Lockout/tagout procedure example: how to write one for a machine, step by step

The four things every procedure must say

The rule is 29 CFR 1910.147(c)(4)(ii). It says the written procedure has to clearly and specifically outline four things. Everything else in a good procedure is there to make these four easy to follow.

1. What it is for. The machine, by name and location, and the work it covers. "Baler BAL-02, shipping dock, all servicing and clearing of jams."
2. The steps to shut down, isolate, block and secure it. Every energy source, with the exact isolation point for each. Not "turn off power." "Circuit breaker CB-7, gray box on the wall 3 ft left of the baler, handle to OFF."
3. The steps to put on, take off and hand over the locks and tags, and who is responsible for them. Who locks, where, and what happens at shift change.
4. How to test that it worked. What button to press, what should happen (nothing), and what to look at to be sure.

There is an exception in the rule for machines with one energy source that is easy to see and lock, with no stored energy and no history of accidents, where locking that one point shuts everything down. All eight conditions have to be true at once, and very few machines in a real shop pass that test. Write the one-page procedure anyway. It takes less time than the argument with the inspector.

A finished example: vertical baler

This is the kind of machine that hurts people in warehouses and stores every year, and the kind many shops have never written a procedure for. Made-up facility, real energy sources. The format is the one we use: a two-sided placard posted on the machine, with a photo of the machine and of every isolation point.

How to write yours in an afternoon

1. List the machines. Anything someone will ever reach into, work under, or open up: conveyors, presses, compressors, mixers, saws, packaging lines, dock levelers, HVAC units, the big panel. One procedure per machine, or one per identical model if the isolation points are the same.
2. Walk each one with the operator and the mechanic. The operator knows what it does when it's running. The mechanic knows what it does when it isn't. Find every kind of energy: electrical, hydraulic, pneumatic, mechanical springs and flywheels, gravity, heat, steam, chemicals, water.
3. Find the isolation point for each one. The disconnect, not the e-stop. The air supply valve and the bleed, not the regulator. The valve you can lock, not the one you hope stays closed. Number them and put a tag on the machine at each one so the procedure and the machine match.
4. Take the photos. One of the machine, one of each isolation point with the lock on it. A photo settles "which gray box" forever.
5. Write the steps in the order you'd do them. Notify, shut down, isolate, lock, release stored energy, verify. Then the restore steps. Short sentences. A new mechanic should be able to follow it without asking.
6. Try it. Lock the machine out using only the paper. If you had to ask someone anything, fix the paper. Then press start with it locked. This is the verification step and it is the one that catches the backfeed, the second disconnect, and the capacitor nobody mentioned.
7. Post it on the machine, and keep the master. The posted copy is for the person with the lock. The master, with the revision date and the annual inspection record, is for you and the inspector.

Locks, tags and who holds the key

• Lockout locks are for lockout only. Not the toolbox, not the gate. Standardized by color or shape so everyone recognizes them, durable enough for the environment, and strong enough that taking one off takes bolt cutters, not a screwdriver. 1910.147(c)(5).
• Every lock says whose it is. Name on the tag or on the lock. One key, in that person's pocket. Nobody gets a spare.
• One lock per person. If four people are inside the machine, there are four locks on the hasp. Nobody's safety depends on someone else remembering they're in there.
• A tag warns. A lock holds. Tagout alone is only allowed when the isolating device physically cannot be locked, and then you have to add something that does the same job: pull a fuse, block a valve handle, remove a coupling. 1910.147(c)(3).
• Only the person who put a lock on takes it off. If they went home with the key, the rule has a path for removing it (1910.147(e)(3)): verify they are not in the plant, make every reasonable effort to reach them, and make sure they know before they come back to work. Write that path into your program and use it rarely.

The annual inspection nobody does

Once a year, for every procedure, an authorized employee who is not the one using the procedure watches someone lock out the machine with it, and reviews the procedure with each person authorized to use it. Then you write down the machine, the date, who was included, and who did the inspection. That is 1910.147(c)(6), and it is the paragraph most often cited after a lockout injury, because it is the one that would have caught the procedure that didn't match the machine anymore.

The practical way: put every machine on a calendar, two or three a month, and have the inspection be the retraining. Fifteen minutes at the machine with the paper in hand. Fix what's wrong the same day.

Training: three kinds of employees

Retrain when the job changes, the machine changes, the procedure changes, or the annual inspection shows somebody doing it wrong. Keep a record with the name and the dates. 1910.147(c)(7).

Shift changes, crews, contractors and cords

• Shift change. The lock stays on. The incoming person puts theirs on before the outgoing person takes theirs off. Write that handoff into the procedure. 1910.147(f)(4).
• Crews. Group lockout: one person is in charge, a group lock box or hasp holds the machine, and every person on the crew still has their own personal lock on the box. 1910.147(f)(3).
• Contractors in your plant. You tell them your procedures. They tell you theirs. Your people follow whatever the contractor's lockout requires while they're there. Put it in the pre-job meeting and write down that it happened. 1910.147(f)(2).
• Cord-and-plug tools. Unplugging counts, if the plug stays in the hands of the person doing the work. A plug in the wall across the room doesn't. 1910.147(a)(2)(iii)(A).
• Minor adjustments during production. The rule allows them without lockout only when they are routine, repetitive and part of running the machine, and the machine has some other protection built in, like a guarded jog control. "We do it all the time" is not that. Most jam clearing needs the lock.
• Testing with power on. Sometimes you have to energize to position something. The rule gives the sequence: clear tools and people, remove the locks, energize and test, then isolate and lock again before the work continues. 1910.147(f)(1).

What about construction?

1910.147 is a general industry rule. On a construction site OSHA enforces lockout through the construction standards: 1926.417 for electrical circuits and equipment (deenergized equipment rendered inoperative and tagged at every point where it could be energized), 1926.702(j) for concrete and masonry equipment like mixers, pumps and screens (locked out and tagged, tag reads "Do Not Start"), and the general duty clause for everything else. The expectation is the same thing you just read: a known isolation point, a lock, and a test. If your contracting business also has a shop, a yard with a crusher, or a fleet bay, that part is general industry and 1910.147 applies to it directly.

Mistakes we find on the first walk-through

• A lock on the e-stop or the control switch. The machine is stopped, not isolated.
• One lock for the whole crew, held by the lead. The person inside has nothing protecting them.
• No verification step. Isolate, lock, reach in. The second disconnect on the other side of the wall was still on.
• The procedure is in a binder in the office. Nobody on second shift has seen it.
• The machine was modified and the procedure wasn't. A new air cylinder, a new feed, a new disconnect.
• The annual inspection has never happened, or it's a signature on a form and nobody went to the machine.
• Contractors doing work on your equipment without being told about your procedure, and your people not told about theirs.
• Someone else's lock cut off because they went to lunch.

Questions we get

Not sure how this applies to your work? Ask the 29Safety safety team in the chat, or email safetyteam@29safety.com.