Performance Oriented
LOTO Training for Authorized, Affected, Other Employees
BY CHRIS SANFORD

In a memo to regional administrators dated April 28, 2010, OSHA Administrator Dr. David Michaels reiterated an OSHA policy that requires employees be trained in a manner that they understand. And, they have to exhibit such an understanding.

Many OSHA standards require that employees receive training so that work will be performed in a safe and healthful manner. Some of these standards require “training” or “instruction,” others require “adequate” or “effective” training or instruction, and still others require training “in a manner” or “in language” that is understandable to employees.

It is OSHA’s position, wrote Michaels, “regardless of the precise regulatory language, the terms “train” and “instruct,” as well as other synonyms, mean to present information in a manner that employees receiving it are capable of understanding. This follows from both the purpose of the standards — providing employees with information that will allow work to be performed in a safe and healthful manner that complies with OSHA requirements — and the basic definition that implies the information is presented in a manner the recipient is capable of understanding.

This means that not only do employers have to present information in a language the employees understand, but OSHA’s training provisions contain a variety of specific requirements related to employee comprehension. For example, the lockout/ tagout standard requires the employer to verify that the employees have “acquired” the knowledge and skills for which they have been trained.

When it comes to lockout/tagout training requirements, as detailed in 29 CFR 1910.147(c)(7), the specific training material may vary from workplace to workplace, and even from employee to employee.

Self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. However, in an instruction bulletin to its compliance officers, OSHA says that unless the training program is specific to the servicing that will be performed by an employee, use of computerbased training by itself would not be sufficient to meet the intent of OSHA’s LOTO training requirements.

OSHA urges employers to be wary of relying solely on generic, packaged training programs in meeting their training requirements because training must be relevant for the employees’ actual servicing and maintenance work activities.

Essential training information will necessarily vary from workplace to workplace, and even from employee to employee within a single workplace, depending on the type and complexity of the energy control procedure, as well as the employee’s duties and responsibilities under the LOTO program.

Specifically, training under LOTO includes site-specific elements and, very importantly, it must be tailored to employees’ assigned duties.

In addition, the employer has the responsibility to ensure that employees understand the purpose and function of the energy control program and to ensure that these employees have the knowledge and skills required to safely apply the energy control measures.

In an effective training program, it is important that trainees have the opportunity to ask questions when material are unfamiliar to them. In a computer-based program, this may be achieved by providing a telephone hotline so that trainees will have direct access to a qualified trainer. Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting.

Industrial operations, and in particular hazardous energy control operations, can involve many complex and potentially hazardous tasks. It is imperative that employees are able to perform such tasks safely. OSHA believes that computer-based training programs and training videos can be used as part of an effective safety and health-training program to satisfy OSHA training requirements, if the training as a whole provides employees with the information and knowledge necessary to safely perform the work.

In order to provide adequate information, any LOTO training program must address, at a minimum, the following three areas: 1) the purpose and function of the energy control program; 2) the elements of energy control procedures relevant to employee duties; and 3) the pertinent requirements and prohibitions of the LOTO standard.

The training, detailed in paragraph 1910.147(c)(7)(i), must be specific to the needs of authorized, affected, and other employees, and the degree of knowledge required for these three employee groups diminishes from authorized employee to affected employee and from affected employee to other employee.

Authorized employees are those responsible for implementing the energy control procedures (e.g., an employee who locks out or tags out machines) and/or performing the servicing or maintenance activities. These employees must have the knowledge and skills necessary for the safe application, use, and removal of energy isolating devices. For employers with a large number of procedures, each authorized employee must be able to safely perform the work required by any energy control procedure that he may be called upon to use, however rarely.

Therefore, these employees need training in the applicable aspects of the procedure and its proper utilization, together with training in the:

A. Recognition and understanding of all applicable hazardous energy sources; B. Type and magnitude of the hazardous energy sources associated with machinery or equipment on which they will perform servicing or maintenance; C. Energy control procedures, including the methods and means to isolate and control relevant energy sources.

Affected employees are those employees (e.g., machine operators and material handling specialists) who operate or interact with machines that are serviced and maintained pursuant to energy control procedures, as well as those employees (e.g., general laborers) who are assigned to work in areas where energy control procedures are utilized to service or maintain machinery.

In other words, employees who are assigned to areas where servicing or maintenance work is performed, but who do not implement energy control procedures or perform servicing and/or maintenance work need only be trained as affected employees.

Affected employees must be able to:

A. Recognize LOTO devices immediately;

B. Recognize when the energy control procedure is being used;

C. Understand the purpose and use of the procedure; and, most importantly; D. Understand the importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked out or tagged out.

Affected employees are required to be instructed in these matters and be informed that disregarding or violating the prohibitions imposed by the energy control procedure could endanger their own lives or the lives of their co-workers.

Other employees who may be in an area where energy control procedures may be utilized must receive instruction regarding the energy control procedure and the prohibition against removing a lockout or tagout device and attempting to restart, reenergize, or operate the machinery.

This instruction, which can be provided during new employee orientations, by use of employee handbooks, or through safety meetings, must convey what the energy control program does, the program’s prohibitions, and that the employees are not to touch any locks, tags, energy isolation devices, or equipment covered by this program.

This instruction is required for all employees who are not classified as “authorized” or “affected” employees unless the company establishes, communicates, and enforces a policy prohibiting an employee or group of designated employees from ever being in an area where servicing or maintenance is performed pursuant to an energy control procedure.

The success of an energy control program depends upon clearly outlined steps to be taken by employees, periodic inspections and other management procedures designed to ensure accountability, and effective training to teach employees about the applicable procedure for the servicing or maintenance task to be performed. FSM