6.2 Lockout/Tagout Procedural Steps & Stored Energy Isolation
Key Takeaways
- 29 CFR 1910.147(c)(4) requires written, machine-specific energy control procedures detailing specific steps for shutdown, isolation, device placement, stored energy control, and testing verification.
- An employer is exempted from documenting a written LOTO procedure for a specific machine ONLY if all eight single-energy-source criteria under 1910.147(c)(4)(i) Note are completely satisfied.
- The 7-Step LOTO Shutdown Sequence must follow an exact chronological progression: Preparation, Notification, Shutdown, Isolation, LOTO Application, Stored Energy Dissipation/Restraint, and Verification of Isolation.
- Stored residual energy in hydraulic accumulators, compressed air receiver tanks, charged capacitors, and elevated gravitational dies must be bled, vented, grounded, or mechanically blocked prior to entry.
- Equipment restoration following LOTO must strictly adhere to the 5-step sequence under 1910.147(e): Machine Inspection, Employee Notification/Positioning, Device Removal by Applicator, Affected Employee Notification, and Energy Restoration.
6.2 Lockout/Tagout Procedural Steps & Stored Energy Isolation
Machine-Specific Energy Control Procedures (1910.147(c)(4))
Under 29 CFR 1910.147(c)(4), procedures must be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in activities covered by the standard. Procedures must clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized, including but not limited to:
- A specific statement of the intended use of the procedure.
- Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment to control hazardous energy.
- Specific procedural steps for the placement, removal, and transfer of lockout devices or tagout devices and the responsibility for them.
- Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.
The Single Energy Source Documentation Exception
Paragraph 1910.147(c)(4)(i) Note provides a narrow documentation exception. An employer does not need to document a written energy control procedure for a specific machine or equipment only when all eight of the following conditions exist:
- The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees.
- The machine or equipment has a single energy source which can be readily identified and isolated.
- The isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment.
- The energy source is isolated from the machine or equipment and locked out during servicing or maintenance.
- A single lockout device will achieve a locked-out condition.
- The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.
- The servicing or maintenance does not create hazards for other employees.
- The employer has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
The 7-Step LOTO Shutdown Sequence
Executing Lockout/Tagout requires strict compliance with a sequential 7-step shutdown protocol to establish a Zero Energy State before any servicing commences:
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| 7-STEP LOTO SHUTDOWN SEQUENCE |
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| Step 1: Preparation for Shutdown (Identify energy types, hazards, & controls) |
| Step 2: Employee Notification (Notify affected employees of impending LOTO) |
| Step 3: Machine Shutdown (Orderly shutdown using operational controls) |
| Step 4: Machine Energy Isolation (Operate disconnect switches, valves, blinds) |
| Step 5: LOTO Device Application (Attach locks/tags to isolation devices) |
| Step 6: Stored Energy Dissipation & Restraint (Bleed, vent, ground, block) |
| Step 7: Verification of Isolation (Test start controls & electrical meters) |
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Step 1: Preparation for Shutdown
Before an authorized employee turns off a machine or equipment, they must possess comprehensive knowledge of the type and magnitude of energy, the hazards of the energy to be controlled, and the specific method or means to control the energy.
Step 2: Notification of Affected Employees
Affected employees must be notified by the authorized employee prior to the application of lockout or tagout devices, informing them that energy control measures are being implemented.
Step 3: Machine or Equipment Shutdown
The machine or equipment must be turned off or shut down using the established, orderly procedures (e.g., depressing stop buttons, opening control switches, closing valves) to prevent hazard escalation.
Step 4: Machine or Equipment Energy Isolation
All energy isolating devices (e.g., main circuit disconnect switch, line valve, circuit breaker, blind flange) necessary to control energy to the machine must be physically located and operated to isolate the equipment from its energy sources.
REGULATORY DEFINITION: An Energy Isolating Device is a mechanical device that physically prevents the transmission or release of energy (e.g., a manually operated electrical circuit breaker, a disconnect switch, a line valve, a block). Push buttons, selector switches, and software control loops are NOT energy isolating devices under 1910.147(b).
Step 5: Lockout or Tagout Device Application
Authorized employees must attach lockout or tagout devices to each energy isolating device in the off or safe position. Lockout devices must hold energy isolating devices in a neutral or "off" position.
Step 6: Stored Energy Dissipation and Restraint
Following device application, all potentially hazardous stored or residual energy must be safely relieved, disconnected, restrained, or otherwise rendered safe:
- Hydraulic / Pneumatic: Bleed pressure lines and drain fluid/air receivers.
- Capacitors: Discharge electrical capacitors using certified grounding sticks.
- Gravitational Potential: Install mechanical safety blocks, pins, or hold-down chains on elevated rams, dies, or counterweights.
- Springs: Release spring tension or mechanically block spring-loaded mechanisms.
- Thermal: Allow thermal lines to cool and vent pressure relief lines.
Step 7: Verification of Isolation (Zero Energy State Verification)
Prior to starting work on equipment that has been locked out, the authorized employee must verify that isolation and deenergization have been accomplished:
- Operates operating controls (push buttons, selector switches) to confirm the machine cannot be restarted. Controls must be returned to the off/neutral position after testing.
- Performs electrical testing using a calibrated, zero-verified multimeter (Test-Verify-Test protocol under Subpart S) on electrical conductors.
- Checks pressure gauges, sight glasses, and bleed valves to confirm zero hydraulic/pneumatic pressure.
Dissipating and Restraining Stored Energy Types
| Energy Category | Stored Energy Hazard | Control & Restraint Technique |
|---|---|---|
| Hydraulic Accumulators | Residual high-pressure oil trapped in accumulator spheres. | Open manual bleed valves to tank; observe pressure gauges drop to zero. |
| Elevated Mechanical Rams | Gravitational potential energy capable of crushing workers. | Insert engineered steel safety blocks or locking pins beneath ram die before entering. |
| Compressed Air Receiver Tanks | Trapped pneumatic pressure in supply piping. | Close main supply ball valve; open manual line drain cock until airflow ceases. |
| Electrical Capacitor Banks | Stored electrical charge remaining after main breaker opened. | Apply high-voltage grounding hooks/discharge rods to physical terminals. |
| Tensioned Mechanical Springs | Compressed or stretched springs holding mechanical force. | Mechanically release tensioning screws or install physical containment cages. |
The 5-Step Machinery Restoration Sequence (1910.147(e))
Before lockout or tagout devices are removed and energy is restored to the machine or equipment, authorized employees must complete the following mandatory 5-step restoration protocol:
- Inspect Machine and Work Area: Check the work area to ensure that non-essential items (tools, spare parts, equipment) have been removed and that machine components are operationally intact.
- Verify Employee Positioning: Check the work area to ensure that all employees have been safely positioned or removed from the hazard zone.
- Remove LOTO Devices: Each lockout or tagout device must be removed from each energy isolating device by the authorized employee who applied the device (subject to the emergency removal exception under 1910.147(e)(3)).
- Notify Affected Employees: Ensure affected employees are notified that lockout or tagout devices have been removed prior to restarting the equipment.
- Restore Energy and Start Equipment: Reenergize energy isolating devices, remove line blinds, and perform operational testing.
Which condition is REQUIRED for an employer to utilize the written procedure documentation exception under 29 CFR 1910.147(c)(4)(i) Note?
What is the critical final step (Step 7) of the LOTO shutdown sequence before an authorized employee begins servicing a machine?
How MUST gravitational potential energy in an elevated mechanical press ram be controlled during maintenance under 29 CFR 1910.147(d)(5)?
Under 29 CFR 1910.147(e)(3), who is designated as the PRIMARY person authorized to remove a lockout device during equipment restoration?