workers to handle insulated tools and identify hazardous live wires.

It’s also a good idea to schedule regular refresher training to keep your employees up-to-date on policy or regulatory changes.

To reduce the danger of an accident, ensure your team only uses high-quality machinery with safety features. For example, electrical contractors may need to work on high-voltage systems as part of their job. In such instances, they must only use tools with insulated handles, non-conductive materials, and an auto shut-off system.

You must also ensure your team can follow manufacturer guidelines when using tools. Modifying or misusing electrical tools by bypassing their safety mechanisms can cause serious mishaps.

4. Enforce Compliance With OSHA Regulations

Whether you own an electrical business or work as an independent electrical contractor, you must follow Occupational Safety and Health Administration (OSHA) regulations when working on-site. This is not just a legal obligation but an integral part of workplace safety.

OSHA’s framework highlights key safety guidelines. For instance, according to the OSHA Standard .303, you must ensure proper wiring and grounding when installing electrical equipment. You must also ensure your employees maintain a safe distance from live electrical parts while working, according to the OSHA Standard .333. Complying with these OSHA guidelines can save lives and your company from hefty penalties.

Many companies have benefitted from complying with OSHA’s safety regulations. The most recent example is a Des Moines-based contractor who consulted with OSHA’s Iowa chapter. During this consultation, OSHA identified 42 hazards on the contractor’s construction site and helped them take corrective action to reduce injuries.

5. Establish Lockout/Tagout Procedures

Did you know that, according to OSHA figures, implementing Lockout/Tagout (LOTO) procedures can save up to 120 lives each year and prevent 50,000 injuries? During maintenance and repair phases, you can follow these LOTO procedures and steps:

• Isolate electrical equipment from their power supply.
• Lock out the power source to prevent restarting.
• Release any stored energy from the machinery.
• Use tagout devices to warn workers against operating the machinery.

6. Equip Workers With Personal Protective Equipment (PPE)

Personal Protective Equipment, or PPE, is more effective in ensuring workplace safety than you think. They can be a lifesaver in most instances involving electrical equipment, lowering occupational injury incidents by 37.6%.

Ensure you provide your workers with commonly used PPE such as insulated gloves, safety boots, face shields, and arc flash and flame-resistant clothing. In areas with electrical equipment, you must use insulating or rubber mats to protect your team against shocks. For heavy manufacturing tasks, workers should also wear flame-resistant clothing.

You can create and use a PPE inspection checklist to guarantee your team receives complete protection. Long-term use of these kits can reduce effectiveness, so inspecting them regularly is crucial. Also, educate your workers on using each PPE so they know when and where to use it.

7. Foster a Safety-First Culture on Job Sites

When your employees embrace safety procedures as part of the company culture, they’re more likely to internalize safety measures daily.

Employees who take personal responsibility for maintaining a safe workplace will exercise greater care in their work. In the long term, this lowers the risk of accidents by 70%. You can foster a safety-first culture by:

• Encouraging leaders and supervisors to prioritize safety measures, setting an example for subordinates to follow
• Offering regular on-site training on safety protocols
• Encouraging open conversations about safety concerns and challenges. For example, you can implement a “see something, say something” policy to garner safety feedback.
• Setting up a system to report safety inconsistencies. For example, you can set up a safety hotline or encourage your team to report safety issues via a safety reporting app.
• Rewarding safe conduct to encourage others to follow suit

Learn more: How to Create an Employee Handbook

8. Utilize Proper Signage and Labeling

Clear labels and signs can help you and your workers prevent missteps or lapses in attention that could cause accidents. Safety signages create clear visual reminders about electrical safety, reducing workplace accidents considerably.

OSHA identifies three main types of signs you can use on a work site. This includes danger signs, caution signs, and general safety information labels.

You can use signage to mark potential hazards and safety zones, such as those near control rooms or electrical panels. For example, you can warn workers about high-voltage machinery by using a lightning bolt symbol or a “Danger: High Voltage” sign. You can also use bold electric panel labels to indicate their voltage levels.

Use color-coded labels to distinguish between different types of electrical equipment. For example, you can use red labels to signify emergency circuits and green to signify grounding devices. Most importantly, ensure you and your workers understand what each sign or label represents.

9. Maintain Equipment and Electrical Systems Regularly

Regular equipment checks aren’t just a compliance issue. They’re integral to workplace safety and help avoid unexpected machine failures and injuries. The National Safety Council (NSC) reported that injuries from worksite equipment were the third-leading cause of workplace death in -.

Routine servicing and testing of electrical installations can help you avoid unexpected accidents. This includes scheduling regular weekly, monthly, or quarterly inspections of electrical systems and machinery based on their usage and risk level. You should also plan regular maintenance to lubricate and clean equipment.

Depending on your location, you may also need to perform seasonal maintenance. For example, humidity or rainy weather can affect electrical systems, prompting the need for additional cleaning. Aside from technical maintenance, you must ensure that electrical systems and equipment are clean and debris-free. This can help prevent overheating and fires.

10. Have an Emergency Response Plan in Place

Despite taking the necessary measures, things could still go wrong on your worksite. Drafting an emergency response plan is one of the best ways to handle unexpected electrical accidents at work.

The plan should include everything from providing first aid and calling emergency services to evacuation arrangements, if necessary. You could also include additional steps in this plan, such as shutting down machinery and administering lifesaving procedures like CPR.

The Federal Emergency Management Agency (FEMA) advocates practicing exercises and emergency drills to build preparedness. It also recommends referring to an extensive safety checklist during an emergency. Make sure you share and discuss the plan with your team members so they’re ready to respond.

Housecall Pro: Your Partner in Electrical Safety

When you manage an electrical business, providing technical services is just one part of the job. You must also handle day-to-day operations like managing clients and invoices and communicating with team members. To do this and do it well, you need reliable tools that simplify operations and make daily business efficient. A trustworthy electrical contractor software can help ease your business management burden.

You can ensure both efficient and safe work environments by looking for these features in business management software:

• Customizable job checklists to ensure key safety protocols are in place
• Payroll management features that allow you to track employee hours and overtime and calculate pay accordingly
• In-app chat features that facilitate more efficient communication and collaboration
• Automated booking, invoicing, and client management features
• Safety assurance with downloadable job hazard and safety analysis (JSA) templates

Build a Safer Work Environment with Housecall Pro

Maintaining a safe work environment should be a priority, especially as your electrical business scales to new heights. Let Housecall Pro shoulder some of the responsibility and help you build a safer, more efficient, and more profitable business. Take the first step toward creating a safer work environment with Housecall Pro today.

If you want to learn more, please visit our website Electrical Lockout.

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