Perform Periodic Reviews of LOTO Procedures – Safetip #217

Safety Tip and Best Practice
August 19, 2020

Our latest Safetip is about performing periodic reviews of lockout/tagout (LOTO) procedures and verifying that employees are following energy control procedures.

In 2019, OSHA’s LOTO standard was the fourth most frequently cited standard. Moreover, the LOTO standard has been consistently in the top five for the last five years.

An effective LOTO program is not just about safety, it’s also about compliance, which is why it’s a good idea to conduct periodic reviews of LOTO procedures.

Review Procedures

The Washington State Department of Labor & Industries has published safety standards for lockout/tagout. The document is a great source of good practices.

One of them consists of conducting periodic reviews of procedures using lockout or tagout devices.

If a review involves lockout devices, the reviewing employee should review responsibilities with each authorized employee who uses the procedure. The reviews of authorized employees using procedures involving only lockout devices can be done in a group meeting, if desired.

If a review involves tagout devices, the reviewing employee should review the following with each authorized and affected employee:

  • Employee responsibilities under the procedure
  • Limitations of tagout devices

Unlike procedures involving lockout devices, the reviews of authorized and affected employees using procedures involving tagout devices have to be done with each employee individually, not in a group meeting, the standards say.

Verify Employee Knowledge

The Washington State safety standards for LOTO also include periodic reviews to verify that employees know and follow energy control procedures. There must be a periodic review at least annually to:

  • Make sure that employees know and can apply the energy control procedures
  • Correct any deviations or inadequacies identified

In addition, the periodic review must be done by an authorized employee other than the ones using the energy control procedure being reviewed. You must also document that periodic reviews have been done by including the following information:

  • Machine or equipment the energy control procedure was used for
  • Date of the review
  • Employees included in the review
  • Person doing the review

Finally, consider using a mobile app so you can conveniently perform the reviews from anywhere and at any time, online or offline. This is much better than taking notes and then manually entering the information in a system.

Our Safetips share safety tips or best practices that contribute to safety excellence. Visit our blog regularly for new Safetips!

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