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When Are Lockout/Tagout Procedures Not Required?

Read our guide to know when lockout/tagout procedures are not required by OSHA. If these criteria are met, you may not need to create a lockout procedure.

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Lockout/tagout processes are required by OSHA standard 1910.147 to ensure safety every time a piece of machinery is being serviced or tested. The goal of lockout/tagout is to isolate energy sources from equipment when it is being serviced, and confirm that these energy sources do not accidentally get turned on or have their stored energy released while the equipment is being serviced or repaired.

Keeping up with lockout/tagout is challenging for many facilities. In fact, OSHA’s lockout/tagout standard was one of the most cited regulations in 2022 for the 28th year in a row. In manufacturing, it continues to be the most cited regulation. Many manufacturing lockout programs are compliant at first, then become non-compliant over time as things change within their facilities and they get behind on updating procedures.

Remember that your machine-specific lockout procedures must be updated every time changes are made to your equipment. In addition, employees must be trained on these new procedures. Audits can be challenging to keep up with, but it’s critical to stay on top of your procedures so you can stay compliant and achieve a safe work environment for all of your employees.

It’s important to note that the lockout standard has eight criteria to determine what equipment requires lockout procedures.

Make sure to read each exemption criterion carefully before you decide not to move forward with a lockout/tagout procedure for any piece of equipment. For example, if you meet seven criteria but miss the eighth one, you risk getting a citation and, worse, putting your employees at risk of getting injured while a piece of equipment is being serviced.

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Lockout/Tagout Program Services

Our team of experienced engineers and specialists can help you create a simple, successful Lockout/Tagout Program customized to your needs.

Eight Exemptions to Lockout/Tagout as Defined by OSHA

Most machines in your facility likely need a documented lockout/tagout procedure. However, some machines are not required to have outlined lockout procedures in place.

As you go through your annual audit, review any machine that does not have a documented procedure. Then, see if that piece of equipment meets the following eight criteria for exemptions, according to OSHA standard 1910.47.

1. There is no potential for stored or residual energy

Shutdown ensures that there is no stored energy in a piece of equipment. A machine might be exempt if there is no possibility of any part of it containing or reaccumulating residual energy (such as capacitors, thermal sources or moving parts).

2. The machine has one easily isolated energy source

Whether the energy source is electrical, steam, compressed air, chemicals, water, fuels or something else, it must be the only source of energy for the machine. The energy source also needs to be easy to isolate.

3. Isolating the machine’s energy source completely deactivates and de-energizes it

Once the machine’s energy source is isolated, the machine must be completely deactivated and at a zero-energy state to qualify for an exemption from having a lockout/tagout procedure.

4. The machine must be locked out

The machine must be shut down, isolated from the energy source, and locked out while being serviced to be exempt from having specific lockout/tagout procedures.

5. Only one lockout device

The machine must be isolated and controlled using just one lockout device. If you need several devices to lock out a machine, then it is not exempt.

6. Exclusive employee control

The employee servicing or testing the machine must confirm that the device is under their exclusive control while they are working on the machine. If working with one or more authorized employees, a specific lockout procedure would be required.

7. No additional hazards

The employee working on the machine must do so without creating any additional hazards that could potentially cause harm or injury to other workers in the facility.

8. No prior accidents

Regardless of meeting all the above seven requirements for exemption, the company cannot have any previous accidents on the machine due to uncontrolled energy if it wants a particular machine to be exempt.

We Can Help You Stay Compliant

Lockout/tagout is a critical part of your company’s safety plan. Confirm you’re ready for your annual inspection by verifying that any machine that does not currently have a lockout/tagout procedure meets all eight of the above requirements. If it does not, then you must create and document a new process to stay compliant with OSHA’s standards and keep your employees safe.

The fact that lockout/tagout is one of the most frequent regulations cited by OSHA demonstrates that many facilities do not have the correct procedures in place. If you want to learn more about lockout/tagout or need some support implementing lockout/tagout procedures in your workplace, we can help.

Contact us today to learn more about how we can help you improve your lockout/tagout procedures to keep your workers safe and your company in compliance with OSHA regulations.

Published September 8, 2023

Topics: Safety Solutions Lockout Tagout Lifecycle Services

Jake Thatcher
Jake Thatcher
Senior Safety Project Engineer, Rockwell Automation
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