LOTO Procedure

Guide

Does every machine need its own lockout procedure?

Short answer: every machine needs a documented way to be locked out, but not always its own sheet of paper. Here is how the standard handles it.

The rule

29 CFR 1910.147(c)(4)(i) says procedures shall be developed, documented and used for the control of potentially hazardous energy. The procedure must clearly and specifically outline how to control the energy of the machine it covers.

One procedure for similar machines

OSHA's interpretations allow a single procedure for a group of similar machines: machines that use the same type and magnitude of energy and have the same or substantially similar controls, so that the steps to shut down, isolate, block and secure them, and to place and remove locks, are the same. The procedure must also say which machines it covers, by type and location or by model, so an authorized employee knows it applies to the machine in front of them (OSHA interpretation). Three identical slicers on the same counter can share one. A spiral mixer and a planetary mixer cannot, even if they sit side by side. And a procedure so generic that it fits every machine is not acceptable: it must be detailed enough to follow on the real machine.

The exception: when no written procedure is needed

The note to (c)(4)(i) lets you skip the written procedure only when all eight of these are true:

  1. The machine has no potential for stored or residual energy, or for its reaccumulation after shutdown.
  2. It has a single energy source that can be readily identified and isolated.
  3. Isolating and locking out that source completely de-energizes and deactivates the machine.
  4. The machine is isolated from that source and locked out during servicing.
  5. A single lockout device achieves a locked-out condition.
  6. The lockout device is under the exclusive control of the authorized employee doing the work.
  7. The servicing does not create hazards for other employees.
  8. The employer has had no accidents involving unexpected activation of such machines during servicing.

Most food equipment fails at least one of these: mixers and slicers coast after stopping, ovens store heat, packaging machines have air and electricity.

What this means in practice

Make a list of your machines, group the truly identical ones, and write one procedure per group. It is less work than it sounds, and it is what an inspector will ask to see first.

Need the written procedure?

Pick your machine, add your details and print a machine-specific procedure with DANGER tags.

Create a procedure

General information, not legal advice.