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Cord-and-Plug Lockout/Tagout (LOTO) Exception

Energy Control

The Problem

Lockout/Tagout (LOTO) procedures are designed to protect workers from hazardous energy during maintenance or servicing of equipment. However, one exception applies to cord-and-plug connected equipment. Misunderstanding this exception can lead to serious injuries or even fatalities, especially when hazardous energy is not fully de-energized or when the plug is not under exclusive control. Today, we’ll clarify the conditions under which this exception applies and how to ensure safety.

Identify the Hazards

  • Residual Energy: Equipment like compressors or machinery with capacitors may retain energy even after being unplugged.

  • Loss of Plug Control: If the plug is not under the exclusive control of the worker, there’s a risk of accidental re-energization.
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  • Teamwork Hazards: When multiple workers are servicing equipment, misunderstanding the exception could result in one worker re-energizing equipment while others are still working on it.

Safety Practices and Preventative Measures

To safely apply the cord-and-plug exception, follow these steps:

  1. Ensure Complete De-Energization:

    • Unplugging the equipment must eliminate all forms of hazardous energy.
    • Examples:
      • A disconnected compressor might still have residual pneumatic energy in storage tanks or lines.
      • Equipment with capacitors might retain electrical charge after being unplugged.
    • Precaution: Verify that all residual or stored energy is fully released before starting work.
  2. Maintain Exclusive Control of the Plug:

    • The plug must remain:
      • In the worker’s hand, pocket, or within arm’s reach and in their line of sight.
    • If multiple workers are involved:
      • The exception does not apply. Each worker must attach their own lockout device to the plug.
    • Precaution: If the plug cannot remain under exclusive control, LOTO procedures must be used to secure it.
  3. Know When to Default to LOTO:
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    • If there’s any uncertainty about whether unplugging the equipment removes all hazardous energy, or if exclusive control of the plug cannot be maintained, always apply full LOTO procedures.‍
    • Precaution: When in doubt, lock it out.

Real-Life Case or Scenario

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

E.g. In a recent incident, a worker servicing a piece of equipment relied on the cord-and-plug exception but didn’t realize the machine's capacitors still held electrical charge. While the equipment was unplugged, the residual energy caused a severe electric shock. This could have been prevented by ensuring all energy sources were fully de-energized before starting work.

Employee Responsibilities

  • Verify De-Energization: Check all energy sources are fully neutralized, including residual energy.
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  • Maintain Plug Control: Keep the plug under your direct control throughout the task.
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  • Use LOTO When in Doubt: If conditions for the exception aren’t met, apply a lockout device.

Employer Responsibilities

  • Provide training on the cord-and-plug exception and when it applies.
  • Ensure tools and testing equipment are available to verify de-energization.
  • Encourage employees to use LOTO if there’s any uncertainty about safety conditions.

Discussion & Questions

  • "What challenges have you faced when using the cord-and-plug exception?"
  • "Can anyone share an example of when LOTO was necessary despite unplugging equipment?"

Encourage employees to share their experiences and clarify any doubts.

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Commitment/Action Plan

Let’s commit to using the cord-and-plug exception only when all conditions are fully met. Starting today, take the extra time to verify energy neutralization and ensure proper plug control to avoid accidents.

Wrap-Up

The cord-and-plug exception can streamline work, but safety must always come first. By fully understanding the conditions and precautions, we can prevent serious injuries and fatalities. Thank you for your attention and dedication to workplace safety.

Standards Overview

  • OSHA's Lockout/Tagout Standard (29 CFR 1910.147) requires procedures to control hazardous energy during servicing and maintenance.

  • Cord-and-Plug Exception: LOTO is not required if:some text
    • The equipment is completely de-energized by unplugging it.
    • The plug remains under the exclusive control of the employee performing the work.

By understanding and applying these standards correctly, we can prevent accidents and ensure compliance.

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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