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Lockout Tagout Kits and Devices: Frequently Asked Questions

Q. What is an energy control program?


Required by OSHA , an energy control program is a set of control procedures, employee training, and periodic inspections designed to ensure employee safety during equipment/machine servicing or maintenance. The program requires that any machine or equipment being serviced be isolated from the energy source and rendered inoperative to prevent unexpected energizing, startup, or release of stored energy that can cause injury.

Q. What does LOTO mean?


Short for Lockout/Tagout , LOTO is a safety procedure used to protect workers from being harmed by any accidental release of hazardous energy. It involves locking out and/or tagging out any piece of equipment or machinery that’s undergoing service or maintenance. LOTO procedures identify such not-fit-for-use equipment and prevent the unintended release of energy that can manifest electrically, chemically, mechanically, hydraulically, thermally, or pneumatically.

Q. What are the employer’s responsibilities with respect to LOTO?


OSHA has detailed certain specific requirements for employers to ensure the health and safety of workers when servicing or maintaining equipment/machinery. These include putting in place an energy control program, using lockout and tagout devices as appropriate, and ensuring these meet OSHA requirements.

Employers also have the responsibility to develop, document, implement, enforce energy control procedures, and inspect these at least annually. They should also provide effective training to all the employees to whom the standard applies. You may refer to this OSHA Fact Sheet for more details.

Q. Can tagout devices replace lockout devices?


A tagout device may be used in place of a lockout device when an energy control device cannot be locked out, as stated in OSHA 1910.147(c)(2)(i) . When this is done, it should be ensured that the tagout device provides employee protection equivalent to a lockout device.

Additionally, OSHA 1910.147(c)(3)(i) requires that when used on an energy isolating device that is capable of being locked out, the tagout device should be attached where the lockout device would have been attached. The employer is also required to demonstrate that the tagout program safety matches that of the lockout program.

Q. Do lockout devices have to be red in color?


While OSHA has not specified a specific color for lockout or tagout devices, it does require that these devices be standardized across a facility so that employees can identify and distinguish a lockout device from other similar devices like security locks in the workplace. As stated in OSHA 1910.147(c)(5)(ii)(B) , this standardization may be in terms of color, shape, or size and print or format for tagout devices.

Q. Are there any specific requirements that LOTO devices should meet?


The requirements specific to LOTO devices are covered in OSHA 1910.147(c)(5). OSHA requires that these devices be reserved for their designated use only and be durable enough to withstand the environment in which these will be placed. These should also exhibit consistency across a facility in terms of either the color, shape, size, print, or format as applicable.

These devices should be designed and placed such that they do not get removed easily and unintentionally. The identity of the person installing the device is also required to be disclosed on the lock/tag. Additionally, OSHA requires the use of phrases such as Do Not Start , Do Not Open, Do Not Close, Do Not Energize, Do Not Operate on tagout devices.

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