Top OSHA Safety Issues for Manufacturers: Proper Lockout/Tagout

by Pam

What Is OSHA?

In 1970, the United States Congress and President Richard Nixon created the Occupational Safety and Health Administration (OSHA), a national public health agency with the mission of ensuring safe working conditions for employees across the country. This follows various historical workplace disasters, such as the Triangle Shirtwaist Factory fire, so as to best prevent those tragedies from repeating.

In the decades since its founding, OSHA has implemented health standards spanning numerous industries, including asbestos, fall protection, machine guarding, bloodborne pathogens, and more. With unified efforts from employers, employees, health professionals, unions, worker advocates, and more, OSHA has reduced work-related fatalities by almost 63 percent. 

Why Is OSHA Important for Your Manufacturing Facility?

Following OSHA protocols and safety regulations is critical not only for the safety of your most valuable asset—your employees—but also for the short- and long-term success of your manufacturing organization. Without your employees, your facility obviously can’t fully or properly run at normal capacity. Plus, your manufacturing business could gain a reputation for being unsafe and extra dangerous for workers, which is also bad for business.

Following OSHA is essential for more than your manufacturing business, though—it’s also important for the growth of the economy. Occupational injuries and related illnesses cost American employers almost $99 billion in workers’ compensation in 2018.

What Are Lockout/Tagout (LOTO) Procedures?

Lock-out/Tag-out procedures ensure that dangerous machines are properly shut off and not able to be started up again prior to the completion of maintenance or repair work. The goal of these efforts is to prevent accidental discharges, movements, or other potentially hazardous activity from the machine.

The number of accidents per year averages around 60,000 with workers injured from exposure to hazardous energy, which contributes to losing about 24 workdays for recuperation. Common injuries include electrocutions, amputations of fingers, hands, or arms, severe crushing injuries, and even fatalities due to improper lockout/tagout procedures.

To maintain a safe work environment and keep your employees productive and protected, lockout/tagout procedures are an essential part of your manufacturing business.


Authorized employees should be trained on LOTO procedures and on the hazards related to cleaning, repairing, servicing, setting up, and adjusting prime movers, machinery, and equipment. Each affected employee shall be instructed in the purpose and use of the energy control procedure. 

All other employees whose work operations may be in an area where LOTO may be utilized should be instructed about the prohibition relating to attempts to restart or reenergize machines or equipment that are locked out or tagged out. Production line workers who do not perform LOTO should have awareness level LOTO training.

Cleaning, Servicing, and Adjusting Operations

Machinery or equipment capable of movement shall be:

  • Stopped
  • The power source de-energized or disengaged
  • The moveable parts shall be mechanically blocked or locked out to prevent inadvertent movement or release of stored energy
  • Accident prevention signs or tags or both shall be placed on the controls of the power source of the machinery or equipment

In all cases, accident prevention tags and/or accident prevention signs shall be placed on pertinent equipment and controls.

Materials and Hardware

Signs, tags, padlocks, and seals shall have means by which they can be readily secured to the controls. The official tag-out device attachment should be a non-reusable type attached by hand, self-locking, non-releasable, and with a minimum unlocking strength of more than 50 pounds.

Repair Work and Setting Up Operations

Equipment and machines NOT equipped with lockable controls or readily adaptable to lockable controls shall have positive means taken:

  • De-energizing
  • Disconnecting from the power source
  • Other effective action(s) to prevent movement and the inadvertent release of stored energy

Be sure to unplug connected equipment; unplugging must control all de-energization and the plug should be under the exclusive control of the person performing the work.

Hazardous Energy Control Procedures

A hazardous energy control procedure should be developed in writing and utilized. This document must include separate procedural steps for the safe lockout/tagout of each machine or piece of equipment affected by the hazardous energy control procedure.

There are two exceptions to this:

  • Condition 1: The operational controls named in the procedural steps are configured in a similar manner; the locations of disconnect points (energy isolating devices) are identified; and the sequence of steps to safely lockout or tagout the machinery or equipment is similar
  • Condition 2: The machinery or equipment has a single energy supply that is readily identified and isolated and has no stored or residual hazardous energy

Almost 95 percent of all LOTO citations involve not having a formal Energy Control Program in place!

Periodic Inspection Program

Review your program and procedures annually to evaluate the effectiveness and determine the necessity for updating the written procedure(s). 

Assign an authorized employee or someone other than those using the hazardous energy control to conduct the inspection. This way, hazards aren’t overlooked and you can ensure continuous safety for your employees. 

Steps to OSHA Safety Regarding LOTO Procedures

Follow these general steps to ensure your manufacturing business is following proper LOTO procedures from OSHA:

  • Survey the plant to identify the various equipment where lockout/tagout is necessary
  • Develop a written program
  • Develop separate written procedures for each equipment item
  • Provide lockout hardware, signs, and tags
  • Provide employee training
  • Conduct periodic inspections

Protect Your Employees with CMTC’s Consulting Services

CMTC’s goal is to make sure that the companies we work with understand the applicable safety standards and continuously keep employee safety top of mind. After all, your employees are your most valuable asset! 

We provide smaller manufacturers with the resources of larger companies and our manufacturing experts analyze any unnecessary risks from an industrial safety standpoint and advise on potentially hazardous situations. 

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