Non-negotiable
Most employers have some type of program or procedures for the control of hazardous energy (COHE) – better known as “Lockout/Tagout” (or simply LOTO) because it is mandated by federal workplace laws.
But more importantly, controlling hazardous energy prevents serious injuries including fatalities from the release of hazardous energy or unexpected equipment startup during work activities.
This critical element of a company’s overall health and safety program is not simply an optional or recommended practice. It is non-negotiable. Every year in the U.S., countless workers are seriously injured or killed because they gambled with their lives by performing equipment repairs or other tasks without a LOTO in place or by using inadequate LOTO programs.
Tragic Statistics
This tragedy is validated through OSHA’s annual top ten violation report that consistently includes the lack of adequate LOTO practices. During 2024, LOTO violations took third place with 2967 citations issued for violating 29CFR1910.147.
Unfortunately, this negative safety trend isn’t limited to only 2024, as LOTO infractions have been consistently listed in OSHA’s Top Ten list over the last several decades.
What Makes A Good LOTO Program?
Employers who understand their responsibilities and obligations for worker safety have implemented good LOTO procedures to control hazardous energy by following OSHA regulations. But many of these programs were likely developed in accordance with only 29CFR 1910.147, Subpart J ‘The Control of Hazardous Energy (Lockout/Tagout)’ found under OSHA’s General Industry regulations.
Furthermore, many EHS safety professionals may have also attended an OSHA 7115 course offered by one of the OSHA Training Institute (OTI) Education Centers to aid them in what they believe to be an adequate COHE/LOTO program.
While this may seem to be sufficient and a prudent choice, it may not be effective or compliant when dealing with electricity.
This is because electrical energy has unique hazards that warrant additional precautions, safety practices, skill sets, and qualifications. This fact must lead us to the invariable question, “Are there further prescriptive actions needed when controlling electrical energy?”
The simple answer is “yes.” But this will require us to mine through a comprehensive review of all pertinent OSHA regulations and other applicable standards, where we’ll find a more comprehensive answer to this very important but often unrecognized question.
By limiting ourselves to only 1910.147 Subpart J and/or attending an OSHA 7115 course, we may not have complete information for controlling all forms of hazardous energy, especially electricity, as we will soon discover.
Limitations of 1910.147 Subpart J
First, if we look closely at the scope of 1910.147(a)(1), we find the standard establishes “the minimum performance requirements” to prevent inadvertent start up or release of hazardous energy during servicing and maintenance of machines and equipment. “Minimum requirements” means there are other mandates on top of what is identified by this standard. Subpart J also contains a list of its limitations of certain industries and types of energies it does not apply to.
One of the key exceptions is controlling electrical energy according to section 1910.147(a)(1)(ii)(D) which states the following:
“Exposure to electrical hazards from work on, near, or with conductors or equipment in electric-utilization installations, is covered by Subpart S.’ (emphasis added)
Did you catch that? OSHA’s main “Lockout/Tagout” regulation (1910.147 Subpart J) points employers to another safety regulation when specifically dealing with electricity. This means LOTO to control electrical energy is governed by a completely different OSHA standard, one that specifically addresses electrical safety regulations pursuant to 1910.301 through 399, Subpart S, and explicitly by section 1910.333 titled “Selection and Use of Work Practices.”
Therefore, if your COHE/LOTO program was founded solely on 1910.147 Subpart J, then there’s a very good chance significant safety gaps exist when attempting to control electric current to protect your workers. The primary reason for this gap is because electricity warrants additional safety actions that are not necessary when controlling other forms of hazardous energy.
Additional COHE regulations for electric utilities
Those who work within electric utilities will also need to address their COHE programs through adherence with 1910.269 Subpart R, which is separated into two distinct areas: electric generation and electric transmission/distribution systems.
The first area targets COHE in electric generation plants, and is found in 1910.269(d) where LOTO is required, which is similar to but differs from 1910.147, Subpart J. This regulation applies to electric power generation regardless of how the electrons are generated; for example, power plants using fossil fuels, hydro, nuclear, wind, solar, renewables, battery energy storage systems (BESS), geo-thermal, etc. It can also apply to non-utility industries with co-generation capabilities.
But once the current leaves the power plant to the transmission and distribution grid, then 1910.269(m) must be followed using the clearance process rather than LOTO. We will not delve deeply into the COHE standards for electric utilities in this article but felt it was necessary to inform the reader of further OSHA requirements for this specialized industry.
I will elaborate further in a separate article which will specifically discuss COHE for electric utilities.
Next Parts - Looking Ahead
Next, in Part 2, we’ll begin the journey of discovery behind the reasons why using 1910.147 Subpart J alone is inadequate to protect employees from electric shock and arc flash.
We will also provide common examples of how the same employees working on the same equipment but tasked with different work activities can unknowingly expose themselves to potential injury without the employees or EHS professionals being aware of it.
From Part 3 and beyond, we will discuss the required COHE/LOTO methods within the applicable governance and standards to adequately control electrical energy.
Since LOTO is obviously an essential and foundational part of electrical safety, we must also cover additional electrical safety practices by using NFPA® 70E®, Standard for Electrical Safety in the Workplace to augment the applicable OSHA regulations.
NFPA 70®, National Electrical Code®, NEC® , 70E®, and Standard for Electrical Safety in the Workplace® are registered trademarks of the National Fire Protection Association, Quincy, MA.
