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Coordinating Lockout/Tagout (LOTO) with Contractors

Energy Control

The Problem

Working on shared machinery with contractors or workers from another employer creates serious risks if lockout/tagout (LOTO) procedures are not properly coordinated. Miscommunication, assumptions, or a lack of coordination can lead to hazardous situations such as the unexpected release of energy, resulting in injuries or fatalities. Today, we’ll explore how to coordinate LOTO procedures effectively to eliminate these risks.

Identify the Hazards

  • The Danger of Miscommunication:

    • Workers may assume a hazardous energy source has been isolated when it hasn’t.
    • Contractors may rely on the host employer to perform critical safety tasks, leading to gaps in the process.
  • Examples of Risks:

    • Residual pressure in a vessel that wasn’t bled off.
    • Workers unknowingly reactivating equipment while others are performing maintenance.

Key Issue: A lack of coordination increases the likelihood of serious injuries from unexpected energy releases.

Safety Practices and Preventative Measures

To eliminate these hazards, follow these steps for effective coordination:

  1. Notify Supervisors Before Work Begins:

    • Always inform your supervisor or safety representative when contractors or workers from another employer are involved in servicing shared equipment.
  2. Coordinate LOTO Procedures:

    • Hold a meeting or review written LOTO procedures from all parties to ensure alignment.
    • Confirm that everyone understands the sequence of tasks, actions, and responsibilities.
  3. Clarify Roles and Responsibilities:

    • Identify who is responsible for each step of the LOTO process (e.g., bleeding residual pressure, locking out energy sources).
    • Ensure all workers, including contractors, know their role and agree on their responsibilities.
  4. Verify All Safety Steps Are Completed:

    • Always verify that lockout/tagout actions have been fully implemented before beginning work.
    • For example, confirm that all energy sources are isolated and residual energy has been safely released.
  5. Communicate Continuously During Work:

    • Maintain ongoing communication throughout the task to ensure no steps are missed or misunderstood.
    • Update all parties if there are changes in procedures or conditions.

Real-Life Case or Scenario

Where possible, use an actual incident that you have experienced or been involved in.

E.g. Here’s an example: A contractor assumed that the host employer had bled off the residual pressure in a vessel. The host worker thought the contractor would handle it. As a result, the pressure wasn’t released, leading to a near-miss when the equipment was opened. This type of confusion could easily have resulted in severe injuries or worse. Simple coordination could have prevented this situation.

Employee Responsibilities

  • Notify your supervisor about any work involving contractors or other employers.
  • Participate actively in coordination meetings or reviews of written procedures.
  • Verify that all lockout/tagout steps are completed before beginning work.
  • Never assume the other party has handled critical safety tasks.

Employer Responsibilities

  • Provide clear and documented lockout/tagout procedures for employees and contractors.
  • Facilitate coordination meetings or procedure reviews before work begins.
  • Ensure all parties are trained and understand their roles in the LOTO process.
  • Verify that all LOTO actions are complete before authorizing work.

Discussion & Questions

  • "Have you ever had to coordinate lockout/tagout procedures with contractors? How did you ensure everything was handled safely?"
  • "What challenges have you faced when working with contractors on shared equipment?"

Allow employees to share their experiences and discuss ways to improve coordination.

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Commitment/Action Plan

Let’s commit to making coordination a standard part of every task involving contractors or other employers. Starting today, notify your supervisor about these situations, and always participate in coordination meetings to ensure everyone is aligned on lockout/tagout procedures.

Wrap-Up

Proper coordination during lockout/tagout is not just a best practice—it’s a lifesaving measure. By taking the time to communicate and verify safety steps, we can prevent accidents and ensure everyone goes home safe. Thank you for your attention and commitment to safety.

Standards Overview

  • Coordination is Required: OSHA mandates that employers must coordinate their lockout/tagout programs when employees from multiple employers are working on the same equipment (OSHA 1910.147).
  • Clear Responsibilities: Employers must ensure that workers are aware of all procedures, actions, and responsibilities through communication and documentation.

These requirements exist to ensure no one assumes critical safety tasks have been completed by someone else.

OSHA Occupational Safety and Health Administration

Legal Disclaimer

This toolbox talk is provided for informational and educational purposes only. It is not intended to be a substitute for professional legal, safety, or regulatory advice. The information presented is based on best practices and general industry standards but may not apply to all workplace situations.
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It is the responsibility of the employer, supervisors, and workers to ensure compliance with applicable federal, state, and local laws, regulations, and standards. The authors, presenters, and distributors of this toolbox talk assume no liability for the use or application of the information provided.
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Participants are encouraged to consult appropriate legal, safety, or regulatory professionals to address specific concerns or questions. Always follow your organization's policies and procedures for workplace safety and hazard mitigation.

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