The Control of Hazardous Energy standard (29 Code of Federal Regulations [C.F.R.] 1910.147), commonly known as Lockout Tagout (LOTO) under the Occupational Safety and Health Administration (OSHA) has been relatively untouched since it was published in 1989.
LOTO infractions are one of the persistent and most-cited OSHA standards. The top 10 frequently cited LOTO infractions include a failure to:
- Have equipment-specific LOTO procedures
- Train workers in LOTO
- Conduct periodic inspections
- Establish a LOTO program
- Follow the sequence of LOTO
- Protect workers during group LOTO operations
- Identify all or disconnect all energy sources
- Notify employers
- Manage shift changes
- Follow the “servicing and tool change” exception
For some time, OSHA has discussed the potential for revision, and in May 2019, OSHA issued a request for information (RFI) to solicit information from stakeholders and industry on updates or changes in relation to strengths and limitations of modern technology for the control of hazardous energy to protect workers. For example, the 2019 RFI noted the LOTO standard specifies that control circuit devices cannot be used as energy-isolating devices, but “the agency recognizes recent technological advances may have improved the safety of control circuit-type devices.” A notice of proposed rulemaking (NRPM) was anticipated for September of 2022 but was never announced.
The Spring Regulatory Agenda affirms OSHA has considered the received comments and is preparing to initiate rulemaking to update the LOTO standard. The agenda indicates a projected date of March 2023 for an NPRM.
Pay close attention to OSHA’s forthcoming updates and expect to see continued aggressive enforcement throughout the year, especially with LOTO. The team at EHS Support will continue to monitor this and will keep you informed of any updates.
Questions? Contact Monica Meyer