Lockout/Tagout Corporate Policy: Necessary Components for Compliance

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ESC Services Corporate Policy The policy should be specific and should list who is responsible for which aspects of the program, define which employees are considered authorized, and include samples of the site-specific lockout/tagout procedures."

A lockout/tagout corporate policy is an essential component for a lockout/tagout program; it outlines the rules and expectations regarding the energy control program.

Often times, companies make the mistake of creating a generic policy simply to meet OSHA compliance requirements. However, using a policy that has not been customized to the needs of the facility defeats the purpose of having a written policy in the first place.

The policy should be specific and should list who is responsible for which aspects of the program, define which employees are considered authorized, and include samples of the site-specific lockout/tagout procedures.

To confirm a compliant and useful policy, the following components must be included and tailored to each company’s program.

General Information

  • Define the scope of work being covered. What work is covered by the policy, who is affected by the policy, and when should lockout/tagout be utilized.
  • Include a list of definitions. This list should be similar to the one from OSHA’s 1910.147 standard but should also include any definitions specific to the site.
  • Define the expectations for lockout/tagout procedures. Determine what type of equipment requires a procedure, who is responsible for creating and maintaining them, and which employees are allowed to use the document.

Equipment Servicing

  • List general shutdown and restore steps. Certain steps must be taken prior to servicing equipment, including notification, normal shut off, application of locks, and proper verification that the system is in a zero-energy state. Similarly there should be a list of steps to be taken before returning the system to normal operating conditions.
  • Explain the process for testing or repositioning the equipment during lockout/tagout. At times it may be necessary to partially reenergize the system during servicing in order to test or inspect the machine. Specific steps of how to do so should be included.
  • Standardize the lockout devices to be used. It is the responsibility of the employer to provide adequate locks, tags, and devices to be used solely for lockout/tagout. They must be standardized by color, shape, or size and must be made of durable, substantial materials.

Employee Training

  • Outline the expectation for employee training. Before a lockout is ever administered, every authorized employee must be trained in proper execution of lockout/tagout and have general knowledge of the process and affiliated hazards. Affected employees must also participate in awareness training.

Annual Review

  • Include provisions for periodic inspection of lockout procedures. At least annually, all lockout/tagout procedures must be audited to confirm compliance. Changes to the equipment must be reflected in the energy control procedures and the record of the annual audit must be documented.
  • Include provisions for annual review of authorized employees. Authorized employees must be audited annually to guarantee they still have full comprehension of lockout/tagout. Annual refresher trainings are not sufficient; auditors must observe employees locking out equipment to be sure procedures are followed and correct devices/locks are applied. If necessary, employees found to be deficient in understanding must be retrained.
  • Include provisions to review program effectiveness. During the annual audit, the overall program should be reviewed. If major changes have taken place to the program, the corporate policy must be updated. If the program is not effective, a deeper investigation should take place to determine what trainings or cultural changes need to take place to improve employee safety.

Special Circumstances

  • Cover guidelines for contractors performing lockout/tagout. In the case of outside personnel, it is the responsibility of the employer to decide who’s lockout/tagout procedure to use. Contractors should be briefed on the employer’s lockout/tagout policy prior to beginning work.
  • Explain how to perform group lockout. When multiple workers are servicing the same piece of equipment, it is important to assign a Person-In-Charge who will be responsible for the continuity of work. Each person involved must be given an equal level of protection by applying their own lock to prevent unexpected re-energization.
  • Address continuity of the lockout during shift change. When servicing will last several days and involve authorized employees from different shifts, specific guidelines must dictate how the continuity of the lockout will be safely achieved.
  • Steps to be taken in the event of emergency lock removal. In the event that a lockout lock needs to be removed by an individual other than the one who attached it, there must be a system in place to contact the authorized employee prior to a supervisor removing the lock.

Policy Enforcement

  • Include detailed means of enforcement. The policy should discuss how the employer will enforce the policy and what the repercussions will be for those who fail to comply.

When questions arise regarding the control of hazardous energy regulation, a lockout/tagout corporate policy should be the first place to look for answers. When written properly, the lockout/tagout policy will clearly outline how to maintain safety and compliance when servicing equipment.

For assistance writing or reviewing a lockout/tagout corporate policy, contact us.

About Ashley Reyes
Ashley Reyes is the Engineering Operations Manager with ESC Services, a Rockwell Automation business. She manages the field engineering team and has previously managed several lockout/tagout implementation projects for many large companies in the US and Internationally. Ashley has worked in many different industries including general manufacturing, pharmaceutical manufacturing, and food processing.