Lockout/tagout: Owner client vs. contractor responsibilities
A new contractor has been chosen for my project. What are OSHA’s requirements to ensure I’m keeping my employees and my contractor employees safe?
Responding is Steven Stogner, head systems engineer, TradeSafe, Las Vegas.
Your brand-new facility is ready to start producing world-famous widgets. Contractors are being vetted to enter and work inside the new plant, and equipment is ready to be put in service. But do your contractors have an OSHA-compliant lockout/tagout or “control of hazardous energy” process? Do they know your lockout/tagout procedures, and are they ready to work safely?
Here, I’ll address the basic requirements for “owner clients” and contractor responsibilities regarding lockout/tagout.
OSHA’s standard on the control of hazardous energy (1910.147), or lockout/tagout, was written to protect workers from injuries or fatalities caused by the unexpected release of hazardous energy. Whether we’re talking about 13,800 volts from an electric motor control center or the release of 1,000 pounds of steam, either one – and all other forms of energy – can be deadly. It’s important for owner clients and contractors to know their roles and responsibilities, and it must be clear, easy to understand and compliant with 1910.147 (for most applications).
Owner clients are responsible for specific requirements regarding lockout/tagout: training, determining affected and authorized employees, annual inspections, and verification, to name a few. However, they also have responsibilities for their contractors. See 1910.147(f)(2).
Challenge No. 1 – Communicating requirements: The first requirement is to communicate lockout/tagout procedures to get on the same page. OSHA’s 1910.147(f)(2)(ii) states that “the onsite employer shall ensure his/her employees understand and comply with restrictions and prohibitions” of the contractor. “Shall ensure” should raise some concerns and eyebrows. You may ask, “Am I responsible for training my contractors and ensuring they understand?”
Solution: Contractors could be considered “authorized” or “affected” employees and are therefore required to receive training on the lockout/tagout process/program. If, by definition, they’re “authorized” employees (they’re responsible for locking out equipment, for example), they’re subject to the owner clients’ methodology of lockout/tagout and the owner client must demonstrate that they understand the process. Various methods of accomplishing training can be done, from orientations that require a test/quiz or an onsite training program from the contractor’s representative – whatever ensures compliance.
Challenge No. 2 – Various contractors and group lockouts: If an owner client uses the group method, whereby several contractors or different departments may be working under the same lockout, personal locks must still be used, per 1910.147(f)(3)(ii) C and D.
Solution: If I’m working under my company’s crew lock, I must also put a personal lock on the group lock mechanism if I’m working on the equipment. Likewise, I’d remove the lock upon completion of my work. Typically, this can be achieved by having specific color locks for contractors and a different, specific color for personal protection locks.
Challenge No. 3 – Shift change: If I have multiple or 12-hour shifts, I must also determine a method to “orderly transfer” the control of hazardous energy from one shift to the next. This should be easy to understand and minimize exposure to employees on different shifts.
Solution: This can sometimes be achieved by logbooks or safe work permits, whereby a documented exchange of the keys takes place for the contractor crew/departmental lock.
In summary, lockout/tagout can be complex. However, the simpler the process, the easier employees can understand and follow expectations. Implementing lockout/tagout programs are a little different for contractors and involve duties to train, and depending on “authorized” vs. “affected” employees, employers must know the difference and comply accordingly.
However, effective implementation of the whole program, to demonstrate effectiveness, typically includes clear and concise adult training programs, easy to understand procedures, and clear expectations that include contractor expectations and communication, with an all-encompassing audit or inspection process to validate the program is working and protecting employees.
Finally, a best practice is to pass these programs in front of an employee safety team. After all, it’s their tool. Let them be involved in the planning, design and implementation so they can be a part of something they helped design.
Editor's note: This article represents the independent views of the author and should not be considered a National Safety Council endorsement.