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OSHA Top 10 Workplace Safety Violations: Why Lockout/Tagout Ranks Every Year

Dec. 5, 2022
Industrial safety expert Bill Belongea explains why lockout is consistently cited in OSHA’s annual list of top workplace safety violations and shares best practices for companies to not only improve employee safety—but also their bottom line.

Each year, the Occupational Safety and Health Administration (OSHA) releases a list of the top 10 most-cited safety violations, with lockout/tagout (also known as LOTO) ranking year after year, along with other serious violations like fall protection, hazard communication and respiratory protection. With nearly 2,000 lockout citations
reported in fiscal year 2022 alone, according to the National Safety Council1, it’s evident that many companies struggle to prioritize and implement effective lockout strategies. 

Before evaluating whether a company’s procedures are effective, it is first important to understand how OSHA’s 1910.147 standard defines lockout, which is “the practice of controlling hazardous energy to prevent the unexpected start-up, energization, or release of stored energy during service or maintenance activities.”2 Hazardous energy encompasses all energy sources, including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources, such as gravity, in machines and equipment that can be hazardous to workers. Above all, company leaders must recognize lockout is not just best practice to prevent worker injury—it’s the law. 

Lockout in Manufacturing Facilities

Industrial manufacturing environments are typically what comes to mind when discussing lockout, as many of these facilities rely on heavy machinery and hazardous energy to complete their day-to-day operations. While OSHA’s 1910.147 lockout standard applies to a variety of facilities, formal lockout practices are of paramount importance in any manufacturing facility where environmental or mechanical hazards abound. Heating, cooling, and ventilation equipment, combustion and welding equipment, and heavy machinery designed to handle hard materials, such as wood, metal, and plastic, are a few areas where lockout procedures are often needed in manufacturing facilities.  

Every manufacturing facility is required to comply with OSHA, with failure to meet current standards resulting in possible OSHA violations and penalties, or worse, catastrophic incidents and injuries. Any of these outcomes can jeopardize company operations if critical machinery and equipment is down because of incident investigation.  

Within the manufacturing space, some of the most common reasons for lockout noncompliance include: 1) the thought that recognition and isolation of hazardous energy is a difficult compliance requirement and 2) the misconception that lockout procedures decrease productivity. 

5 Best Practices for Manufacturing Facilities

Though each facility has its own unique set of safety challenges, companies should prioritize the following industry best practices when working to develop and maintain a first-rate lockout program:

  1. Develop a Hazardous Energy Control Program/Policy. A baseline approach to safe lockout practice is the implementation of a Hazardous Energy Control Program specific to the operations of each manufacturing facility. This program should be a user-friendly, site-specific document customized to the operation that outlines the roles and responsibilities of all employees within the Lockout Management System. This guiding document is used to audit lockout activities within your organization. 

  2. Create machine-specific, visually instructive lockout procedures. In addition to an overview guide of lockout program standards, it is important to provide equipment-specific visual documents outlining the procedural steps to shut down equipment safely to a zero-energy state. For this type of instruction, a visual approach is best, one where you clearly show the equipment to be worked on with step-by-step instructions as to which isolation points must be secured and what must be done to prepare for shutdown and isolation of hazardous energy. 

  3. Training and retraining. In addition to being equipped with a lockout program and equipment-specific procedures, employees must be properly trained so they understand the purpose and function of the facility's lockout program and the equipment to which they are exposed. The amount and type of training that each employee receives should be based on the relationship that employee's job has to the equipment being locked out and the degree of knowledge relevant to hazardous energy that employee needs to control. A hands-on, practical approach is a best practice for training.

  4. Auditing and inspecting. To identify methods of improvement in process, and changes or updates on equipment, manufacturing facilities must conduct in-depth audits and inspections to determine areas where hazardous energy is present and lockout procedures need to be implemented. This includes on-site examinations and analyses of the facilities and their applications for controlling hazardous energy sources during maintenance and repair operations.

  5. Enlisting the help of trusted third parties. It’s easy to feel overwhelmed when maintaining a lockout program. Completing proper documentation, periodic inspections, changes in processes – and then reflecting them in company policies, procedures, and training program – takes knowledge, extra capacity, time and meticulous management. However, with the support of trusted third-party resources like Master Lock that offer customized, efficient processes and expertise, the journey to creating a safe and compliant lockout program becomes seamless.  

The Business Case for Implementing Lockout Procedures in Manufacturing Facilities

Too often, company leaders make the mistake of viewing safety compliance as an incremental cost that works against profitability. Despite this misconception, many companies find financial and operational benefits when implementing lockout procedures, including:

  • Operational efficiencyIdentifying weak points and hazards throughout operations can affect the reliability of work being performed. Improvements increase productivity, leading to short-term gains that can turn into long-term, sustainable profitability. For example, making safety equipment readily available where lockout needs to be applied can increase productivity. 
  • Forecasting preventable losses. Proactive efforts eliminate or minimize incidents, resulting in estimated cost savings that exceed the price of the reactive actions. Example: creating preventative maintenance schedules to decrease downtime on machines and equipment. 
  • Job satisfaction. Workers don't respond positively to unsafe and hazardous workplaces and may not work for long under those conditions in exchange for a paycheck. Management already has a demanding list of responsibilities and having to respond to preventable on-the-job incidents only makes their job harder. Positive reinforcement for successful lockout activities is a great way to motivate employees to do the right thing. 

Though the first goal of developing a comprehensive lockout program is ensuring compliance with OSHA—that is just the tip of the iceberg. Clear, systemized lockout procedures and practices are essential to keep employees safe and will ultimately result in fewer accidents on the job. Many manufacturing leaders who invest in lockout processes find that going beyond compliance to running a well-organized safety management system is not only a justified business decision, but also represents a significant stride toward building a safer, more productive workplace for years to come. 

To learn more about creating, auditing, or updating electrical safety programs, visit Master Lock’s Professional Lockout & Safety Services website. For additional safety and security insights, visit insights.masterlock.com. 

1 National Safety Council. OSHA Reveals Top 10 Safety Violations at NSC Safety Congress & Expo. (2022) 
2 Occupational Safety and Health Administration. 1910.147 - The control of hazardous energy (lockout/tagout). 

About the Author 

Bill Belongea, Professional Services Program Manager at The Master Lock Company, has nearly 20 years of experience in the safety industry. A graduate from the University of Wisconsin-Whitewater with a B.S.E. in Occupational Safety, Bill has experience in the printing, injection molding, aerospace, construction and press industries, and now utilizes his expertise to help facility and factory managers all over the world including Europe, Australia, China, and Mexico. Bill has an expansive knowledge in a best practice safety management approach. He is currently a member of the ANSI Z244.1 Standard Committee on the Control of Hazardous Energy as well as ANSI Z10 Safety Management Systems Committee.
NOTE: This information is intended to help guide facilities and its personnel. However, proper implementation, training and compliance is the responsibility of the facility and its operators.  

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