Taking a Deep Dive into the World of LOTO

Taking a Deep Dive into the World of LOTO

Procedures must keep pace with industry 4.0 smart manufacturing.

When it comes to taking the important first step in setting up your energy control procedures (OSHA’s lockout/tagout standard 1910.146), the sky is the limit. Lockout/tagout (LOTO) is a key safety program when working with any power source including electricity, hydraulic pressure, pneumatic pressure, water pressure, thermal energy and even pyrophoric chemicals that combust upon contact with the air.

As companies dive deep into the world of LOTO, their approach is usually comprehensive. What separates the rare few greats from the rest of the overworked industry is how the program proceeds from that point forward.


  • As facilities are upgraded, are LOTO procedures updated to reflect these changes?
  • Are specific isolation valves and electrical disconnects put in place for each new production line?
  • Are annual evaluations being conducted? The answer to that last question is frequently: No. Not many companies follow up on their annual evaluations, and only a fraction bring in a fresh set of qualified eyes to ensure the process is optimally completed. Why? Because the annual evaluation process tends to become yet another task for overworked safety professionals.

Enterprise growth can also become the root of many challenges, particularly if safety programs are not properly scaled. Growth outpacing safety programs is one of the main reasons the 1910.147 control of hazardous energy (lockout/tagout) is on the top 10 list of OSHA’s most cited standards year after year.

LOTO Enforcement

In the most recent year reported, fiscal year 2020, OSHA assessed a proposed $7.5 million dollars in penalties for violating the LOTO standard, making it the sixth most frequently cited agency standard. Food manufacturing, fabricated metal products, plastics and rubber products, wood products and primary metal manufacturing are the most heavily penalized industries.

More recently, in September 2021, OSHA proposed $1.67 million in fines for an Ohio aluminum parts manufacturer following an investigation into the death of a 43-year-old worker struck by a machine’s barrier door in March 2021. OSHA alleges the company allowed employees to bypass guarding mechanisms designed to protect them from the barrier door closing on them, and that a malfunction in the door's optic control existed prior to the deadly incident. The worker was loading a part into the machine when the barrier door closed, fatally injuring him.


This article originally appeared in the November/December 2021 issue of Occupational Health & Safety.

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