Is lockout/tagout (LOTO) required in construction?

Q:

Is lockout/tagout (LOTO) required in construction?

A:

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 involve a fatality or serious injury. OSHA has historically granted little leeway to employers when LOTO violations are identified, and monetary penalties can be punitive.

(Read about How to Build a Lockout/Tagout Policy to Prevent Tragic Outcomes.)

Nominally, LOTO does not apply to Construction activity. It would be highly unusual for construction employees to service the types of industrial devices to which LOTO applies, such as conveyor belts in a pretzel factory or milling machines in an engine block plant. The devices and machines within the parochial realm of LOTO are operated by machine operators and/or service and repair professionals, not carpenters or mobile crane operators. So, there’s not a universal need for OSHA to apply the LOTO requirements to construction.

(Learn about Lockout/Tagout in Construction: What You Need to Know.)

Though the LOTO standards found at 29 CFR 1910.147 don’t apply to construction activity, OSHA does have some universal precautions for construction that address the control of hazardous energy; these precautions are found at 1926.417. Because construction activity doesn’t involve the types of industrial machinery found in factories, the standards applicable to the control of hazardous energy in construction activity are far less expansive; less than 100 words. This guidance 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; they must also be “rendered inoperative.” OSHA used this particular wording to indicate that methods other than lock-out are permissible (as long as they’re effective). In a letter of interpretation, OSHA stated that removing a fuse or physically disconnecting a plug are two examples of rendering a device inoperative. Tags must be attached at all points where the electrical equipment or circuits can be energized. Communication is key.

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 for this purpose. However, if going above and beyond the OSHA standards and using an in-house tagging system, it’s crucial that your procedure is understood by all and there’s uniformity in practice.

Please note that State OSHA programs can write standards that reach beyond those of Federal OSHA. When conducting construction activity in a State with its own OSHA program, it’s prudent to review their standards to learn whether you’ll need to comply with additional provisions with LOTO and any other actions the State requires for Construction activity, but that Federal OSHA requires only in General Industry workplaces.

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Written by Maurizio Delcaro
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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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