Question

Is lockout/tagout (LOTO) required in construction?

Answer
By Maurizio Delcaro | Last updated: November 16, 2022

Lockout/tagout (LOTO) is a General Industry OSHA standard that applies to "the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees.”

The General Industry LOTO standard and its appendix are about 5,000 words long, which is an indication of just how important this issue is. If an industrial machine starts up while an employee is working on (or inside) it, then the incident is likely to result in a fatality or serious injury.

Given the severity of these events, it's not surprising that OSHA gives little leeway to employers over LOTO violations – and the monetary penalties can be punitive.

LOTO Regulations Applicable to the Construction Industry

Technically, lockout/tagout doesn't apply to construction activity. It would be highly unusual for construction workers to service the types of industrial devices that require LOTO procedures. Conveyor belts in a pretzel factory, sure. Milling machines in an engine block plant, too. But not the tools used by the the people showing up to the construction site.

When devices and machines that require LOTO are involved, they're operated by machine operators and serviced by repair professionals, not carpenters or the people working the controls on the mobile crane. So, there's no need for OSHA to apply universal LOTO requirements to construction.

Still, that doesn't mean there are no LOTO guidelines that apply to the construction industry.

The 29 CFR 1910.147 lockout/tagout standard doesn't regulate construction activity, but OSHA does have some universal precautions for construction that address the control of hazardous energy, which can be found at 1926.417. Because construction activity doesn’t involve the types of industrial machinery found in factories, the s

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tandards applicable to the control of hazardous energy in construction activity are far less expansive – less than 100 words. It can be summarized as follows:

If a control that governs the delivery of electrical power to equipment or circuits is required to be deactivated in order to do the work on the equipment (or circuits), then the control needs to be tagged. The tag signals to others that the control is deactivated, and that the equipment is out of commission.

It's important to note that de-energizing the equipment (or circuits) isn’t enough – it must also be “rendered inoperative.” OSHA used this particular wording to indicate that methods other than lockout are permissible (as long as they’re effective). In a letter of interpretation, OSHA used removing a fuse or physically disconnecting a plug as two examples of rendering a device inoperative. Communication is key, so tags must also be attached at all points where the electrical equipment or circuits can be energized.

(Find out How to Build a Lockout/Tagout Policy to Prevent Tragic Outcomes.)

In-House LOTO Programs

The 1926.417 standards apply to electrical equipment and installations used to provide electric power and lighting at construction sites, not electrically-powered tools. So, there’s no requirement to tag a circular saw that needs repair, though there’s nothing stopping you from using tags as an extra precaution.

However, remember that if you go above and beyond the OSHA standards and use an in-house tagging system, your procedure needs to be understood by everyone on site. Uniformity in your lockout/tagout practice is essential.

State OSHA Standards

Also, be aware that State OSHA programs can write standards that reach beyond those of Federal OSHA. When you have a construction project in a state that has its own OSHA program, take the time to review their standards to see if you'll need to comply with any additional provisions – for lockout/tagout or anything else.

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Written by Maurizio Delcaro

Maurizio Delcaro

Maurizio believes that a commitment to operational efficiency at all levels of management is the greatest factor in maximizing safety and productivity. His EHS and risk management experiences include transportation, construction, environmental remediation, and OSHA, and he moonlights as a part-time university instructor. Maurizio is credentialed as a CSP, CET, OHST, and CHST with the Board of Certified Safety Professionals and CEHT with the National Environmental Health Association.

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