Clients often require contractors to use their existing lockout/tagout (LOTO) program while performing work activities such as:

• Adding new conveyors, equipment, or machines;
• Renovating a current work area;
• Demolition work;
• Building new workspaces and facilities; or
• Connecting new and old utilities.

Utilities, equipment, machines, and HVAC systems often have sources of hazardous energy that require isolation during demolition and construction activities to keep contractor employees safe. Your client will perform the de-energization and initial energy isolation by applying its LOTO procedure and then require your workers to lock onto its group lockout box.

Contractors must become familiar with OSHA’s Control of Hazardous Energy (lockout/tagout) standard, section 1910.147, which doesn’t typically apply to construction work apart from clients requiring its use. Instead, contractors doing construction follow §1926.417, Lockout and tagging of circuits, which requires contractor employees to:

• Deactivate controls,
• Render de-energized equipment and circuits inoperable, and
• Place a control tag at all points of energization.

The issue contractors face is that OSHA’s construction standard for controlling hazardous energy isn’t detailed enough to cover situations involving existing equipment in their client’s facilities.  Construction workers don’t usually service and maintain equipment (like a service technician does), so LOTO requirements aren’t as stringent in the construction industry.

To complete the steps above, contractors need to apply their client’s LOTO procedure in most cases. Contractors who use their client’s LOTO procedure will cover the three construction LOTO steps above, but §1910.147 has more stringent requirements like written energy control procedures, specific employee training, and periodic inspections to ensure safe work. While using your client’s LOTO program, three common issues that workers will likely encounter are:

• Using a single energy control procedure for multiple machines,
• Training for work that involves electrical hazards, and
• Conducting inspections.

Contractors don’t always have hazardous energy exposure from the client’s facilities throughout all construction phases, partly contributing to the misuse of LOTO procedures. LOTO is unnecessary when there isn’t an unexpected start-up or stored energy hazard. A better practice is to follow standard operating procedures (SOPs) during certain phases of construction where exposure to these electrical hazards doesn’t exist.  

Using one procedure for multiple machines or equipment

Your client’s facility may have many similar machines and equipment that require isolation from hazardous energy sources during demolition and construction. Per §1910.147, your client can use one hazardous energy control plan for all similar equipment and machines.

Your client’s procedure must include enough detail and provide enough direction so your employees can follow it and safely perform their work. If the procedure is too generic, it will not be useful. To be covered by one procedure, the machines or equipment must have the same:

• Specific procedural steps for shutting down, isolating, blocking, and securing them to control hazardous energy;
• Specific procedural steps for the placement, removal, and transfer of lockout or tagout devices and the responsibility for them; and
• Specific requirements for testing to determine and verify the effectiveness of lockout/tagout devices and other control measures.

Ensure your client’s procedure provides instructions that specify a step-by-step approach on each type of machine and equipment. Your client will be familiar with their equipment and machines. Still, your workers will need to understand these instructions too so they can verify the client has taken proper steps to shut down, isolate, or block hazardous energy sources before applying their locks to the group lockout box. Both you and the client will have LOTO responsibilities, so communicate and clarify as much as necessary.

Training to handle electrical hazards

Ensure your workers have had the proper training required by OSHA’s electrical safety standards. If you’re applying your client’s LOTO procedures, your workers may need additional training to verify an electrical circuit has been de-energized.

Employees who perform lockout/tagout require training as authorized employees. An authorized employee can apply an energy-isolating device and lock to a machine or equipment or a lock to a lockout box. However, an authorized employee cannot verify that an electrical circuit is de-energized. Doing so requires training as a qualified person.

The electrical standards require that a qualified person verify, using test equipment, that the circuit elements and equipment parts have been de-energized. Whether an employee is qualified depends on the circumstances and the equipment involved. An individual can be “qualified” on certain equipment in the workplace, but “unqualified” on other equipment. The energy control procedure for equipment with electrical hazards should include steps to lock out all energy sources safely.

For example, before digging up a client’s concrete floor where known electrical utilities exist or before starting demolition activities, your qualified person needs to verify electrical circuits have been de-energized by the client. Applying energy-isolating devices and locks without this verification and only verbal confirmation from the client can be fatal to your workers.

Applying group LOTO and performing inspections

Although not discussed explicitly in OSHA’s construction standards, group LOTO situations are common in existing facilities. Your client will require your workers to apply a lock onto a group lockout box. Here are two safety tips to consider while using group LOTO procedures at your client’s facility:

1. Use group LOTO procedures while multiple employees have exposure to start up or the release of stored energy hazards, and
2. Take responsibility to affix your LOTO device to the group lockbox or energy isolating device.

You don’t want workers trying to tie in systems, equipment, machines, or utilities that the facility owner’s employees just re-energized.

Performing inspections

The lockout standard requires your client to periodically inspect each energy control procedure at least once a year. If you have short-term work at your client’s facility, they may use their periodic inspection program to ensure your employees follow their LOTO program properly. Some clients even require contractors to self-perform an inspection and provide it with the results afterward.

If your client categorizes machines and equipment, they may ask you to inspect a representative number of your authorized employees performing the LOTO procedure within each category. The sampling must reasonably reflect the energy control practices for the procedure under inspection. If the client uses one procedure for several machines, they may ask you instead to select different machines from the group for evaluation.

Navigating your client’s LOTO program doesn’t need to be cumbersome when they ask your workers to follow their LOTO procedures. Proper training, safety procedures, and inspections can help you prevent accidents and keep your employees safe during demolition and construction activities at your client’s facility.