Creating Efficient Lockout/Tagout Training That Adheres to NFPA 70E

When it comes to LOTO training to follow the NFPA 70E standard, three types of employees need to be covered.

• By Darron Wright
• Jun 01, 2019

Electricians, machine operators, and laborers are among the 3 million workers who service and maintain equipment routinely and face the greatest risk of injury from energy sources. Employees in almost every industrial setting are exposed to such hazards, which is why the National Fire Protection Association 70E standard highlights the need for staging safe work zones with boundaries, barricades, signs, and attendants. A key component to these safe work zones is an effective Lockout/Tagout (LOTO) program.

OSHA was established in 1970. Subsequently, standards 1910 Subpart S and 1926 Subpart K were written to address the design of safety-related work practices for persons who install, maintain, and repair electrical circuits or equipment. Still, OSHA found failing to properly control energy accounted for nearly 10 percent of serious accidents in many industries. Realizing the two measures weren’t enough, OSHA recommended the creation of NFPA 70E, a requirement for safe work practices to protect personnel by reducing exposure to major electrical hazards.

NFPA 70E helps companies and employees avoid workplace injuries and fatalities due to shock, electrocution, arc flash, and arc blast during maintenance and construction in industrial plants. While it covers many key principles, addressing lockout/tagout practices is one component that takes the OSHA guidelines for safety a step further.

Every year, workers are unnecessarily exposed to hazardous energy sources during servicing, maintenance, or setting up equipment. Accidental start-up of machinery or unintended release of stored energy often presents catastrophic risks that can cause serious physical injuries or death to workers unaware that someone else has started a machine or energized a circuit. By implementing proper lockout/tagout procedures and training, risks such as employee injuries, damage to equipment, production interruption, and ruined reputations can be avoided.

OSHA defines lockout as "The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed." Tagout, meanwhile, is "The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed."

Lockout/Tagout Training
Training is a component of any LOTO program because it helps provide the information and equipment teams need to begin implementing an effective program. When it comes to lockout/tagout training to adhere to NFPA 70E, three types of employees need to be covered:

• Authorized Employees are responsible for implementing energy control procedures and performing the required servicing or maintenance. Training for Authorized Employees includes details about the type and magnitude of the hazardous energy sources present at the facility and the methods for isolating and controlling these energy sources. Authorized Employees also must receive training on machine-specific procedures.
• Affected Employees operate equipment or work in an area in which an energy control procedure is being implemented. Affected employees are not themselves responsible for locking and tagging out, and they are not authorized to do so.
• Other Employees include office or warehouse personnel who may work in an area where an energy control procedure is utilized.

The responsibilities of Affected and Other Employees are to recognize when energy control procedures are being implemented and to understand the purpose of these procedures. They must not attempt to start up or use equipment that has been locked or tagged out and must relay all such requests to the Authorized Employee on duty.

OSHA states that employees need to be trained to ensure that they know, understand, and follow the applicable provisions of the hazardous energy control procedures. The training must cover at least three areas: aspects of the employer's energy control program; elements of the energy control procedure relevant to the employee's duties or assignment; and the various requirements of the OSHA standards related to lockout/tagout.

Retraining is required when jobs, machinery, or energy control procedures change or inspection reveals program inadequacies. There are consultants and companies that offer LOTO training that help employers comply with OSHA requirements.

Unfortunately, lockout/tagout standards do not cover longshoring, construction, or agriculture. OSHA states that adequate training would be difficult for transient, short-term workers often employed in these settings. Additionally, energy control procedures might vary widely from one work site to the next, and a construction worker could be employed at several sites in a single year. And maintenance work on construction equipment requires the potentially hazardous positioning of buckets, blades, and vehicle body parts—safety issues beyond the scope of general industry energy control.

The Importance of the Hierarchy of Controls
Lockout/tagout programs and corresponding training have become popular topics of conversation as NFPA 70E nears the one-year mark of including the Hierarchy of Controls in its mandatory text for the first time. The Hierarchy of Controls is not a new concept, but this inclusion in the top source for best practices and procedures underscores how critical it is for organizations to have a firm understanding of the hierarchy, of which lockout/tagout finds itself a part.

The Hierarchy of Controls offers a systematic process for reducing the likelihood of an electrical incident. Its five hierarchy tiers start at the bottom with the controls perceived to be the least effective, which is protecting the worker with Personal Protective Equipment. It then moves up to those considered the most effective, such as Replacing the Hazard or Physically Removing the Hazard altogether. Administrative controls are found in the second tier from the bottom and according to OSHA are meant to change the behavior of workers, with examples including things such as training, procedures, policies, and installation of signs and warning labels. A lockout/tagout program is an example of an administrative control; these are mainly used alongside existing protocols where hazards are not well controlled.

For many organizations, these are the primary approaches to reducing workplace injuries. As a result, the safety of these workers relies on the controls being properly designed, maintained, and implemented by the staff. Warnings and signs can certainly help mitigate hazards, but the training employees receive to use these components can help prevent workplace injury even more.

OSHA has estimated that its lockout/tagout standard prevents 85 percent of the total number of injuries or fatalities from exposure to hazardous energy in the workplace. It estimated that approximately 31,900 minor (non-lost-workday) injuries, 28,400 lost-workday injuries, and 122 fatalities per year are prevented by the standard.

While the standard is great, it's the lockout/tagout programs and training that really deliver the safe results that organization and companies are looking for. Over time, equipment and operating procedures can change, but lockout/tagout programs will always play a critical role for organizations looking to avoid workplace injuries and to adhere to NFPA 70E, OSHA 1910 Subpart S, and OSHA 1926 Subpart K.

This article originally appeared in the June 2019 issue of Occupational Health & Safety.