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Office of Risk Management

Environmental Health & Safety

Control of Hazardous Energy

The EHS program S-001 outlines measures for controlling hazardous energies by locking out-or tagging out (LOTO) equipment and machinery to protect against injury from electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources.

View the detailed program here 

 

Who is covered?

Any employee or student whose work or education involves hazardous energies while servicing or maintaining equipment—electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy sources will be covered by SMU’s Control of Hazardous Energy Program.

When does the program apply?

The program applies to the control of hazardous energy when employees are involved in service or maintenance activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining or servicing machines or equipment. These activities also include lubricating, cleaning or unjamming machines, and making adjustments or tool changes, where people may be exposed to hazardous energy.

If a service or maintenance activity is part of the normal production operation, the employee performing the servicing may be subjected to hazards not normally associated with the production operation itself. Workers doing service or maintenance activities during normal production operations must follow lockout/tagout procedures if they:

  • Remove or bypass machine guards or other safety devices,
  • Place any part of their bodies in or near a machine's point of operation, or
  • Place any part of their bodies in a danger zone associated with machine operations.

When does the program not apply?

The program does not apply to general industry service and maintenance activities in the following situations, when:

  • Exposure to hazardous energy is controlled completely by unplugging the equipment from an electric outlet and where the employee doing the service or maintenance has exclusive control of the plug. This applies only if electricity is the only form of hazardous energy to which employees may be exposed. This exception encompasses many portable hand tools and some cord and plug connected machinery and equipment.
  • An employee performs hot-tap operations on pressurized pipelines that distribute gas, steam, water, or petroleum products, for which the employer shows the following:
    1. Continuity of service is essential;
    2. Shutdown of the system is impractical; and
    3. The employee follows documented procedures and uses special equipment that provides proven, effective employee protection.
  • The employee is performing minor tool changes or other minor servicing activities that are routine, repetitive, and integral to production, and that occur during normal production operations. In these cases, employees must have effective, alternative protection. This exception is limited, however, and applies only when economic considerations prevent the use of prescribed energy-isolation measures and when the employer provides and requires alternative measures to ensure effective, alternative protection.

What if I use Contractors to perform the work?

If an outside contractor services or maintains machinery, SMU and the contractor must inform each other of their respective lockout or tagout procedures. SMU also must ensure that employees understand and comply with all requirements of the contractor's energy-control program(s).

What equipment must be Locked Out or Tagged Out?

Whenever the program is applicable, the machinery must be shut off and isolated from its energy sources, and lockout or tagout devices must be applied to the energy-isolation devices.

  • Use lockout devices for equipment that can be locked out.
  • Tagout devices may be used in lieu of lockout devices only if the tagout program provides employee protection equivalent to that provided through a lockout program.
  • Ensure that new or overhauled equipment is capable of being locked out. Develop, implement, and enforce an effective tagout program if machines or equipment are not capable of being locked out.
  • Be aware of and know how to handle situations such as; when machines or equipment must be tested or re-positioned, when outside contractors work at the site, in group lockout situations, and during shift or personnel changes.

Records Management

It is the managers responsibility to ensure the documents are kept up-to date, a copy stored at the LOTO station for employees to utilize (other than SF 001-1), and updated copies sent to the EHS group within the Office of Risk Management upon completion and revision.

  • SF 001-1 LOTO Documentation form is utilized each time maintenance or service is undertaken.
  • SF 001-2 LOTO Authorized Person form is a live listing of all persons authorized to perform maintenance or servicing on specific equipment.
  • SF 001-3 LOTO List of Procedures form is a live listing of all LOTO procedures in place within your department.
  • SF 001-4 LOTO New Specific LOTO Procedure form is a required instructional document to develop a new LOTO procedure.
  • SF 001-5 LOTO Emergency Lock Removal form is a required instructional document used to document the emergency removal of a LOTO device.
  • SF 001-6 LOTO Periodic Review form is an inspection document for the required periodic review of the Control of Hazardous Energy within your department.
  • SF 001-7 LOTO Annual Program Review is a document for the required annual review of the functioning of the Control of Hazardous Energy Program as it applies to the departments on campus.

Training

Training must ensure that employees understand the purpose, function, and restrictions of the energy-control program. SMU will provide training specific to the needs of "authorized," "affected," and "other" employees.

  • "Authorized" employees are those responsible for implementing the energy-control procedures or performing the service or maintenance activities. They need the knowledge and skills necessary for the safe application, use, and removal of energy-isolating devices. They also need training in the following:
    1. Hazardous energy source recognition;
    2. The type and magnitude of the hazardous energy sources in the workplace; and
    3. Energy-control procedures, including the methods and means to isolate and control those energy sources.
  • "Affected" employees (usually machine operators or users) are employees who operate the relevant machinery or whose jobs require them to be in the area where service or maintenance is performed. These employees do not service or maintain machinery or perform lockout/tagout activities. Affected employees must receive training in the purpose and use of energy-control procedures. They also need to be able to do the following:
    1. Recognize when the energy-control procedure is being used,
    2. Understand the purpose of the procedure, and
    3. Understand the importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked or tagged out.

All other employees whose work operations are or may be in an area where energy-control procedures are used must receive instruction regarding the energy-control procedure and the prohibition against removing a lockout or tagout device and attempting to restart, reenergize, or operate the machinery.

In addition, if tagout devices are used, all employees must receive training regarding the limitations of tags.

SMU will provide initial training before starting service and maintenance activities and must provide retraining as necessary. EHS offers this training online via SafetySkills. Please contact EHS to sign up for this training. It is the managers responsibility to ensure the applicable employees are trained and retrained in accordance with this program. Training on specific equipment LOTO procedures may be carried out by the department responsible for the maintained or serviced equipment. EHS is available to assist with this training, and retraining, when necessary.

EHS maintains and tracks EHS training logs. It is the managers responsibility to ensure any training or retraining sign in sheets or attendance logs are delivered to the ORM for credit and regulatory compliance. SMU must certify that the training has been given to all employees who will be servicing or maintaining equipment. The certification will contain each employee's name and dates of training.

SMU will provide retraining for all authorized and affected employees whenever there is a change in the following:
  • Job assignments,
  • Machinery or processes that present a new hazard, or
  • Energy-control procedures.

Retraining also is necessary whenever a periodic inspection reveals, or SMU has reason to believe, that shortcomings exist in an employee's knowledge or use of the energy-control procedure.