Failure by employers to develop and use hazardous energy control procedures as required by OSHA’s lockout/tagout standard (29 CFR 1910.147) is one of the Agency’s annual top 10 most frequently cited workplace safety violations. Perhaps the most demanding compliance obligation is establishment of a written energy control program. OSHA, the National Institute for Occupational Safety and Health (NIOSH), and state plans have endeavored to assist employers by providing detailed instructions and templates that can be used in writing the program.  Below we list several key considerations that should be addressed in any written energy control program.

What is hazardous energy?

Hazardous energy is a slippery term that encompasses more than just electrical energy. In general, hazardous energy is any type of energy that can be hazardous to workers because it can cause equipment to move. In addition to electricity, hazardous energy includes hydraulic fluid, air pressure, water pressure, gravity, chemical energy, static energy, and thermal energy. Something as simple as a wound spring contains hazardous energy. Moreover, hazardous energy can be stored even when equipment is turned off. For example, if a certain valve is opened, hydraulic fluids can move machinery parts even when the motor or electricity is off.

Primary standard

OSHA’s 1910.147 standard covers the servicing and maintenance of machines and equipment in which the unexpected start-up or the release of stored energy could cause injury to employees. In part, employers must:

• Ensure that that a designated individual turns off and disconnects the machinery or equipment from its energy sources(s) before performing service or maintenance and that the authorized employee(s) either lock or tag the energy-isolating device(s) to prevent the release of hazardous energy and take steps to verify that the energy has been isolated effectively.
• Ensure that the employee(s) take steps to prevent injury that may result from the release of the stored energy if the potential exists for the release of hazardous stored energy or for the reaccumulation of stored energy to a hazardous level.
• Establish a written energy-control program.

Other standards

In addition to 29 CFR 1910.147, two other OSHA standards contain energy control provisions—29 CFR 1910.269 (Electric power generation, transmission, and distribution) and 29 CFR 1910.333 (Selection and use of work practices).  Also, some standards relating to specific types of machinery contain de-energization requirements—such as 29 CFR 1910.179(l)(2)(i)(c), which requires that switches be “open and locked in the open position” before performing preventive maintenance on overhead and gantry cranes.

Written program

NIOSH lists 19 “important” elements that should be considered in the writing a solid energy control program. These include:

• A list of all sources of hazardous energy with machine-specific information.
• A list of which operations require lockout.
• Which employees need to be trained on lockout procedures. Temporary employees and external employees and contractors must be included.
• A requirement that training must be documented and verified, preferably by a person who does not perform lockout.
• A requirement that only one key exists for each assigned lock and that only the affected employee has the key.
• Requirements that the locks used for lockout are all the same type and are used for no purpose other than lockout/tagout. In this way, employees can recognize easily that a lock is being used for lockout.

“Realize that the most important point is that the performance of lockout is an administrative procedure,” states NIOSH. “It is therefore susceptible to non-compliance or mistakes by any of the involved, managers, workers, contractors, and others. Everyone is involved in its success and failure, and that makes it important to have an established team.”

NIOSH’s full list of considerations for a written program is at https://www.cdc.gov/nora/councils/manuf/loto/guide/control.html.