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OSHA’s LOTO Standard: Due for an Update

By: Maureen Paraventi

A variance granted to a U.S. steel production company set the stage for what many in the occupational safety community hope will be a long-overdue revision of OSHA’s lockout/tagout (LOTO) standard. CFR-29 910.147, which is aimed at preventing equipment from releasing hazardous energy while someone is using it, hasn’t been changed in more than three decades. In contrast, ANSI/ASSP Z244.1, ANSI B11.0, ANSI B11.19 and UL 6420 have all been released or updated within the past three years. These standards provide a framework to help improve LOTO and alternative measures while meeting OSHA requirements.

In a Safety 2021 session last year, Christopher Brogli, VP of Global Safety Business Development for Ross Controls, discussed both current federal regulations and the variance that may have gotten the ball rolling toward a revision of CFR-29 010.47. He began by noting that the regulation deals with all types of hazardous energy, including electrical, mechanical, hydraulic, pneumatic, chemical and thermal.

Employer Responsibilities

In the U.S., employers are responsible for having a LOTO program, which means they must create one if one doesn’t currently exist; establish procedures for it; determine what hardware is necessary to do the energy isolation; train employees on it on a yearly basis; and conduct periodic inspections of the program.

“As part of the program, employers must identify when lockout and tagout is necessary on a piece of equipment,” said Brogli. “They have to identify the energy sources on that piece of equipment and what the isolation device is. Once they’ve identified that isolation device, they need to determine how it can be locked out and tagged out and they have to define a procedure for that.”

He added that in addition to a lockout procedure, there must be one for re-energizing the machine once lockout’s been done. They must also provide LOTO devices. In addition to employees, training must include contractors who will use the equipment. The periodic inspections of the program should encompass the premises, procedures and hardware. If new equipment was introduced into the worksite, or existing equipment was modified, the procedures and lockout devices may need to be modified. Additionally, employees might require additional training, to address the changes.

Lockout/tagout devices must:

  • Control and/or dissipate hazardous energy
  • Be easily accessible (outside of hazardous area and at a convenient height)
  • Easily identifiable
  • Capable of being locked only in the off position
  • Suitable to the application environment

How a Variance Led to an RFI

OSHA issued a request for information (RFI) a few years ago intended to generate information from stakeholders about LOTO procedures. “Basically, what this RFI was looking at was, ‘is there a way of doing lockout using something called energy isolation devices, or maybe more of an automated lockout process?’” said Brogli. The RFI asked people in industry about their perception: “Is there a better way to do lockout that’s less burdensome for the employers themselves and just as effective?”

Brogli noted that the RFI was inspired by a permanent variance OSHA granted in 2016 to Nucor Steel Connecticut Incorporated, from complying with the provisions of OSHA standards that regulate LOTO. Most of the 87 comments OSHA received in response to the RFI “were very encouraging,” according to Brogli, although there were a few negative comments from mechanical installer and electrical installers. Most respondents felt that some sort of automated lockout process would be beneficial.

Nucor incorporated a trapped key system. In this system, whenever the machine is turned to the off position, the trapped key sends a signal to an energy isolation device that deenergizes the system. That key remains trapped until the pressure in the system reaches a zero-energy state. Once it does, the employee can then remove that key, and put into a group lock box.

“It was a very systematic approach and it used energy isolation devices,” said Brogli.

Nucor had to provide a substantial amount of documentation to OSHA in order to obtain the variance – documentation which allowed the agency to evaluate:

  • Whether the device provided an equivalent level of employee personal control over machine re-energization
  • The ability to account for exposed employees
  • Verification of isolation to that required by the OSHA standard

OSHA reached three conclusions from its review of Nucor’s application for a variance:

  • The alternate device allowed energy control measures to remain under the personal control of the exposed employee through control of the trapped key, using a group lockbox
  • Employees were able to verify de-energization
  • Authorized employees were easily identified before an equipment re-start

An automated LOTO process has been in use in Europe a number of years, said Brogli, “But in the U.S., because the standard really has not been updated since the late 1970s, our standard is seen as very old and outdated.” WMHS

ROSS Controls designs and manufactures pneumatic valves and control systems and is recognized as a leader in fluid power safety solutions and poppet valve technology (

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