OSHA Field Safety and Health Management System (SHMS) Manual
CHAPTER 13. CONTROL OF HAZARDOUS ENERGY SOURCES
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Purpose
This chapter establishes the OSHA Field Safety and Health Management System (SHMS) National Lockout/Tagout (LO/TO) Program. The policies and procedures in this Program are intended to set broad expectations for preventing OSHA employee injury or death from uncontrolled hazardous energy sources when there are no alternatives to conducting work activities where energy isolation is required. OSHA expects Regions, DTSEM and DTE to develop specific procedures that align with this program as needed.
This Program is designed to protect OSHA employees from the inadvertent or unintended release of energy, movement, or flow in electrical potential, mechanical, or material systems, which could result in an injury or fatality to outside personnel as defined in 29 CFR 1910.147(f)(2). Locally developed OSHA procedures that align with this LO/TO Program will ensure that all potentially hazardous energy from machines or equipment is isolated using lockout devices before OSHA employees perform any activities (e.g., inspections) where unexpected energizing, start up, or release of stored energy could cause an injury or a fatality.
All OSHA employees are considered affected employees because their jobs required them to likely work in an area in which machine or equipment servicing and maintenance is being performed. For the rare occasion when lockout devices are determined necessary, management will determine if and when a limited number of OSHA employees are considered authorized employees. If Directorate Directors, Regional Administrators (RA), and Area Directors (AD) decide employees under their supervision will never be considered authorized employees, only the annual training requirements for affected employees in this program apply to that Region/Directorate.
This Program assumes that OSHA is the outside employer and authorized OSHA employees may conduct work activities as outside personnel. Normally, OSHA employees are not expected to put themselves in a position that would require isolating hazardous energy sources. However, work activities that require taking measurements or visually inspecting equipment at an on-site employer’s worksite is considered maintenance or servicing. LO/TO program requirements apply if there is a potential for the unexpected energizing, start up or release of stored energy that could cause injury. Only authorized employees will use this Program to lock out hazardous energy. This will include providing information to the on-site employer about OSHA’s LO/TO procedures as required in 29 CFR 1910.147(f)(2)(i) (see section V.C.1).
This Program relies on an effective on-site employer LO/TO Program and OSHA employee’s ability to assess its effectiveness during the required information sharing about LO/TO procedures. OSHA employees will not conduct work activities that require controlling hazardous energy as outside personnel if there is not an effective on-site employer LO/TO Program
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Scope
This LO/TO Program is intended to apply specifically to OSHA employees covered by the OSHA Field Safety and Health Manual—specifically OSHA employees conducting work activities at another employer’s facility (e.g. inspecting or otherwise visiting another employer's facility), hereinafter referred to as the on-site employer as established in 29 CFR 1910.147(f)(2)(i).
The procedures in this program do not provide OSHA-owned equipment-specific LO/TO procedures required by 29 CFR 1910.147 for equipment at OSHA facilities. Regions/Directorates that require employees to isolate hazardous energy at OSHA facilities will develop specific LO/TO procedures for applicable OSHA-owned equipment that is consistent with, and at least as protective as, 29 CFR 1910.147. The RA/Directorate Director will provide information about LO/TO procedures to personnel servicing OSHA equipment as the on-site employer and will ensure that they are informed about the servicing personnel’s LO/TO procedures
This Program also does not apply to hazardous energy in OSHA offices covered in Chapter 6, Office Safety and Health. When there is a potential for exposure to energized parts, Chapter 22, Electrical Safety provides necessary procedures for electrical hazard recognition and avoidance.
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References
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29 Code of Federal Regulations Section 1910.147, The Control of Hazardous Energy (Lockout/Tagout)
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29 Code of Federal Regulations 1910, Subpart S, Electrical
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29 CFR 1926, Subpart V, Electrical Power Transmission and Distribution
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CPL 02-00-147, The Control of Hazardous Energy, Enforcement Policy and Inspection Procedures, dated February 11, 2008
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OSHA Field Safety and Health Manual, Chapter 6, Office Safety and Health
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OSHA Field Safety and Health Manual, Chapter 22, Electrical Safety
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Definitions
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Affected OSHA Employee is an OSHA employee that may conduct activities in an area in which LO/TO procedures are being used. All OSHA employees are potentially affected employees since they may encounter LO/TO devices at an OSHA facility or at another employer’s worksite.
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Authorized OSHA Employee is an OSHA employee authorized by an RA, Directorate Director, Area Office Director or a designee to use a lockout device. Authorized OSHA Employees will use a lock only in a group lockout that includes the on-site employer’s primary authorized employee in order to perform inspection activity on a machine or piece of equipment.
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Energy Isolation Device is a mechanical device that physically prevents the transmission or release of energy, including but not limited to manually operated circuit breakers, disconnect switches, line valves, a block and any similar devices. Push buttons, selector switches and other control circuits are not acceptable as energy isolating devices.
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Lockout Device is a device that utilizes a positive means, such as a key or combination lock, to hold an energy isolating device in a safe position and prevent the energizing of a machine or equipment (e.g. blank flanges and bolted slip blinds). Each lockout device will be supplied with a tag that meets the requirements of 29 CFR 1910.147, is intended for use in group lockout, and includes a tag that identifies the lock user and the application date.
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Tagout Device is a prominent warning device, such as a tag, and a means of attachment, that can be securely fastened to an energy isolating device in accordance with an established procedure to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed. For this Program, only lockout devices are authorized to control hazardous energy and tags are used only to label locks.
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Responsibilities
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RAs/Directorate Directors and Area Office Directors/equivalents or designees will:
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Decide if employees are authorized to conduct work activities that require LO/TO procedures on rare occasions when no alternatives are available.
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Provide training to affected and authorized OSHA employees as described in this LO/TO Program.
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Request assistance from SLTC’s Health Response Team (HRT) when investigations and inspections require hazardous energy isolation and the Region or Directorate does not have the resources to safely implement LO/TO procedures.
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Develop local procedures that meet requirements in 29 CFR 1910.147 for OSHA-owned machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy could harm OSHA employees or outside servicing personnel. Determine if authorized OSHA employees are expected to isolate hazardous energy sources at their respective OSHA facilities. Develop and provide site specific information about LO/TO procedures to outside personnel servicing OSHA equipment and share information about the servicing personnel’s LO/TO procedures before work begins (29 CFR 1910.147(f)(2)).
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If RAs, Directorate Directors, Area Office Directors or designees determine that authorized OSHA employees are authorized to use lockout devices as outside personnel, they must:
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Develop local procedures for LO/TO program implementation to supplement this Program.
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Select employees who are authorized to implement LO/TO procedures in this Program and that have the knowledge and skills required for the safe application, use, and removal of hazardous energy control devices. Ensure that selected authorized OSHA employees understand the purpose of the LO/TO program and, at a minimum:
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Can recognize hazardous energy sources;
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Will represent this chapter and local procedures as OSHA's LO/TO Program to the on-site employer as the outside personnel, as required by 29 CFR 1910.147(f)(2)(i);
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Can verify the on-site employers LO/TO program and procedures are effective (e.g. interviews and contacting equipment manufacturers);
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Know the importance of considering alternative methods and how to identify them for measuring or visually inspecting equipment;
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Know and follow the specific LO/TO procedures described in this Program; and
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Voluntarily accept assigned tasks and is willing to perform authorized OSHA employees responsibilities. Should safety concerns arise when locking out equipment or machines, the OSHA employee may choose to end the task, and will discuss safety concerns with the on-site employer and OSHA management from a safe location.
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Issue each Authorized OSHA Employee a lockout device with a key. The lockout device type should be standardized within each Office and in compliance with 29 CFR 1910.147(c)(5) for use in group lockout with at least an on-site employer authorized employee.
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Determine if authorized OSHA employees will maintain their lockout devices or if all lockout devices will be maintained in a central location until they are needed for approved LO/TO procedures. Include specifics in the local LO/TO procedures.
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Maintain a spare key for all issued lockout devices in a secured area. This key will be only used with the Area Office Director/designee’s approval. The spare key may be provided to the authorized OSHA employee if they misplace their key or may be used to remove the lock from an energy isolated device in accordance with the procedures in this Program.
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When approving an employee's request to use LO/TO procedures, consider the following:
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Are alternative methods a better option to obtain necessary information?
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Is the information critical to the inspection?
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Is the on-site employer LO/TO program effective?
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Conduct post-use evaluations with the authorized OSHA employee who used LO/TO procedures following each approved lock application. OSHA regulation 29 CFR 1910.147(c)(6) requires periodic inspections of the LO/TO procedure(s) at least annually. Post-use evaluations, conducted following each application, are intended to meet the periodic inspection intent (see Appendix A, Control of Hazardous Energy Sources Pre-Request for Approval Checklist and Post-Application Evaluation).
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OSHA employees are responsible for following this Program and Region or Directorate specific procedures. OSHA employees designated as authorized by their direct supervisors with approval from the applicable RA, Directorate Director or Area Office Director or designee to lock out hazardous energy will:
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Obtain information about the on-site employer’s LO/TO program and provide the on-site employer with the following OSHA LO/TO Program description orally or in writing to meet requirements in 29 CFR 1910.147(f)(2)(i) when considering implementing LO/TO procedures at their workplace.
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All OSHA employees are considered affected employees.
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A limited number of OSHA employees are authorized employees and allowed, only under specific scenarios, to use a lockout device as outside personnel conducting equipment inspection activities in coordination with an on-site employer.
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Authorized OSHA employees will verify that the on-site employer LO/TO program is effective before proceeding with local OSHA management approval processes.
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Authorized OSHA employees will never have the only lockout device on a controlled hazardous energy source and will only participate in a group lockout that includes at least one on-site authorized employee.
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At any time, the on-site employer, OSHA employee or their management may cancel any activity if it is determined unsafe.
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Perform LO/TO procedures in accordance with this Program (e.g. request approval, verify host employer program, and notify supervisor when complete).
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Participate in post-evaluations conducted by OSHA RA, Directorate Director and/or Area Office Director, or designees each time LO/TO procedures are implemented.
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Safe Alternatives
The following lists some options for alternative methods to obtain information without requiring hazardous energy isolation:
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Camera positioned from a safe location (e.g. a camera connected to an engineering rod, camera equipped with zoom lens or video equipment);
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Electronic measurement devices used from a safe distance/location (e.g. laser measurement device);
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Employer provided diagrams, drawings, hazard assessments and/or inventories of energy sources;
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Interviews with authorized personnel, maintenance personnel and machine or equipment operators; and
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Seek assistance from employer-authorized personnel in obtaining measurements and evidence.
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Procedures
All OSHA employees, when working near equipment that is locked or tagged out, but not inspecting equipment that requires hazardous energy controls:
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Do not alter the locks or tags that are in place; and
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Do not conduct activities that could lead to an exposure to the hazardous energy if released.
In the rare occasion when an authorized employee needs to use a LO/TO device, the authorized OSHA employee will first consider all other alternatives and ensure that locking out the machine or equipment is absolutely necessary. As outside personnel, the authorized OSHA employee will share information with the on-site employer about equipment-specific LO/TO procedures. The authorized OSHA employee must verify that the on-site employer’s procedures are effective in identifying and isolating all applicable hazardous energy sources, and must obtain approval from management before applying locks to a group lockout in accordance with this OSHA Program.
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When inspecting a machine or equipment that uses an electrical cord for power and the OSHA employee is required to place any part of his or her body into the point of operation or danger zone, the OSHA employee should ask the on-site employer representative to unplug it. The OSHA employee must maintain exclusive control of the cord and plug during inspection activities (e.g. lock a plug cap).
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When an OSHA employee makes an initial determination that an inspection activity (e.g. taking measurements, conducting a visual inspection) may require controlling hazardous energy sources, either before or during an inspection, the employee must follow these procedures:
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Consider alternative methods for obtaining the information.
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If no alternatives are identified:
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Thoroughly review the on-site employer’s LO/TO program, including any machine-specific procedures, and determine the program’s effectiveness. The OSHA employee must interview the on-site employer’s authorized employee(s) to verify that the on-site employee(s) are thoroughly familiar with the equipment, its hazardous energy sources, and any procedures in place for isolating and controlling hazardous energy.
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Obtain and review any manufacturer’s information on LO/TO procedures for the equipment or machine.
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Notify their OSHA management that they are requesting to lock out hazardous energy to conduct inspection activities.
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OSHA management and the OSHA employee requesting the approval will discuss and consider all alternatives.
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If no alternatives are identified the applicable OSHA management representative will decide whether to approve using LO/TO procedures and also whether:
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The requesting employee will continue with the inspection activities as an authorized OSHA employee; or
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Another authorized OSHA employee will proceed with the inspection activities.
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Prior to using LO/TO device(s) to control hazardous energy approved by management, the authorized OSHA employee will:
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Inform the on-site employer about OSHA’s LO/TO Program including the procedure for the host employer to follow if a lock is left in place after the OSHA employee leaves the facility.
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Comply with OSHA requirements under 29 CFR 1910.147 and follow the on-site employer’s effective LO/TO procedures.
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Verify that the on-site employer’s authorized employee(s) fully de-energized the equipment/machine and utilized an appropriate and effective energy isolating device(s) for the equipment/machine.
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Place his or her lock(s) on each isolating device for the equipment as part of a group lockout. OSHA employees will only enter into group lockout that includes a lock placed by the on-site employer’s authorized employee.
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Ensure that the on-site employer’s authorized employee verifies that the hazardous energy source is controlled after ensuring that personnel are not potentially exposed to the hazardous energy if released.
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Not attempt to activate/operate the on-site employer’s equipment.
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Authorized OSHA employees applying LO/TO procedures will:
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Limit the time for conducting work activities that require hazardous energy LO/TO to the absolute minimum needed to complete tasks.
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Remove only their energy-isolating device.
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Notify their responsible OSHA Manager(s) that the LO/TO procedure is complete when lockout devices are removed.
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If the lockout device is unintentionally left on the equipment after leaving the worksite, the on-site employer will contact the appropriate OSHA Office before removing the device. OSHA management will contact the OSHA employee to verify their location and the OSHA employee will return to the site to remove the lock. Where the OSHA employee cannot return to the site, the OSHA employee’s responsible OSHA Manager(s) may authorize removing the lockout device(s) only after the OSHA employee’s location is verified and the OSHA employee agrees with removing the lockout device.
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Training
Required training is based on expected work activities as described below:
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All OSHA employees, including affected and authorized employees, will receive training annually about this LO/TO Program and the Directorate/Area Office procedures, purpose, function, and use.
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Authorized OSHA employees must receive specific training in addition to LO/TO Program training annually or when conditions change that includes:
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How to identify hazardous energy sources they might encounter during inspections at another employer's worksite;
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Energy types and magnitudes they may encounter at another employer's workplace;
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The importance of considering alternative methods for obtaining the required inspection information;
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Methods and means necessary for energy isolation and control;
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The local procedures for requesting approval for using LO/TO procedures; and
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How to verify specific on-site employer LO/TO procedures when the use of a lockout device is required
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Retraining will be conducted whenever a post-evaluation reveals, or the responsible OSHA Manager(s) has reason to believe, that LO/TO procedures are not being used properly or that the appropriate skills need refreshed.
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Recordkeeping
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The applicable OSHA RA/Directorate Director or Area Office Director/equivalent or designee will:
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Maintain training records.
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Maintain documentation for lockout device issuance.
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A suggested format for pre-application checklist and post-application evaluation is enclosed in Chapter 13, Appendix A.
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APPENDIX A: CONTROL OF HAZARDOUS ENERGY SOURCES PRE-REQUEST
FOR APPROVAL CHECKLIST AND POST-APPLICATION EVALUATION
Pre-request Checklist for authorized OSHA employees to consider before requesting approval to implement lockout/tagout (LO/TO) procedures:
- Have you explored all alternative methods for obtaining the information without needing to lock out hazardous energy? Yes No
- Does the employer have an effective LO/TO program? Yes No
Note: Review the employer's LO/TO program to make sure it meets the requirements in 29 CFR 1910.147.
- Does the employer have specific procedures for this machine? Yes No
Note: Obtain a copy and review the employer's specific procedures to make sure they have addressed all hazardous energy associated with the machine.
- Does the employer have the correct lockout devices for use on the energy isolating device? Yes No
Note: Make sure the employer has the correct hardware for the control of the hazardous energy.
- Have you interviewed the employer’s authorized employee to ensure that the employee is thoroughly familiar with the equipment, its energy sources, and the procedures in place for the purpose of isolation and control? Yes No
- Have you informed the employer of OSHA’s LO/TO Program? Yes No
- Have you informed your supervisor about your need to use LO/TO? Yes No
If you answered yes to all the above questions, you may request approval to use the OSHA Field SHMS LO/TO Program and local procedures.
Post-application Evaluation (29 CFR 1910.147(c)(6))– Completed by the Authorized OSHA employee who used the LO/TO procedures.
Date/time the lock was applied______________and removed_____________
Name of the OSHA Manager(s) that approved the lockout:
__________________________________________________________
Who participated in the LO/TO procedures including on-site employer and OSHA employees?
Machine/Equipment description:
Review OSHA employee's responsibilities for LO/TO procedures:
Date of post-evaluation:
Names of post evaluation participants:
Any lessons learned and recommendations: