It’s Time to Update Your Lockout/Tagout Procedures

The Occupational Safety and Health Administration (OSHA) lockout/tagout standard requires any operation dealing with hazardous energies — electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources — to have an energy control program in place to protect employees. 

While this includes equipment in repair facilities, many fleet professionals don’t realize that the same lockout/tagout standard applies to working on vehicles and power-operated equipment. 

OSHA has this standard in place for good reason: Following lockout/tagout (LOTO) standards prevents an estimated 120 fatalities and 50,000 injuries each year. 

One could argue LOTO programs also protect employers. Injuries resulting from exposure to hazardous energy take workers off the job to recuperate for an average of 24 workdays, and the related costs can add up quickly. Beyond lost productivity, costs include medical treatment, vocational rehabilitation, increased workers’ compensation premiums, repairs for damaged equipment, and more. 

Because the human and financial risks can be high, it’s important to not just follow LOTO procedures, but to update them regularly. These six tips can help. 

1. Review the Policy Regularly

Establishing LOTO procedures isn’t a one-and-done activity. OSHA requires affected operations to review their policies periodically. But if fleets don’t have a plan in place to do so, it can be an easy thing to forget.

“While fleets have practiced doing LOTO in their shop equipment for years, I’m always amazed how many fleet operations haven’t reviewed their LOTO programs when it comes to working on vehicles and power-operated equipment,” said Gary Lentsch, CAFM, fleet manager, Eugene Water & Electric Board. “By reviewing your LOTO program annually at safety meetings, it gets your employees involved as they review their responsibilities as they pertain to the LOTO procedure. So ultimately, the purpose of the inspection is to correct any deficiencies with the LOTO procedure.”

While OSHA requirements may vary by state, federal requirements dictate reviews must have two components: 1) an inspection of each energy control procedure, and 2) a review of each employee’s responsibilities as they pertain to the energy control procedure being inspected. 

As fleets review their procedures, OSHA also requires the following:

• Each energy control procedure must be inspected separately. 
• Every procedure needs to be reviewed at least annually. 
• Employees must demonstrate the procedures during inspections, and inspections need to happen while authorized employees perform servicing and/or maintenance activities on machines or equipment. 

Ultimately, the inspector’s job is to determine if the procedures are adequate, are understood by employees, and are being followed properly. After the inspection, fleets should review each employee’s responsibilities for the procedure that was inspected.

“OSHA says employers must conduct periodic inspections of their LOTO procedures. The inspections must be performed by a competent person other than the ones that are using the LOTO procedures,” Lentsch said. “Like many, it took a close call to make us do an intense review of our LOTO procedures.”

2. Ask the Right Questions

If you haven’t reviewed your LOTO procedures and documentation in the last year, it is probably time for an update. But the question is, what should be updated? 

Lentsch recommends fleet professionals ask the following questions, which should prompt ideas for additions and revisions:

• What are your procedures and are they being followed?
• When you ask technicians what the LOTO procedures are, does their response match what is documented? 
• Do technicians feel there is anything missing from the LOTO procedures?
• Are LOTO procedures clear, concise, and easy to follow?
• Do LOTO instructions leave too much room for interpretation?
• What language could be added to clarify procedures or make them more specific?
• Have there been any changes in policy or regulatory requirements that need to be addressed?

3. Adjust for Fleet Changes

Changes to your fleet lineup could also require updates to your LOTO procedures. When fleets add new types of equipment or vehicles equipped with new technology, the current LOTO routine may not be adequate.

“We continue to see changes in vehicle technology and changes in the operator’s specification of each vehicle,” said Jacob Berks, fleet operations manager, Sacramento Municipal Utility District in California. “These changes require a review and possible changes to our lockout/tagout policy. For example, many operators request remote start from the key fob, or the vehicle may have a remote start/stop switch from the rear of the vehicle to start/stop an auxiliary driven component such as hydraulic circuit, aerial, derrick, air compressor, etc. As new vehicles come into the fleet, it’s important to take time to review each one and see if changes need to be made.”

For Lentsch, the biggest fleet change is the transition to electric vehicles; when vehicles are powered differently, it’s likely they must be locked out differently, too. “While it is difficult enough to predict all the incremental changes with our existing technologies, we can’t ignore that more of our fleet is going electric. Our technology is moving us from engines, transmissions, and drivetrains to batteries, electric motors, and high voltage wires,” he said. “Today, more and more energy is being generated in vehicles, so our LOTO programs need to control hazardous energy during service and maintenance activities.” 

While your policy should account for new vehicles and equipment added to the lineup, OSHA guidelines remind fleets that overhauled equipment needs to be capable of being locked out, too, and may require a different procedure than it did before.

4. Ask the Experts

Getting a fresh perspective on your LOTO procedures can help fleets identify updates, and asking shop technicians is a good place to start. Lentsch said a fleet’s safety partners may also be able to provide helpful resources.

Of course, fleet operations will also want to consult the federal OSHA guidelines to ensure their standard operating procedure continues to abide by the standards. LOTO procedures can also vary by state, so it’s important to review those standards as well. For instance, Berks’ fleet follows Cal/OSHA guidelines and Lentsch’s fleet the Oregon OSHA lockout/tagout guide. States may even have resources available that are specific to the automotive repair industry, as Oregon does.

But beyond general guidelines, Lentsch said fleet operations have access to resources that are more customized to their specific operation. “While there are several safety consulting services available, the OSHA has an on-site consultation program that offers a no-cost and confidential occupational safety review in all 50 states,” he said. “It’s important to know that these on-site consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with you to identify workplace hazards, provide advice for compliance with OSHA standards, and assist in establishing and improving safety and health programs.”

5. Prepare for Common Dangers

Even though each fleet is unique, they could face some common hazardous energy dangers. 

Both Berks and Lentsch cited remote start as an issue. “If an operator can’t find his vehicle because it’s been brought into the shop for service, the operator may walk through the yard pressing his remote start key fob while listening for his vehicle. Meanwhile, 50 yards away a mechanic may be mid-way in the engine compartment replacing a fan belt,” Berks explained. “The potential for a major life-threatening or life-altering accident is huge. Lockout/tagout is designed and implemented to protect against these kinds of unexpected and unintended accidents.”

Berks said the second most common issue in his shop occurs when a driver brings a truck towing a trailer into the shop to replace a light. “The operator is wanting to stay in the vehicle with the key in the ignition while the mechanic performs a small quick repair,” he said. “This situation happens all the time, but now you have a mechanic between the truck and trailer looking to make sure it’s plugged in correctly. This is a major hazard, and the potential is there for the operator to start and move the vehicle because it’s not locked out.”

Developing guidelines for common situations like these and reviewing them with technicians can help prevent injuries or severe incidents. 

6. Be Methodical in Documenting the Policy

If updates are identified, document them properly to formalize the procedure. 

“As with any well-written procedure, you may want to follow the recursive process of prewriting, research, drafting, revising, and editing,” Lentsch said. “Be sure to get your shop involved, as shop contributions are needed for buy-in and enforcement of the LOTO procedures.”

Lentsch recommends that documentation include:  

• The intended use of LOTO procedures
• Potential types of hazardous energy, like mechanical hazards associated with unexpected start-ups or motion releases
• Defined procedures for shutting down, isolating, and blocking components for sudden releases
• The steps for locking out vehicles and equipment as well as what’s involved with putting the vehicle back in service once the work is complete.

Don’t Forget to Reinforce the Policy

You may make excellent revisions to your LOTO policy, but driving the message home with employees is just as important as making updates. 

“Things are always changing, so it’s important to review the policy and keep it fresh in the minds of the team,” Berks said. “It’s there to protect each employee and is only effective if implemented.”

Lentsch said it’s even more important to reinforce LOTO policies with employees, as both familiarity with their environment and pressure to perform can cause technicians to skip steps.

“We can get complacent about some of the potential dangers that we face by working on so many vehicle-related tasks throughout the day,” Lentsch said. “As some fleet shop operations push for time standards and efficiencies, our technicians may weigh their personal values of taking a risk to get their work done. Having a properly executed lockout/tagout program for our fleet-related vehicles and equipment reduces injuries and safety violations in our maintenance facilities.”