Effective training techniques for the Control of Hazardous Energy (Lockout/Tagout)

Every year employees are injured or killed on the job due to the unexpected energization or start-up of machines or equipment, or the release of stored energy. The Occupational Safety and Health Administration (OSHA) established regulations to address the control of this hazardous energy under 29 CFR 1910.147, which have become known as the lockout/tagout (LOTO) standards.

In the December 2024 issue of their Safety and Health magazine, the National Safety Council (NSC) discussed OSHA’s Top Ten Cited Safety Standards for fiscal year 2024. Lockout/Tagout appears at #5 on that list with 2,443 violations, which included 477 violations of the LOTO regulation’s training requirements.

OSHA publishes the “Top 10 List” to alert employers about these commonly cited standards so they can take steps to find and fix recognized hazards. Providing training on the requirements for controlling hazardous energy for all employees is paramount in reducing the LOTO statistics.

What are the training requirements for Lockout/Tagout?

OSHA defines the LOTO training and communication requirements in 29 CFR 1910.147(c)7. These are the steps to protect employees in the workplace, including authorized employees (i.e., those who service and maintain equipment), affected employees (i.e., those whose job requires them to operate or use the equipment), and all others who work in areas where the equipment or machines are located.

All employers are required to establish an energy control program consisting of energy control procedures, employee training, and periodic inspections to ensure that before any employee performs any service or maintenance on a machine or equipment where the unexpected energizing, start up, or release of stored energy could occur and cause injury, the machine or equipment must be isolated from the energy source, and rendered inoperative.

The training provided to employees must ensure that the purpose and function of the energy control program are understood and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees. Such training includes:

• Providing each authorized employee with the information necessary to recognize hazardous energy sources, the type and magnitude of the energy available, and the methods and means necessary for energy isolation and control. This includes the purpose and limitation of tags.
• Instructing affected employees on the purpose and use of the energy control procedure.
• Providing instruction about the procedure to all other employees whose work operations are or may be in an area where energy control procedures may be utilized, and that any attempt to restart or reenergize machines or equipment that are locked out or tagged out is prohibited.
• Retraining all authorized, affected, and other employees whenever there is a change in their job assignments, a change in machines, equipment, or processes that present a new hazard, or when new or revised energy control methods and/or procedures are introduced.
• Retraining to reestablish employee proficiency whenever a periodic inspection reveals that employees’ knowledge should be updated.

The employer is required to certify that employee training has been accomplished and is being kept up to date. This certification should contain each employee’s name and dates of training.

Helpful training techniques

Effective safety training presentations

When presenting employees with the information they need to know to carry out their jobs safely and comply with the LOTO regulatory requirements, materials should be easy to read or comprehend and should highlight why LOTO training is so important – to prevent injury and/or death by recognizing and controlling hazardous energy. It should also emphasize that disregarding or violating the energy control program could endanger their own lives or the lives of their coworkers.

Effective training maximizes learning and retention by utilizing various methods of providing the required information to employees, including:

• PowerPoints: Develop engaging presentations to identify and communicate the elements of the hazardous energy control program. Make sure the presentation is accurate, clear, practical, and credible.
• Handouts: Materials to take away that highlight key points.
• Exercises: Develop examples of hazardous control procedures and establish exercises around the procedure to identify the steps to properly control the hazardous energy.
• Case studies: Examples and scenarios of LOTO situations to help identify actions to take and actions to avoid when controlling hazardous energy.
• Videos: Use videos to present training or case study content but should not be the only means of learning.
• Evaluation and quizzes: Use tests and quizzes to reinforce knowledge learned from presentations, exercises, and other training techniques.
• Hands-on activities: Use hands-on training to ensure authorized employees have the necessary skills to apply, use, and remove energy controls on the machines and equipment at your facility.

Building procedures

The first step of an effective lockout/tagout training program involves establishing energy control procedures that are incorporated into an effective written Hazardous Energy Control Program. Each energy control procedure must include the following:

• A specific statement of the intended use of the procedure.
• The specific types of energy to be controlled and, in instances in which a common procedure is to be used, the specific equipment covered by the common procedure by type and location.
• Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.
• Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices and the responsibility for them.
• Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.

Providing employees with an understanding of how to recognize and control hazardous energy and actively involving them in the process of building effective energy control procedures can help eliminate hazards before an incident occurs and reduce the likelihood of an OSHA citation.