Safety always is the No. 1 concern in any work environment with hazardous machinery. The power sources for any hazardous energy source must be accessible and clearly identified as the correct choice for the equipment to be serviced. This is the very essence of why lockout/tagout procedures were developed.

While most managers realize that lockout/tagout has remained in the Top 10 most-cited regulations year after year, they often fail to recognize how their own company also might be as negligent as the companies involved in the startling statistics. In fact, if you’re reading this and you haven’t taken a hard look at your lockout/tagout program in the last 2 years, you can assume you are in the same boat.

Commonly Overlooked and Misunderstood Components

The first misunderstood component of lockout/tagout is the most basic: the "procedure" itself. Employers often believe they can get by without machine-specific lockout/tagout procedures for each piece, or without having any procedures at all. There’s a common, mistaken belief that as long as the employee is familiar enough with the equipment, nothing bad can happen. 

Many companies believe that simple equipment, such as exhaust fans, grinders, drill presses and the like do not require machine-specific procedures. To be exempt from having a machine-specific procedure, a given machine must meet eight criteria set by OSHA in CFR 1910.147(c)(4)(i), meaning that the vast majority of equipment definitely will need its own procedure. 

So how much is "vast majority?" Assume 90 percent or more of all your equipment and you’ll be close; 95 percent or more and you’re closer. Remember, non-lockable energy such as kinetic and gravity count as secondary sources. 

Another important and overlooked aspect is failing to consistently audit and update employee training and lockout/tagout procedures. When any part of the equipment or layout changes, the procedures and associated employee training must be evaluated and updated as necessary. Businesses often try to save costs by keeping the same system in place, year after year, even as employees and equipment change, leaving their lockout/tagout procedures woefully out of date.

Circling back to the most commonly overlooked aspect of lockout-tagout – the procedures themselves. 

Most-Likely Deficiencies

The most-obvious way in which businesses are deficient is an attitude that says, "Preventing these accidents would be cost-prohibitive." This demonstrably is false.

Lockout/tagout violations consistently are in the list of the 10 most-cited regulations by OSHA every year. Businesses who try to cut costs by skimping on safety with lockout/tagout are inviting disaster, in more ways than one. The important thing to remember is that when neglecting lockout/tagout procedures, it's not an accident; it's an incident. When something is 100 percent preventable by the use of established rules and equipment, it is no accident when it happens. Incidents are completely predictable and completely preventable.