Contents

Approved by K. Johnson
Reviewed 12/23

18.1 Policy
18.2 Scope
18.3 Applicability
18.4 Exceptions
18.5 Roles and Responsibilities
18.6 Definitions
18.7 Required Work Processes 

• Work Process A. LOTO Program Quick Reference Map
• Work Process B. Basic LOTO Rules 
• Work Process C. Cord-and-Plug Equipment 
• Work Process D. Simple LOTO  
• Work Process E. Complex LOTO  
• Work Process F. Complex LOTO Requiring a Responsible Individual 
• Work Process G. Group LOTO With a Lockbox
• Work Process H. Tagout Only 
• Work Process I. Subcontractor LOTO Permit 
• Work Process J. Shift Changes and Transfer of Control 
• Work Process K. Temporary Partial Restoration 
• Work Process L. LOTO Hardware 
• Work Process M. Training and Authorization 
• Work Process N. Developing LOTO Procedures 
• Work Process O. Special Condition LOTO Lock Removal 
• Work Process P. Periodic Inspections of LOTO Procedures 
• 🚩🚩Work Process P.1. LOTO Program Assurance Plan🛑
• Work Process Q. Physical Separation
• Work Process R. Interlock Systems 
• Work Process S. Administrative Control 
• Work Process T. LOTO Coordination 

18.8 Source Requirements 
18.9 Reference Documents 
18.10 Appendices 

• 🚩🚩Appendix A. LBNL LOTO Procedure Process🛑
• Appendix B. Written LOTO Procedure Alternate Format
• Appendix C. Absent Person LOTO Lock Removal Form 

🚩Additional Process Flows and Training Aids can be found here: https://electricalsafety.lbl.gov/loto/🛑

Note:
🚩🚩    Denotes a new section

🚩    Denotes the beginning of changed text within a section

🛑    Denotes the end of changed text within a section

____________________

18.1 Policy

All personnel who perform work on or near equipment in which the unexpected energization or start-up of the equipment, or the release of hazardous stored energy, could cause injury shall personally lock out the equipment for the duration of their work.

Persons performing work on projects or sites that do not fall under DOE jurisdiction are not required to follow the requirements of this LOTO Program. However, an equivalent LOTO program meeting applicable regulatory requirements will apply.

18.2 Scope

1. Lockout/Tagout (LOTO) is required whenever construction, service, maintenance, modification, or demolition is being performed on or near equipment in which the unexpected energization or start-up of the equipment, or the release of hazardous  stored energy, could cause injury to people.
2. Hazardous energy is any form of energy that can cause personal injury, including but not limited to:
   1. Electrical
   2. Mechanical
   3. Rotational
   4. Gravitational
   5. Chemical
   6. Pressure or vacuum
   7. Hydraulic
   8. Pneumatic
   9. Non-ionizing radiation sources
   10. Thermal

18.3 Applicability

This program is required for all Berkeley Lab employees, affiliates, students, visitors, and subcontractors who may be exposed to hazardous energy while performing any construction, service, maintenance, modification, or demolition activity.

18.4 Exceptions

Lockout/Tagout (LOTO) is not required for each of the following situations:

1. 🚩🚩Normal operations, also known as normal production operations or normal energized operations, where the machine or equipment is utilized to perform its intended function and is covered by various chapters of the ES&H Manual
   1. Servicing or maintenance that take place during normal operations require LOTO only if:
      1. A person is required to remove or bypass a guard, cover, or other safety device or
      2. A person is required to place any part of his or her body into an area of a machine or piece of equipment where work is actually performed upon the material being processed (point of operation) or where an associated danger zone exists during a machine’s operating cycle
   2. Minor tool changes, adjustments, and other minor servicing activities that take place during normal operations do not require LOTO provided that:
      1. Such activities are routine, repetitive, and integral to the use of the equipment and 
      2. The work is performed using alternative measures that provide effective personnel protection 
2. Hot tap operations involving transmission and distribution systems for substances such as gas, steam, water or petroleum products when they are performed on pressurized pipelines, provided that it has been demonstrated that:
   1. Continuity of service is essential,
   2. Shutdown of the system is impractical, and
   3. Documented procedures are followed, and special equipment is used which will provide proven effective protection for employees.
3. Energized testing and troubleshooting (e.g., alignment, measuring, calibration, fault finding) does not require LOTO where the equipment must be energized to perform the tests.
4. Work on cord-and-plug-connected electrical equipment does not require LOTO controls when Work Process C is followed.
5. Control of hazardous ionizing radiation is covered under Chapter 21 Radiation Protection Program. In radiation areas covered by credited control radiation, safety systems do not require LOTO controls when Work Process R is followed.🛑

18.5 Roles and Responsibilities

Roles	Responsibilities
Division Electrical Safety Officer (DESO)	Manages Electrical Safety Program Implementation for the Division. Provides answers for questions regarding electrical safety content in PUB-3000, Chapters 8 & 18 and the Lab’s Electrical Safety Manual.   Reviews job electrical safety plans (switch tags, Subcontractor LOTO permits, LBNL in-house LOTO procedures, Method of Procedure (MOP’s), 🚩physical separation🛑  plans, deactivation plans, conduit cutting permits, EVAP’s and MEVAP’s). Participates in job walks, as needed, and assists with the  development of electrical safe work practices. Attends LOTO briefings and witnesses zero energy verification as  necessary. 🚩May authorize persons without LOTO training to be Escorted into an area under LOTO (Work Process M: Training Exceptions). 🛑
Environment, Health and  Safety (EHS) Division (Electrical Safety Group)	🚩Maintain, administer, and revise the LOTO Program as needed Ensure that LOTO equipment is available and consistent with Berkeley Lab standards Develop and implement the Lockout/Tagout training courses Ensures full implementation of the LOTO Program through the EHS Assurance Program. Maintains the Quickbase LOTO Procedure/Subcontractor Permit applications Shall communicate to management any LOTO RI that does not seem to understand or follow the LOTO process.🛑
Facilities Engineering	🚩Updates site documentation to make sure it matches field conditions. Provides drawings, arc flash (AF) labels, or panel schedules as requested Electrical Systems less than 750V: Will provide guidance and support as needed to check single line drawings, panel schedules as well as arc flash info to make sure it matches what is on file (ie Panel Schedules and AF labels). If there is a discrepancy found during review, Engineering will provide guidance to the documentation and provide the corrected schedule to be posted in the field and provide an AF label for installation in the field. Electrical Systems greater than 750V: Reviews the LOTO Permit and associated documents and confirms the isolation points bound the scope of work and there are no unidentified safety concerns. Mechanical Systems: Provide guidance as requested🛑
Laboratory Electrical Safety Officer	🚩Must be consulted before the arc flash incident energy on a LOTO procedure exceeds 40 cal/cm2 AFTER additional controls referenced in the Electrical Safety Manual have been implemented. ​​Equipment that is deranged or has been improperly installed, such as overdutied or damaged panels and their associated circuit breakers as a default shall not be operated. Equipment in this condition presents additional hazards and would require specific permission after careful evaluation. Review and approval of Subcontractor QEWs to perform Simple LOTO on hard-wired equipment without a Subcontractor LOTO Permit.🛑
Limited LOTO Authorized Person	Follow the directions of the LOTO Responsible Individual 🚩or the LOTO Person in Charge🛑 Must attend the LOTO Briefing prior to joining any LOTO. 🚩Sign the LOTO briefing sheet to acknowledge receiving the briefing🛑 Maintain control over the keys to their personal LOTO locks Apply his or her own personal LOTO lock and tag when performing service, maintenance, or modification work Must NEVER apply or remove a Personal LOTO lock for anyone else 🚩Must NEVER be the first lock on or the last lock off Sign the LOTO briefing sheet to acknowledge unlocking from the LOTO🛑
Line management (including supervisors, managers, and work leads)	Prohibits employees from working on equipment requiring LOTO until the worker is trained and authorized to perform LOTO Maintains 🚩an index of written LOTO procedures where required, and ensures audits of these LOTO procedures are performed at least annually and reported to EHS during the annual inspection period per the LBNL LOTO Procedure Program (Appendix A) Ensures employees who are part of the LOTO process are assigned to the correct activity in WPC Activity Manager.🛑 Ensures consistent policy implementation and reinforcing LOTO rules 🚩and follows up with any individual who does not follow these rules 🛑 Authorizes the removal of LOTO devices in case of a person’s absence (Work Process O) Ensures that necessary LOTO hardware is available Ensures that all outside contractors operating under the supervision of the division are informed of and adhere to the Berkeley Lab LOTO Program (Work Process I)
LOTO Affected Person	🚩All Berkeley Lab Employees and Affiliates are considered Affected Persons🛑 Follow all LOTO and safety requirements Recognize when LOTO is being used, the general reasons for LOTO, and the importance of not tampering with or removing a lock and tag
LOTO Approver	🚩See LOTO Procedure Program Document (Appendix A)🛑
LOTO Authorized Person	🚩A person who has completed the required LBNL LOTO training outlined in Table M-1.🛑 Recognize the conditions of work that require LOTO.  🚩Must understand the LOTO Safe Zone and make sure their own work stays within the safe zone.   Maintain control over the keys to their personal LOTO locks🛑 Apply his or her own personal LOTO lock and tag 🚩before🛑 performing service, maintenance, or modification work Must NEVER apply or remove a Personal LOTO lock for anyone else
LOTO Coordinator	🚩Maintains oversight for a set of LOTOs established during a large project Must be able to effectively communicate and plan LOTO work as it progresses within a project Provide overall coordination for LOTOs with the project schedule 🛑 Resolve scheduling conflicts between different LOTOs and other scheduled work Ensure the various Responsible Individuals (RIs) are properly informed of any changes that will impact their respective LOTO procedures
LOTO Person in Charge (LPIC)	Must have extensive experience and/or technical knowledge of the system configuration and function of the equipment included in the work boundary. Conduct a LOTO Briefing before implementation of LOTO. Ensure LOTO procedures are followed and procedural steps are completed as written. 🚩Stops work and place the equipment in a safe state when questions arise in the implementation of any written procedure. If an RI has not been assigned, briefs  Limited LOTO Authorized Persons before they join the LOTO.   The LOTO Person in Charge role can be transferred to another equally qualified person after a briefing and documented on the LOTO briefing sheet.🛑
LOTO Procedure Evaluator	🚩See LOTO Procedure Program Document (Appendix A)🛑
LOTO Responsible Individual (RIs)	🚩A person who has completed the required LBNL LOTO training outlined in Table M-1.🛑 Assist in gathering all information for the control of hazardous energy and identifies the work boundary and systems/equipment that will need to be isolated to eliminate all hazardous energy sources. Request technical support as needed to create a risk-based pre-LOTO assessment of safety and negative operational impacts of the LOTO. Works with the Subcontractor to define the scope of the project/work activity to be performed in the LOTO safe zone. Obtains single lines, pictures or planning documents required to initiate the LOTO Permit. Initiates the work order and LOTO Permits. Witnesses the Qualified Person(s) in the execution of the LOTO permit Briefed on the LOTO safe zone by the 🚩LOTO Person in Charge🛑  establishing the LOTO and will then be responsible for briefing any additional LOTO Authorized Persons 🚩or Limited LOTO Authorized Persons🛑 who need to lock out as work progresses Ensures all Subcontractors who lock onto the LOTO have taken EHS0379: LBNL Subcontractor LOTO Orientation Serves as the Authorized Person who: Supervises work teams to ensure the safe and compliant performance of work. Ensures all personnel performing work under the LOTO personally locked out for their tasks Manage any changes to the scope of work that might come up during the course of the job. 🚩Obtains authorization for field changes 🛑 After the job, ensures the LOTO permit or any field changes gets returned to EHS for closure If they need to move to a new project, they will ensure there is adequate 🚩handoff and transfer of control to the incoming🛑 RI.
LOTO Reviewer	🚩See LOTO Procedure Program Document (Appendix A)🛑
Qualified Person – Electrical (QEW) as well as Mechanical	🚩Required to be current with all qualification training. Wear all required PPE and follow all required safe work practices while performing the necessary operations. Assist Non-Qualified Persons in the performance of Lockout/Tagout of equipment, including verifying the zero-energy state of equipment to support the LOTO process Only perform work on equipment that has been placed in a safe work condition, unless proper authorization has been obtained and required controls have been established.🛑

18.6 Definitions

Term	Definition
Absent Person lock removal	A procedure for the removal of a lock and tag by someone other than the person who applied the lock and tag when that person is not present or available to remove the lock 🚩(Work Process O and Appendix C) 🛑
Administrative Lock	Any lock used for a purpose other than LOTO. The lock may serve a safety function other than LOTO, a configuration-control function, or other purpose. Can be any color except red.
Blocked	A condition where a mechanical device is inserted into the energy path to physically prevent movement. Most commonly used with moving parts.
Capable of being locked out	An energy isolation is capable of being locked out if it has a means of attachment to which, or through which, a lock can be affixed with the device in the “off” or de-energized position, or it has a locking mechanism built into it
Complex LOTO	Any LOTO that does not meet the requirements for a simple LOTO is called a complex LOTO. Requires an assigned 🚩LOTO 🛑Person In Charge and a LOTO procedure.
Cord-and-plug- powered equipment	Portable electric equipment, such as power tools, computers, printers, appliances, etc., for which exposure to the hazards of unexpected energization or start-up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug(s) being under the 🚩exclusive 🛑control of the employee performing the servicing or maintenance
Credited control radiation safety system	Specific definitions and requirements for radiation-generating devices, radiation safety systems and credited controls are found in the Chapter 21 Radiation Safety; Chapter 9 – Radiation Generating Device Program; and EHS Procedure 731, RGD Interlock Program.
🚩Division Electrical Safety Advocate (DESA)	A non-qualified electrical worker assigned by the division to perform tasks to support the Electrical Safety Program within the division.🛑
Dissipated	A condition where all stored energy has been reduced to a nonhazardous level. Pertains to energy-storing devices such as capacitors, pressure receivers, accumulators, reservoirs, or springs.
Energized	Connected to a 🚩hazardous🛑 energy source or containing residual or stored 🚩hazardous🛑 energy
Energy isolation	A mechanical device that physically prevents the transmission or release of energy, including but not limited to the following: Manually operated electrical circuit breaker Manually operated disconnect switch Manually operated switch by which the conductors of a circuit can be disconnected from all ungrounded supply conductors, and no pole can be operated independently Manually operated valve Flange blank Pin or block Any similar device used to block or isolate energy Energy isolations shall be capable of 🚩accepting an approved lockout device that physically prevents the actuation of the isolation. 🛑Push buttons, selector switches, software interlocks, and control circuit type devices are not energy isolations and cannot be used to isolate hazardous energy. 🚩Where the desired isolation consists of removing a spool piece, removing fuses, lifting electrical wires, or otherwise disconnecting an energy source without a lockable isolation, follow Work Process H, Tagout Only.🛑
Exclusive Control	Under the exclusive control of the employee means that the LOTO Authorized Person 🚩is working alone and🛑 has the authority to, and is continuously in a position to, prevent (exclude) other individuals from re-energizing or starting the machine or equipment while performing the servicing or maintenance activity.
Exposure	The condition of being subjected to a source of risk presented by hazardous energy sources
Group LOTO with a lockbox (Group Lockbox)	A process to coordinate a complex LOTO so that LOTO Authorized Persons only have to apply a personal LOTO lock to a lockbox instead of at 🚩multiple energy isolation points. 🛑
Group LOTO lock	A LOTO lock used for the purpose of group LOTO. It is identified by a group LOTO lock tag. The keys to group LOTO locks are controlled in one or more LOTO lockboxes.
Hazard zone	The space near a source of hazardous energy where a person could be harmed if the hazardous energy was suddenly or unexpectedly released, such as the unexpected release of stored pressure, the unexpected movement of a machine, the unexpected energization of an electrical conductor, or the spray from a hazardous chemical that was unexpectedly released
Hazardous energy	Energy that is of such a magnitude that it is capable of causing harm to a person.  Thresholds for hazardous electrical energy can be found in the LBNL Electrical Safety Manual. It is oftentimes necessary to involve technical experts to assist in the analysis of other forms of hazardous energy.
Hazardous energy control	The process of systematically implementing mechanical means to prevent hazardous energy from flowing to a person
🚩Hazardous Energy Control (HEC) Group	A group consisting of Hazardous Energy Control Specialists, working for the Facilities Department, responsible for serving as the issuing authority for FAC LOTOs and Subcontractor LOTOs on FAC equipment. 🛑
Hot Tap	A procedure used in repair, maintenance and servicing activities, which involves welding on a piece of equipment (pipelines, vessels or tanks) under pressure, in order to install connections or appliances. It is commonly used to replace or add sections of pipeline without the interruption of service for air, gas, water, steam, and petrochemical distribution systems.
Isolated	A condition where a source of hazardous energy has been controlled by physically stopping the energy path so that the energy cannot flow to workers or equipment. The term “isolated” is commonly used with electrical circuits and fluid lines.
Lockout/Tagout (LOTO)	The method of applying a mechanical lockout device and a tag, 🚩or a special tagout-only tag managed in a lockbox, 🛑 on an energy isolation by a LOTO Authorized Person in accordance with established procedures to control hazardous energies and prevent the equipment from being operated until the lockout device is removed
Look-alike equipment	Equipment that is similar in shape, size, and function that could lead a person to lock out Item A, but start working on Item B instead. Common examples are: “North/middle/south” pumps installed side by side High-voltage switching stations with rows of switchgear Sets of laboratory furnaces installed in a row
🚩LOTO briefing sheet/LOTO log	Used to document dates and times that LOTO briefings were performed or when LOTO Authorized Persons lock on and lock off.  It’s also used to communicate to Limited LOTO Authorized Persons who they need to contact for a briefing before locking on.  Link to suggested form can be found here.  Divisions might have a different version identified in their LOTO Operating Program Document. 🛑
LOTO device	A device or combination of devices that, when applied to an energy isolation and fitted with a LOTO lock or a LOTO hasp: Mechanically prevents the actuation of the energy isolation and Holds fast to the energy isolation until the LOTO lock or LOTO hasp has been removed
LOTO lock	A keyed red padlock used only for the purpose of LOTO
LOTO lockbox	A lockable box used to contain the key(s) of group LOTO locks, or the lower part of the tagout-only tag, 🛑during a group LOTO procedure
LOTO procedure	A formal written document, approved by a LOTO Approver, that details the scope of work performed under the LOTO, the energy isolations to be established, and all steps required to execute the LOTO.
🚩LOTO program	Per OSHA 1910.147, The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative.🛑
🚩LOTO program assurance plan	The purpose of this Lockout Tagout (LOTO) program assurance plan is to document assurance elements designed to review and monitor performance, understand how well the program is performing, and identify opportunities for improvement. (Work Process P.1)🛑
LOTO Responsible Individual (RI) lock	A LOTO lock applied by the LOTO responsible individual (RI) for the purpose of controlling a complex or group LOTO. It is identified by an RI LOTO lock tag. The keys to LOTO RI locks are controlled by the RI. LOTO RI locks also function as personal LOTO locks for the RI. 🚩The following instances of complex LOTO require an RI Lock(s): Group LOTO With a Lockbox (Work Process G) Tagout only (Work Process H) Multiple employers (Work Process I) Shift changes (Work Process J) Temporary partial restoration (Work Process K)🛑
LOTO Safe Zone	The portion of a system that has been placed in a safe work condition by executing the LOTO.
LOTO tag	A distinctive, durable tag approved by Berkeley Lab to identify a lockout device and the purpose of the lock. The LOTO tag is attached to the LOTO lock shackle. Different types of LOTO tags include: Personal LOTO tag RI LOTO tag Group LOTO tag Tagout Only tag
Normal production operations	The utilization of a machine or equipment to perform its intended production function
Personal LOTO lock	A LOTO lock issued to a LOTO Authorized Person for the purpose of individual control. No other person has the key or means of opening it.
🚩Physical separation	Physical separation is the condition in which the sources of hazardous energy are physically removed from the work area to such an extent that Lockout/Tagout is not feasible and not necessary.  See Work Process Q.🛑
Qualified Person	A person who, by reason of experience and instruction, has demonstrated familiarity with the construction, installation, maintenance, and operation of the equipment, installations, and the hazards involved, has been designated by the supervisor or work lead to perform work on equipment. This employee also is required to be current with all required qualification training.
Qualified Electrical Worker (QEW)	A qualified person specifically authorized to work on electrical systems. For specific requirements, see Chapter 8 Electrical Safety.
Safe Work Condition (Mode 0 for electrical work)	A condition whereby the equipment has been placed in a zero-energy state and controlled to prevent re-energization through the process of lockout. Equipment is not safe to work on until it is in a safe work condition.
Servicing and/or maintenance	Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, maintaining, and/or servicing machines or equipment. These activities include lubricating, cleaning, or unjamming machines or equipment; and making adjustments or tool changes where the employee may be exposed to the unexpected energization or start-up of the equipment or release of hazardous energy.
Setting up	Any work performed to prepare a machine or equipment to perform its normal production operation
Simple LOTO	A process to establish a LOTO on equipment without a written LOTO procedure, provided that the conditions of Work Process D are met.
🚩Simple LOTO for Cord and Plug	A process to establish a LOTO on equipment powered by a cord and plug, EHS0389, Simple LOTO for Cord-and-Plug Equipment.🛑
Stored energy source	Any device capable of holding hazardous energy after equipment shutdown. This includes, but is not limited to, capacitors, coaxial cables, tanks, pipes, springs, and flywheels.
Subcontractor LOTO Permit	A LOTO procedure designed for subcontractors who will be locking onto a LOTO.  The Subcontractor LOTO Permit🛑 incorporates the standard Berkeley Lab LOTO procedure format with a process to verify that subcontractors have received the appropriate training and supervision prior to participating in a LOTO.
Tagout only	The placement of a LOTO tag directly on an energy isolation because the energy isolation cannot accommodate a LOTO lock.
Trapped key interlock system	An access control system where a key is held captive until a certain condition is satisfied. When the key is released, it 🚩may be used to unlock a new enclosure, lock out another device, or be placed in a Group Lockbox as part of a complex LOTO procedure. 🛑
Zero Energy State	A condition reached when all hazardous energy sources to or within equipment are isolated, dissipated with no possibility of re-accumulation, and verified as absent through proper testing.
Zero Energy Verification (Mode 1 for electrical work)	A process to verify a zero energy state. For electrical energy, this is called zero voltage verification (ZVV).

18.7 Required Work Processes

Work Process A. LOTO Program Quick Reference Map
Work Process B. Basic LOTO Rules 
Work Process C. Cord-and-Plug Equipment 
Work Process D. Simple LOTO  
Work Process E. Complex LOTO  
Work Process F. Complex LOTO Requiring a Responsible Individual 
Work Process G. Group LOTO With a Lockbox 
Work Process H. Tagout Only 
Work Process I. Subcontractor LOTO Permit 
Work Process J. Shift Changes and Transfer of Control 
Work Process K. Temporary Partial Restoration 
Work Process L. LOTO Hardware 
Work Process M. Training and Authorization 
Work Process N. Developing LOTO Procedures 
Work Process O. Special Condition LOTO Lock Removal 
Work Process P. Periodic Inspections of LOTO Procedures 
🚩🚩Work Process P.1. LOTO Program Assurance Plan🛑
Work Process Q. Physical Separation
Work Process R. Interlock Systems 
Work Process S. Administrative Control 
Work Process T. LOTO Coordination 

 

Work Process A. LOTO Program Quick Reference Map

1. The following is a reference guide to the rest of this document. Its intent is to guide the reader to the appropriate work processes with a brief overview. Detailed requirements are found in the referenced sections.
2. An introduction to the core rules of LOTO is found in Work Process B, Basic LOTO Rules.
3. Cord-and-plug equipment is exempt from LOTO and may be controlled by anyone who has received basic electrical safety training. See Work Process C, Cord-and-Plug Equipment.
4. LOTO processes that can be performed directly by a LOTO Authorized Person are found in the following:
   1. Work Process D, Simple LOTO
   2. Work Process E, Complex LOTO
5. LOTO processes of a complex nature 🚩that are managed by🛑 a designated RI:
   1. Work Process F, Complex LOTO Requiring a Responsible Individual
   2. Work Process G, Group LOTO With a Lockbox
   3. Work Process H, Tagout Only
   4. Work Process I, Subcontractor LOTO
   5. Work Process J, Shift Change & Transfer of Control
   6. Work Process K, Temporary Partial Restoration
6. Additional programmatic requirements are found in the following sections:
   1. Work Process L, LOTO Hardware
   2. Work Process M, Training and Authorization
   3. Work Process N, Developing LOTO Procedures
   4. Work Process O, Special Condition LOTO Lock Removal
   5. Work Process P, Periodic Inspections of LOTO Procedures
   6. 🚩🚩Work Process P.1. LOTO Program Assurance Plan🛑
7. The following work processes are commonly associated with energy control but are not integral to the LOTO process. They describe how to properly integrate these work practices with the LOTO Program.
   1. Work Process Q, Physical Separation
   2. Work Process R, Interlock Systems
   3. Work Process S, Administrative Control
   4. Work Process T, LOTO Coordination
8. 🚩Additional Process Flows and Training Aids can be found here: https://electricalsafety.lbl.gov/loto/🛑

Work Process B. Basic LOTO Rules

1. Lockout/Tagout (LOTO) is the process of establishing a safe work condition on equipment prior to performing work. A safe work condition is established when the equipment has been placed in a verified zero-energy state and positively controlled to prevent unexpected re-energization.
2. Lockout/Tagout (LOTO) is required whenever construction, service, maintenance, modification, or demolition is being performed on or near equipment in which the unexpected energization or start-up of the equipment, or the release of hazardous stored energy, could cause injury to people or damage to equipment. This includes access to areas where it would be unsafe unless the equipment were shut down and de-energized.
3. All persons performing work on locked out equipment shall apply their personal LOTO lock(s) to that equipment. These persons shall be trained and authorized in accordance with Work Process M.
4. LOTO Authorized Persons shall only apply🚩 or remove🛑 their own personal LOTO lock(s). No person shall ever remove another person’s personal LOTO lock, except under the restrictions of Work Process O, Special Condition LOTO Lock Removal.
   1. Note: The system operator control method found in OSHA 1910.269(d)(8)(v) is not applicable or permitted at Berkeley Lab.

5. No person shall operate or attempt to operate any energy isolation to which a LOTO lock or tag is attached other than during the initial challenge when establishing the LOTO.
6. For all LOTO devices, the LOTO Authorized Person applying the LOTO device must be knowledgeable about the proper use and application of the device. LOTO devices that are improperly affixed, or that are used on energy isolations for which they were not designed, may fail to prevent actuation of the isolation or fall off entirely. For this reason:
   1. Upon initially applying the LOTO device, the isolation is challenged to ensure that it will not operate.
   2. After this initial challenge, other persons MUST NOT challenge the LOTO device. This is to prevent the unintentional energization when the LOTO device is improperly applied.
   3. If any person should suspect that a LOTO device has been improperly applied, they must immediately contact the LOTO Person In Charge for resolution. If necessary, the LOTO Person In Charge must stop work and have 🚩everyone locked on🛑 remove their personal locks in order to correct the discrepancy.

7. The LOTO Safe Zone is the extent of equipment that has been placed in a safe work condition. It is defined by the energy isolations that were selected for the LOTO.
   1. For work around electrical hazards, the shock thresholds listed as the Limited Approach Boundary in the LBNL Electrical Safety Manual shall be referenced.  These shall be the trigger distance for implementing an Electrically Safe Work Condition (Mode 0 work). Each individual must apply their personal LOTO lock(s) prior to working within the Limited Approach Boundary.
   2. There are some exceptions for visual inspections that can be found in section 6.6.8 Visual Inspections of the Electrical Safety Manual.

8. The LOTO Safe Zone must always encompass the entirety of the expected scope of work. If the scope of work is expected to shift outside of the LOTO Safe Zone, then the work must be stopped and the LOTO must be changed in order to accommodate the new scope of work.
9. All lockouts shall be established following the requirements in this program. Push buttons, selector switches, software interlocks, and control circuits are not energy isolations and cannot be used to isolate hazardous energy.
10. The LOTO Person In Charge of establishing a LOTO procedure must ensure that the LOTO Safe Zone matches the scope of work.  🚩Any LOTO Authorized Person locking onto the LOTO must understand the extent of the LOTO Safe Zone and remain vigilant that their scope of work does not extend beyond the LOTO Safe Zone.🛑
    1. Only 🚩persons who are LOTO Authorized and Qualified 🛑may perform the necessary manipulation and testing required to establish the lockout. This includes equipment shutdown, operation of isolation devices, releasing stored energy, and verification of de-energization. When work is finished, this requirement also includes restoration, re-energization, and start-up of the equipment.
11. 🚩🚩Formal LOTO Briefings and the LOTO Briefing Sheet/LOTO Log:
    1. A formal LOTO briefing is the process of verbally communicating the detailed specifics of the LOTO to all LOTO participants. This includes the Qualified Persons supporting the LOTO and the LOTO Authorized Persons who will be adding their personal LOTO locks once the LOTO is established. 
    2. The primary topics of these LOTO briefing are:
       1. Detailed description of the scope of work
       2. Detailed description of the LOTO Safe Zone
       3. Overview of expected conditions, or expected future modifications to the LOTO to support the work
       4. Discussion over what additional LOTO processes will be employed (such as transfer of control, temporary restoration for repositioning or testing, group lockbox, Tagout Only conditions, etc.)
    3. The LOTO briefing is a critical part of the LOTO process and required during certain LOTO situations for a LOTO Authorized Person and required at ALL  times for the Limited LOTO Authorized Person prior to applying personal LOTO locks.  See the LOTO Process Flow Job Aid for more details.  
    4. There are two types of LOTO briefings:  
       1. Before execution of the LOTO: This briefing is performed just before establishing the LOTO.  This briefing is conducted by the LOTO Person in Charge and typically focuses on the scope of work and the LOTO safe zone being established.  
       2. After the safe execution of the LOTO and the work zone is in a safe state: This briefing typically focuses on the type of work the employee will be performing in the LOTO Safe Zone and the boundaries of the LOTO Safe Zone.  
    5. The LOTO briefing is repeated:
       1. Any time a Limited LOTO Authorized Person needs to apply their personal LOTO lock(s) to any established LOTO.
       2. Any time a LOTO Authorized Person needs to apply their personal LOTO lock(s) to a LOTO managed by a LOTO Responsible Individual (RI).
       3. When a LOTO is being turned over to be managed by a LOTO Responsible Individual (RI) or a new LOTO Person in Charge is being assigned.  
       4. Before a shift change where a transfer of control needs to take place (Work Process J).
       5. Before and after temporary partial restoration (Work Process K).
       6. After a field change is performed (Work Process I).
    6. A documented LOTO Log must be signed:
       1. LOTO Person in Charge:
          1. When establishing a simple LOTO that involves Limited LOTO Authorized Persons.
          2. After establishing a complex LOTO with or without an RI.  
          3. When being assigned as a new LOTO Person in Charge from another LPiC.
       2. Limited LOTO Authorized Persons:
          1. Before the application of LOTO locks and clearing of LOTO locks for Simple LOTO, Complex LOTO and Complex LOTO with an RI.
       3. LOTO Authorized Persons:  
          1. Before the application of LOTO locks and clearing of LOTO locks for Complex LOTO and Complex LOTO with an RI.  

A LOTO Briefing Job Aid can be found with the LOTO Field Guides at: https://electricalsafety.lbl.gov/loto/.🛑

Work Process C. Cord-and-Plug Equipment

1. Cord-and-plug equipment refers to any electrical utilization equipment that uses a flexible cord and an attachment plug to connect to a source of hazardous energy.
2. Persons working under the cord-and-plug exemption are not required to be LOTO Authorized Persons. However, persons that perform work on electrical equipment under the cord-and-plug exemption may need to be Qualified Electrical Workers. See the Chapter 8 Electrical Safety program for more information.
3. Note that hard-wired electrical utilization equipment shall not be converted to cord-and-plug connection unless it meets the requirements and intent of NFPA 70 – National Electrical Code (NEC) Sections Article 400.7 and 400.8 and NRTL and manufacturer instructions.
4. Cord-and-plug equipment is exempt from LOTO controls when:
   1. All hazardous energy is controlled by unplugging the equipment, and
   2. The plug(s) remain(s) under the exclusive control of the worker performing the work. Under the exclusive control of the worker means that the authorized person has the authority to, and is continuously in a position to, prevent (exclude) other individuals from re-energizing or starting the machine or equipment while performing the servicing or maintenance activity.
      1. 🚩Note: Two or more people cannot simultaneously have exclusive control over the same set of plugs, so this effectively means that exclusive control is only possible when a person is working alone.🛑

5. For cord-and-plug equipment that does not meet the exemption requirements, the LOTO process shall be applied.
   1. If there is stored energy above hazardous thresholds listed in Table 2.2.13 of the LBNL Electrical Safety Manual, such as capacitors 100 V or greater and 10 Joules or greater, a Complex LOTO Procedure must be used.
   2. If exclusive control cannot be established and there is a single plug and no hazardous stored energy, Simple LOTO 🚩for Cord and Plug 🛑may be used. If, however, there are multiple cords, a Complex LOTO Procedure must be used.
   3. For equipment with a removable cable, it is suggested that you use a detachable cord plug lockout device like the one pictured below:

6. Examples that meet the requirements for the cord-and-plug exemption:
   1. A benchtop instrument with a 120 VAC, 15 Amp cord. It has no stored energy, and unplugging the cord completely removes all hazardous energy from the device.
   2. A welder with a 480 VAC, 100 Amp cord. It has no stored energy, and unplugging the cord completely removes all hazardous energy from the device.
   3. A bandsaw with a 120 VAC, 15 Amp cord. It has no stored energy, and unplugging the cord completely removes all hazardous energy from the device.
   4. A vacuum chamber where exclusive control can be established for all cables connected to it, and there is no possibility of coming into contact with any hazardous stored energy.

7. Examples that do not meet the requirements for the cord-and-plug exemption:
   1. Rack-mounted instrument with a 120 VAC, 15 Amp cord. The cord plugs into a power strip located in the back of the unit and is not accessible from the front. The worker needs to perform a task on the front of the panel and cannot see or control where the plug is located. A simple LOTO is required because exclusive control cannot be established.
   2. A benchtop laser with 120 VAC, 15 Amp cord and an internal capacitor bank with 25 J of stored energy. A complex LOTO procedure is required because of the hazardous stored energy.
   3. Equipment that has multiple cords where exclusive control cannot be maintained. In this case, LOTO would be considered complex and require a LOTO procedure.
   4. 🚩Two or more people are working simultaneously on the equipment.🛑

Work Process D. Simple LOTO  

1. The simple LOTO process is a LOTO that does not require an🚩 approved, written 🛑LOTO procedure.  This process may be used by a LOTO Authorized Person to establish a safe work condition prior to performing work. The LOTO Authorized Person is responsible for determining whether the conditions for the simple LOTO process are satisfied. If these conditions are not satisfied, then the LOTO Authorized Person shall follow the complex LOTO process. 🚩Subcontractor QEWs may be approved to perform Simple LOTO on hard-wired equipment without a Subcontractor LOTO Permit. See Work Process I.🛑
2. Conditions: The simple LOTO process is allowed only if all of the following conditions are met:
   1. The machine or equipment has no potential for hazardous stored or residual energy or reaccumulation of hazardous stored energy after shut down which could endanger employees.
   2. The machine or equipment has a single energy source which can be readily identified and isolated.
   3. The isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment.
   4. The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
   5. The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance.
   6. The servicing or maintenance does not create hazards for other employees.
   7. There have been no known accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.

3. For major process/equipment overhaul, rebuilds, etc., which do not require any Subcontractors, but consist of multiple crews, crafts or departments made up of LBNL LOTO Authorized Persons all performing LOTO under the Simple LOTO criteria, a decision may be made by the LOTO Authorized Person or Division ESO to require a complex LOTO Procedure.
4. In order to execute the simple LOTO process, the LOTO Authorized Person shall also be a Qualified Person on the system.    
   1. 🚩Additional LOTO Authorized Persons can add their lock to the isolation.
   2. If Limited LOTO Authorized Persons are participating, a LOTO Person in Charge must be assigned, a briefing sheet will be required and must be signed after receiving the required LOTO briefing from the LOTO Person in Charge.
   3. Only LBNL Qualified Electrical Workers, as designated in the Chapter 8 Electrical Safety Program, may perform work on electrical circuits that operate at voltages greater than the hazardous thresholds outlined in Chapter 8; Table D-1.  This includes establishing LOTO on equipment where zero voltage verification needs to be performed.🛑
   4. For other forms of hazardous energy, this qualification depends on line-management authorization.

5. Establish the LOTO.
   1. Step 1 — Identify energy source and related hazards/controls.
      1. Assess the type, magnitude, and hazards of the energy to be controlled. If there is more than one energy source, or if there is a source of hazardous stored energy, then the simple LOTO method may not be used. Follow the complex LOTO method instead.
      2. Determine the appropriate method for controlling the source of hazardous energy. Methods for energy isolation may include such things as circuit breakers, disconnect switches, or valves. Remember that control circuits such as push buttons, selector switches, emergency stops, contactors, and remotely operated valves are not energy isolations.
      3. Determine the appropriate safe work practices for performing the isolation and verification of zero-energy state. Only a Qualified Person wearing proper PPE may operate the isolation and perform verification of zero-energy state.
   2. Step 2 — Notify affected persons.
      1. Notify all Affected Persons of the impending shutdown and lockout. These persons must be informed that they are not to disturb the lockout device or attempt to restart the equipment until they are informed that the lockout has been cleared and it is safe to resume normal operations.
   3. Step 3 — Shut down equipment.
      1. Verify that it is safe to shut down equipment, then perform normal equipment shutdown. Turn off or shut down the equipment using the established method for that equipment.
   4. Step 4 — Isolate energy source.
      1. Identify the correct energy-isolation device before operation. Take steps to ensure that the means used (disconnect, valve, etc.) for energy isolation correctly corresponds to the equipment on which LOTO is being performed. Check the isolation label and match it to the label on the equipment. Take special care with look-alike equipment.
      2. Isolate the energy source by operating the energy isolation (switch off, valve off, etc.).
   5. Step 5 — Apply LOTO lock and tag.
      1. Equipment design may require performing the verification in Step 6 prior to the application of lock and tag.
      2. 🚩Apply the required LOTO device to the energy isolation in such a way that it physically prohibits operation of the energy isolation. Always allow for the possibility that another person may need to join the LOTO; use  a LOTO hasp if necessary to leave space for additional persons to lock on. Apply the personal LOTO lock and tag to the LOTO isolation, LOTO device, or LOTO hasp as appropriate. Write name, phone number, and any other relevant information on the LOTO tag.🛑
   6. Step 6 — Verify proper isolation.
      1. Challenge the LOTO:
         1. DO NOT ATTEMPT TO OPERATE THE ENERGY ISOLATION IF ANY OTHER LOTO LOCK IS ALREADY APPLIED. DOING SO COULD RESULT IN INADVERTENT ENERGIZATION OF THE SYSTEM AND EXPOSE PERSONNEL TO HAZARDOUS ENERGY.
         2. EVERY TIME: Challenge your personal LOTO lock to ensure that the lock is fully latched.
         3. ONLY IF YOU ARE APPLYING THE FIRST LOTO LOCK: Challenge the LOTO device to ensure that it cannot be removed from the isolation.
         4. ONLY IF YOU ARE APPLYING THE FIRST LOTO LOCK: Challenge the energy isolation to ensure it will not operate.
      2. Attempt to start equipment:
         1. Attempt to restart the equipment using the normal equipment controls.
         2. Verify the equipment will not power up or start.
      3. Verify zero energy:
         1. Test the energy source using appropriately rated instruments.
         2. Any instrument used to test for voltage, pressure, or temperature shall be checked for proper operation both before and after use on a known live source.
         3. The test point must be directly connected to the energy isolation. There cannot be other system components (such as check valves, contactors, other in-line switches or fuses) between the test point and the isolation, as these may mask the presence of energy on a deficient isolation.
         4. All energy is to be treated as present until positively proven otherwise. This means that applicable safe work practices and required PPE shall be used to perform the test for zero-energy state.

6. Perform the Work
   1. The lockout shall remain in place for the duration of work.
   2. Other LOTO Authorized Persons may join the LOTO by applying their personal LOTO lock and tag
   3. 🚩Limited LOTO Authorized Persons will require a LOTO briefing and will need to sign the briefing sheet to acknowledge having received the briefing.🛑
   4. 🚩Everyone locked on🛑 must remain vigilant and ensure that the scope of work does not extend out of the LOTO Safe Zone. If the persons performing work identify a task that falls out of the LOTO Safe Zone, then work will be stopped and a decision will be made either to modify the LOTO or to forgo the work until the LOTO can be modified.

7. Release from LOTO
   1. Step 1 — Confirm It Is Safe to Re-energize
      1. Confirm that the work for which the LOTO was applied has been completed and that it is safe to re-energize equipment. Clear all tools and personnel. Check the work area to ensure that all tools, debris, and personnel are at a safe distance from the equipment. Replace safety guards. Check the equipment to ensure that any removed guards are reinstalled.
      2. Confirm that all safety inspections have been performed.
      3. Confirm that all employees are in a safe position. Ensure all persons remain clear of the equipment’s point of operation or hazard zone.
   2. Step 2 — Remove LOTO Locks and Tags
      1. Remove all personal LOTO lock(s) and tag(s) from the isolation. Each personal LOTO lock shall only be removed by the LOTO Authorized Person who applied it.
      2. Exception: If the person who placed the lock and tag is not available, the procedure for Absent Person removal of LOTO devices shall be followed (Work Process O).
   3. Step 3 — Notify all Affected Persons that the LOTO has been released and equipment will be re-energized.
   4. Step 4 — Re-energize and restore the equipment to the normal condition.
8. Simple LOTO Continuing for More Than One Work Period
   1. Equipment that will be placed out-of-service for an extended period of time may be controlled using an administrative lock (Work Process S) instead of a LOTO lock when no work is being performed.
   2. Alternatively, a Simple LOTO may remain in place while work is not being performed when the equipment is not safe to be reenergized.

Work Process E. Complex LOTO

1. The complex LOTO process is triggered anytime the conditions for the simple LOTO (Work Process D) cannot be met. It requires an approved written LOTO procedure, or a Subcontractor LOTO Permit if a Subcontractor will be participating in the LOTO, and a designated LOTO Person In Charge who is accountable for the safe execution of the LOTO.🛑
2. For complex LOTOs involving group LOTO with a Lockbox, Tagout Only, multiple employers, temporary partial restoration, or shift changes that require a transfer of ownership, Work Process F, Complex LOTO Requiring a Responsible Individual, must be followed.
3. Every complex LOTO shall have an approved written LOTO procedure that meets the requirements of Work Process N.
   1. The LOTO procedure is a formal written document, approved by a LOTO Approver, which details the scope of work performed under the LOTO and the energy isolations to be established.
   2. The LOTO procedure also details, where required, the method of hazardous stored energy dissipation and any specific sequence required for the shutdown.
   3. The LOTO procedure must be documented each time it is performed. There are two ways of documenting, routine and non-routine:
      1. For non-routine LOTO procedures, procedures should be printed out and posted at the jobsite or otherwise made available for LOTO Authorized Persons to reference.
      2. Routine LOTO procedures are equipment specific LOTO procedures that are performed over and over without change. When used, it’s strongly suggested that routine LOTO procedures be posted at the equipment. The purpose of posting a routine LOTO procedure is so that it does not have to be reprinted for each use.  Check to make sure the scope of work matches the procedure and then complete the LOTO log associated with that procedure.
   4. These documents should be kept within your division for auditing purposes.
4. In order to execute a complex LOTO, the LOTO Authorized Person should also be a properly Qualified Person on the equipment. If a LOTO Authorized Person requires a complex LOTO but is not a Qualified Person on the system, the LOTO Authorized Person must request assistance from a properly LOTO Authorized and Qualified Person. This person will be the LOTO Person in Charge.  
   1. If the initial LOTO Person in Charge establishing the LOTO will not be staying the duration of the LOTO, they must transfer their LOTO Person in Charge role to another equally trained and Qualified Person (Work Process B.11). After the new LOTO Person in Charge fully understands the LOTO safe zone that has been set, then they shall apply their personal LOTO locks to all isolations and the outgoing LOTO Person in Charge can remove their LOTO locks. This transfer shall be documented on a LOTO Briefing Sheet/LOTO Log.  
   2. Only LBNL Qualified Electrical Workers, as designated in the Chapter 8 Electrical Safety Program, may perform work on electrical circuits that operate at voltages greater than the hazardous thresholds outlined in Table D-1.  This includes establishing LOTO on equipment where zero voltage verification needs to be performed🛑.
   3. For other forms of hazardous energy, this qualification depends on line-management authorization.
5. Establishing the Complex LOTO
   1. Step 1 — Preparation
      1. 🚩Determine whether you are a Qualified Person who has been trained to operate the isolations and perform zero-energy verifications described in the LOTO procedure. If not, contact a Qualified Person and have him or her assist you in executing the LOTO procedure.🛑
      2. Print out and review the LOTO procedure. Verify that the scope of work to be performed is described in the LOTO procedure, and that the LOTO Safe Zone is adequate for all planned work.
      3. If the LOTO procedure requires revision or is otherwise inadequate, STOP WORK and contact the equipment owner to obtain the proper LOTO procedure.
      4. 🚩Perform a job briefing as outlined in Work Process B.11 (even if you’re working alone).  
         1. Do you understand the scope of work
         2. Do you have the appropriate LOTO equipment required to lockout the isolations; LOTO locks, tags, isolation devices?🛑
   2. Step 2 — Notification
      1. Notify all Affected Persons of the impending shutdown and lockout. Affected Persons must be informed that they are not to disturb the lockout devices or attempt to start up the equipment until they are informed that the LOTO has been cleared and it is safe to resume normal operations.
   3. Step 3 — Follow the LOTO Procedure
      1. Shut down the equipment. Some LOTO procedures will have a required sequence to properly shut down the equipment. This will be attached to the isolation checklist and must be followed exactly as described.
      2. 🚩For each isolation listed on the LOTO procedure, the simple LOTO steps from Work Process D are followed, including:
         1. Shutdown
         2. Isolation
         3. Application of locks and tags to all isolations listed on the procedure
         4. Verification: Challenge/Attempt to Start/Zero Energy🛑
      3. Using the isolation checklist, verify that 🚩all isolations have been locked out🛑 and that absence of energy has been positively verified. It is not acceptable to only lockout some of the isolations listed on the LOTO procedure.
      4. Some isolations may also require stored energy dissipation. The exact method of dissipation will be described in the LOTO procedure.
      5. Sign off 🚩on the LOTO Briefing Sheet/LOTO Log🛑 to indicate that the LOTO procedure has been established.
      6. Post the completed LOTO procedure next to the work area.
6. Performing Work under a Complex LOTO
   1. The lockout shall remain in place until work on the equipment is complete.
   2. Other LOTO Authorized Persons may join the LOTO:
      1. 🚩LOTO Authorized Persons shall🛑 review the LOTO procedure and verify the scope of work and isolations creating the LOTO safe zone match the scope of work that will be performed. They shall then apply their personal LOTO locks and tags to each of the energy isolations listed in the LOTO procedure and then sign the LOTO Briefing Sheet/LOTO Log.
      2. 🚩Limited LOTO Authorized Persons will need to contact the LOTO Person in Charge listed on the LOTO Briefing Sheet for the job and get a briefing before applying their personal locks. 🛑
   3. 🚩Everyone locked on 🛑 must remain vigilant and ensure that the scope of work does not extend beyond the LOTO Safe Zone. If the persons performing work identify a task that falls out of the LOTO Safe Zone, then work will be stopped and a decision will be made either to submit a new LOTO procedure for approval or to forgo the work until the LOTO can be modified.
   4. If it is necessary to temporarily remove only one or some LOTO devices before work is complete, such as for testing or repositioning equipment, a Responsible Individual must be assigned according to Work Process F before following Work Process K, Temporary Partial Restoration.
7. Releasing the Complex LOTO
   1. Step 1 — Confirm That It Is Safe to Re-energize.
      1. Confirm that the work for which the LOTO was applied has been completed and that it is safe to re-energize equipment. Clear all tools and personnel. Check the work area to ensure that all tools, debris, and personnel are at a safe distance from the equipment. Replace safety guards. Check the equipment to ensure that any removed guards are reinstalled.
      2. Confirm that all safety inspections have been performed and all return to service steps have been completed per the requirements listed in the LOTO procedure.
      3. Confirm that all employees are in a safe position. Ensure all persons remain clear of the equipment’s point of operation or hazard zone.
   2. Step 2 — Removal of Locks and Tags
      1. Remove LOTO lock(s) and tag(s) and sign 🚩the LOTO Briefing Sheet/LOTO Log🛑. Personal LOTO locks shall only be removed by the LOTO Authorized Person who applied it.
         1. 🚩Exception: If the person who placed the lock and tag is not available, the procedure for Absent Person removal of LOTO devices shall be followed (Work Process O)🛑
   3. Step 3 — Notify all affected persons that the LOTO has been released and equipment will be re-energized.
   4. Step 4 — Re-energize and restore the equipment to the normal condition.
   5. Step 5 — Sign off the LOTO Briefing Sheet/LOTO Log to indicate that the complex LOTO has been cleared. 🚩Follow the archive process set up within the division.🛑

Work Process F. Complex LOTO Requiring a Responsible Individual

1. The Responsible Individual (RI) is a LOTO Authorized Person  who has been trained to properly manage work activities under the LOTO procedures of a more complex nature than those allowed under Work Process E.
2. The following instances of complex LOTO require a Responsible Individual:
   1. Group LOTO With a Lockbox (Work Process G)
   2. Tagout Only (Work Process H)
   3. Multiple employers (Work Process I)
   4. Shift changes that require a transfer of ownership between shifts (Work Process J)
   5. Temporary partial restoration (Work Process K)
3. Designating an RI for a particular LOTO procedure triggers the following additional requirements:
   1. RI LOTO locks and tags
   2. Formal LOTO briefing 🚩including all LOTO Authorized Persons (Work Process B.11)🛑
4. RI LOTO Locks
   1. An RI LOTO lock is a LOTO lock applied by the RI of a particular lockout. It is identified by the RI LOTO tag attached to the LOTO lock. The RI LOTO locks enable the RI to maintain positive control of the isolations.
   2. An RI LOTO lock applied to an energy isolation indicates that:
      1. This particular isolation was performed for the purpose of LOTO
      2. All verification steps were completed satisfactorily and witnessed by the RI
      3. This particular isolation has been maintained under continuous positive control by the RI since performing the verification steps
   3. RI LOTO locks allow the RI to witness the verification of zero-energy state without passing on that requirement to subcontractors.
   4. RI LOTO locks also function as personal LOTO locks for the RI.

5. The Responsible Individual must identify conditions where additional measures may be required to ensure the safety of all persons involved in the LOTO. These conditions include situations where the LOTO Safe Zone is difficult to readily identify, or where multiple changes in scope result in transitions from one LOTO permit to the next. 🚩It is up to the RI to call upon the help of their DESO or the HEC Group for additional assistance. 🛑Additional measures may include added supervision, special temporary marking of equipment, or additional LOTO briefings.
6. Steps for implementing the Complex LOTO by a Responsible Individual 🚩shall follow the steps listed in Work Process E🛑  (these might be different within your Division, so check with your DESO/DESA to make sure your Division does not have an internal LOTO Program). 🚩LOTO with an RI differs from complex LOTO without an RI for the following reasons: 🛑Steps for implementing the Complex LOTO by a Responsible Individual 🚩shall follow the steps listed in Work Process E🛑  (these might be different within your Division, so check with your DESO/DESA to make sure your Division does not have an internal LOTO Program). LOTO with an RI differs from complex LOTO without an RI for the following reasons: 🛑
   1. For each isolation, the Responsible Individual must 🚩secure each isolation with the appropriate lock and tag.  First lock on and the last lock off. 🛑
   2. 🚩If the RI is not the Qualified Person establishing LOTO, they must witness the establishment of LOTO to ALL isolations, including the zero energy verification. 🛑
   3. The Responsible Individual must brief all the LOTO Authorized Persons 🚩and Limited LOTO Authorized Persons🛑 before they apply personal locks to the isolations or lockbox(es).
   4. The Responsible Individual can remove the RI lock from the isolations or lockbox(es) and the equipment can be returned to service by the equipment owner once the following has occurred:
      1. All the work has been completed.
      2. All safety inspections have been performed and all return to service steps have been completed.
      3. After each LOTO Authorized Person has removed his/her respective personal LOTO locks from the isolations or lockbox(es) and signs the LOTO Briefing Sheet/LOTO Log.

Work Process G. Group LOTO With a Lockbox

1. A group LOTO is a process used to perform a complex LOTO with a lockbox. Instead of applying personal LOTO locks to each energy isolation, the energy isolations are locked out with group LOTO locks. The keys to the group LOTO locks are placed in the lockbox, which is then locked by the Responsible Individual (RI) and each LOTO Authorized Person.
2. The RI may elect to use the Group LOTO process at any time to better facilitate the coordination of a LOTO. Group LOTO is required when performing Tagout Only (Work Process H). Otherwise, group LOTO is not required but may present a desirable solution to effectively manage a large number of persons or isolations.
3. Group LOTO Locks
   1. A group LOTO lock is a LOTO lock used specifically for group LOTO. It is identified by the group LOTO tag attached to the LOTO lock.
   2. A group LOTO lock is applied by the RI to each energy isolation during the execution of a group LOTO procedure. The keys to the group LOTO locks are then placed in a lockbox, which is then locked with an RI lock. Group LOTO locks are mandatory for the group LOTO method.
   3. A group LOTO lock applied to either an energy isolation device or to another lockbox indicates that:
      1. A particular isolation was 🚩locked out🛑 for the purpose of group LOTO
      2. All verification steps were completed satisfactorily and witnessed by the RI
      3. This particular energy isolation has been maintained under continuous positive control by the RI since performing the verification steps

 

4. Steps to Implement a Group LOTO With a Lockbox
   1. The RI determines that the group LOTO work process is appropriate.
   2. The RI manages the execution of  the written LOTO procedure as described in Work Process F.
   3. Instead of RI Locks, the RI must apply group LOTO locks to the energy isolations 🚩or to hasps attached to those isolations.🛑
   4. The RI shall place the group LOTO lock keys inside a lockbox.
   5. The RI must lock the lockbox closed with an RI lock and tag on the outside of the lockbox.
   6. The RI must attach the completed LOTO procedure to the lockbox.
   7. Each lockbox will be clearly identified with the associated LOTO Permit or Procedure number.🛑🚩Each lockbox will be clearly identified with the associated LOTO Permit or Procedure number.🛑
   8. The RI must brief all LOTO Authorized Persons before they apply personal locks to the lockbox (or any isolation if conditions in 5.b below is requested).
   9. All other workers performing work on the equipment satisfy themselves that the group LOTO procedure has been completed, and then apply their personal LOTO lock and tag to the lockbox in a manner that prevents access to the enclosed key(s) until all locks have been removed from the box.
   10. When the work has been completed, and after each worker has removed his/her respective personal LOTO lock from the lockbox and signed off on the LOTO Briefing Sheet/LOTO Log, the RI removes their RI lock from the outside of the lockbox, obtains the group LOTO lock keys from the lockbox, removes the group LOTO locks, and the equipment can be returned to service by the equipment owner.
5. There are times where the RI must take additional measures to accommodate a LOTO Authorized Person who has concerns about a group LOTO or who is not fully satisfied with the group LOTO method. The RI shall make necessary arrangements to accommodate such requests.
   1. Any LOTO Authorized Person may request to either witness the verification or reverification of zero-energy state on some or all of the energy isolations. In this case, the RI must coordinate with a Qualified Person to perform the requested verifications.
   2. Any LOTO Authorized Person may request to not participate in the group LOTO and instead apply personal LOTO locks directly to the isolations, next to the group LOTO locks. The LOTO must then be treated as a complex LOTO under Work Process F. Under the direction of the RI, who must be physically present, the LOTO Authorized Person must apply their personal LOTO locks to each energy isolation listed on the LOTO procedure without exception.
6. Location
   1. Once established, the LOTO lockbox must be kept in a location that is accessible to the LOTO Authorized Persons participating in the group LOTO.
7. Pyramiding
   1. One or more lockboxes can be referenced under a master complex LOTO procedure or another group LOTO procedure. This is useful when managing lockouts with extensive scope and complexity.
   2. There must be only one group LOTO procedure per lockbox. If it is necessary to group multiple LOTO procedures under one master lockbox, each procedure must first be built into its own separate group LOTO. When pyramiding lockboxes, each lockbox must have its own LOTO procedure attached to the lockbox. The master lockbox LOTO procedure must reference each subordinate lockbox 🚩on the master lockbox permit.🛑

Work Process H. Tagout Only

1. “Tagout only” is the practice of applying a LOTO tag without a LOTO lock, where the physical construction of the energy isolation does not accommodate the attachment of a lock.
2. Extra caution shall be exercised when using a Tagout Only procedure. Tags may evoke a false sense of security. Tags are warning devices and do not provide the physical restraint provided by a lock.
3. Criteria:
   1. In the rare case that a device is not capable of being locked out, this Work Process H may be used, subject to the following conditions:
      1. A justifiable and verifiable need must be identified.
      2. Formal approval must be obtained from the immediate supervisor or other line management.
      3. Any energy isolation capable of being locked shall be locked WITHOUT EXCEPTION.
4. Examples of Tagout Only situations include:
   1. Circuit breakers actuated by handles mounted on the exterior of a panel door
      1. When work is required inside the enclosure, opening the enclosure disconnects the actuating handle from the breaker. This defeats the application of a LOTO lock on the handle, and there is usually no physical means to apply a lock inside the enclosure, directly to the breaker.
      2. In this case, a tagout must be applied to the breaker inside the enclosure. Additional measures can include removing the actuator-connecting bar or also tagging out the handle on the door. The concern is that, should the door be closed, the handle could be operated, closing the breaker.
   2. Street valves located in deep holes with no possible means of attaching a lockout device

Tag-out only used because the manhole cover cannot be locked to the street.

c. Fuse removal
d. Blanking, blocking, blind flanging, or capping a pipe system

5. Performing a Tagout Only procedure requires a secondary measure. At Berkeley Lab, the secondary measure consists of using a serialized LOTO tag. 🚩The Tag-out only LOTO tag must have the same serial number printed on its top and bottom portions, which are separated by a perforation in the tag to make it easy to remove the bottom portion (the “stub”). The RI attaches the top portion to the isolation and detaches the tag’s bottom stub. The stub goes into a lockbox where it performs a function analogous to the Group LOTO key in a Group LOTO. All other participants in the LOTO lock onto the lockbox.🛑
6. Procedure
   1. Tagout must only be conducted under group LOTO With a Lockbox (Work Process G).
   2. To tag out an isolation, the Responsible Individual must follow all the steps outlined in the group LOTO Work Process G, with the following changes:
      1. The written LOTO procedure line item for the isolation to be tagged out must indicate:
         1. That the isolation is “TAGOUT ONLY”
         2. The serial number of the group LOTO tag (May be handwritten)
      2. Directly affix to the isolating device a serialized tagout tag with a detachable stub instead of a group LOTO lock and tag.
      3. The tag attachment means shall be capable of withstanding at least 50 pounds of force exerted at a right angle to the disconnecting means’ surface.
      4. The tag attachment means shall be non-reusable, attachable by hand, self-locking, and non-releasable, equal to an all-environment-tolerant nylon cable tie.
      5. Tear off the tagout tag stub and place it in the lockbox. Write the tag serial number onto the group LOTO procedure.
      6. Complete the group LOTO procedure. Once the procedure is completed, the RI locks the box with the RI lock. All persons performing work under the tagout will then apply their personal LOTO locks to the lockbox.
      7. 🚩When it’s time to release the LOTO, all participants unlock from the lockbox so the RI can retrieve the Tag-Out only tag stub. The RI must then verify that the serial number on the stub matches the serial number on the top portion of the tag on the isolation before releasing the isolation. If the serial numbers do not match, the isolation must not be released. 🛑

Work Process I. Subcontractor LOTO Permit

1. The subcontractor LOTO permit is a Complex LOTO procedure designed for subcontractors who will be performing simple as well as complex LOTO. It incorporates the standard Berkeley Lab LOTO procedure format with a process to verify that subcontractors have received the appropriate training and supervision prior to participating in a LOTO.
2. All subcontractors performing work for Berkeley Lab are required to conform to the Berkeley Lab LOTO Program. This Work Process I contains additional requirements to ensure that subcontractors are adequately managed and protected from hazardous energy exposures. The subcontractor LOTO permit process is in place to implement these requirements.
3. Subcontractors include all construction and non-construction subcontractors, all vendors, and all manufacturer representatives or other persons performing or participating in LOTO who are not covered under the Berkeley Lab employee Chapter 6 Work Planning and Control and are therefore not subject to employee LOTO training and authorization requirements.
4. All subcontractor LOTO permits require a designated LOTO Responsible Individual (RI) and are implemented by following Work Process F, Complex LOTO Requiring a Responsible Individual. The Subcontractor LOTO permit may waive the requirement for RI locks on a case-by-case basis.
5. The LOTO RI, or designee, submits Subcontractor LOTO permit requests to the LOTO Permit Database. The requests are reviewed and approved by the designated LOTO Approver who is responsible for the area involved. Prior to participating in any LOTO, subcontractors must have an approved and printed subcontractor LOTO permit and must be briefed by the designated LOTO RI.
6. Subcontractors/vendors are expected to provide their own LOTO equipment. Berkeley Lab may loan LOTO hardware as needed to meet urgent operational necessities. All subcontractor LOTO hardware must meet the requirements set in Work Process L.
7. Only Subcontractor Qualified Electrical Workers (QEWs) who have been separately and individually approved under the Electrical Safety Program may perform their own zero voltage verification (ZVV) on electrical lockouts. See the Chapter 8 Electrical Safety program for more information.
8. Subcontractor QEWs may be approved to perform Simple LOTO on hard-wired equipment without a Subcontractor LOTO Permit provided that:
   1. All conditions for Simple LOTO in Work Process D are met.
   2. They complete EHS0370, Lockout/Tagout for Authorized Persons
   3. The equipment is labeled with an up-to-date arc flash label.
   4. Approval is obtained from the🚩 Laboratory Electrical Safety Officer.🛑 Note: 🚩Approval 🛑is normally restricted to new building construction projects and is specified in the project’s Electrical Energization Plan.
9. Cord-and-plug equipment:
   1. Cord-and-plug equipment is exempt from LOTO provided it meets the requirements of Work Process C.
   2. Where exclusive control of a single plug cannot be achieved and there is no hazardous stored energy, a Simple LOTO may be used without a Responsible Individual (RI) or Subcontractor LOTO Permit, but the Subcontractor employee will need to complete the course EHS0379, Subcontractor Lockout/Tagout online and add their personal lock and tag to the LOTO device.
   3. If 🚩9.a or 9.b do not apply,🛑 then a Subcontractor LOTO Permit must be obtained.  This Subcontractor LOTO Permit can act as your LOTO procedure for the equipment.
10. RI Responsibilities for the LOTO Permit
    1. The RI must ensure that all requirements of Work Process F are followed when implementing the LOTO permit.
    2. In addition, the Responsible Individual must in the course of the LOTO briefing ensure that all subcontractors participating in the LOTO fully understand their responsibilities. Special emphasis must be placed on the following:
       1. Clearly defining the scope of work allowed under the LOTO permit
       2. Clearly defining the extent of the LOTO Safe Zone
       3. Specifying that any 🚩participant who needs to deviate from the original planned scope of work must consult with the RI BEFORE proceeding with any such work. 🛑 
       4. Specifying that all personnel participating in the LOTO must be personally locked out with a red LOTO lock and tag for the duration of their work
       5. Specifying that no new person can participate in the LOTO without first contacting the Responsible Individual and obtaining a LOTO briefing
    3. Upon completion of the LOTO, the Responsible Individual shall follow the archive process set up within the division. 🛑
11. LOTO Permit Expiration Dates
    1. Construction LOTO Permits:
       1. There are times where a permit might need to be implemented several times over the course of a project.  
       2. LOTO Permits in the database expire 60 days from the date of approval and the “Print” 🚩button will disappear.  The RI will need to get an extension from a DESO, HEC Group, or the Electrical Safety Group 🛑to extend the length of that permit and be able to print it again.
       3. Permits hanging in the field DO NOT EXPIRE as long as they have not been 🚩released from LOTO🛑.
    2. Non-Construction LOTO Permits:
       1. These permits are often issued for programmatic equipment and conditions often do not change after initial review.
       2. These permits do not expire in the database as long as the following stays the same:
          1. There is no change in the initial isolation point(s).
          2. The scope of work and company performing the zero energy verification remains the same.
          3. The Subcontractor has taken EHS0379 within the past three years.  
12. EHS Division Responsibilities
    1. 🚩Review Subcontractor LOTO Permits as part of the audit process outlined in the EHS Assurance Program.
    2. Maintain the Quickbase Database used for the Subcontractor LOTO Permit process.🛑 
13. Field changes
    1. A field change is a pen and ink markup of a LOTO Permit that corrects an error discovered during the execution of the LOTO. Field changes to LOTO Permits may be allowed with certain restrictions.
    2. Only certain types of field changes are allowed:
       1. Improper Labeling: A difference in information on permit vs. panel
       2. Change in Scope of Work: Scope change after permit approval. This is only allowed when the new scope of work is determined to be clearly within the LOTO safe zone.
       3. Additional Energy Source Discovered: Energy source discovered during zero energy verification
       4. Isolation Not Required
       5. Other: Small change to information in area affected or special instructions
    3. A field change record sheet must be completed for any field change. Authorization must be obtained verbally from a 🚩DESO, HEC Group, or the Electrical Safety Group🛑 and can be done over the phone.
    4. A field change will not be approved in the following conditions. Contact a LOTO Coordinator for assistance with modifying the permit instead:
       1. If there is time to modify the electronic version of the permit instead.
       2. If the change represents a significant departure from the original LOTO Safe Zone or scope of work.
       3. If there is the possibility of confusion about the permit.
    5. All field changes will be briefed by the RI.
    6. Once a field change has been noted in the LOTO Permit Database, the “print” button will disappear and the permit will need to be updated before it is implemented again.  

Work Process J. Shift Changes and Transfer of Control

1. Shift changes and transfer of control present additional challenges and barriers to proper communication in a complex LOTO situation. It is imperative that the Responsible Individual (RI) makes every effort to sufficiently manage the scope of work and the extent of the LOTO Safe Zone.
2. If equipment will remain locked out after the end of a shift, and work will continue by the incoming shift, an orderly transfer of 🚩control of the isolations🛑 between LOTO Authorized Persons from the outgoing and incoming shifts must be performed.
3. If the simple LOTO method was used, a shift change does not require transitioning to a complex LOTO with an assigned Responsible Individual.
4. The RI for the LOTO must manage all shift changes. Transfer of control from one RI to another must occur separately from the shift change process to minimize confusion.
5. Shift Change
   1. It is recommended, but not required, that all LOTO Authorized Persons in the outgoing shift remove their personal locks prior to going home at the end of the shift. The RI locks must stay in place to maintain continuity of the lockout. The lead worker or supervisor may also maintain a personal lock as desired.
   2. The 🚩outgoing shift🛑 RI must ensure that the incoming shift is updated on the progress of work from the outgoing shift. All changes in scope of work and the LOTO Safe Zone during the previous shift must be thoroughly explained to the incoming shift.
   3. Note that an administrative lock alone is not sufficient to maintain the integrity of a LOTO. As the LOTO Authorized Persons from the outgoing shift remove their personal LOTO locks, the RI must ensure that the RI locks remain in place.
   4. 🚩It is strongly suggested that a LOTO briefing is provided by the Responsible Individual prior to LOTO Authorized Persons proceeding with work at the beginning of each shift. An easy way to control this is to have each LOTO Authorized Person remove their lock(s) at the end of each day and sign the LOTO Log.  The next morning when they return, they get a briefing and sign the LOTO Log again when they apply their LOTO locks and tags. 🛑
6. Transfer of Control when an RI is involved
   1. The outgoing RI may transfer control of the LOTO to an incoming RI at any time either before or after the LOTO is completely established. Transfer of control is not permitted while the LOTO is being established or during any modification, such as a field change or temporary restoration of power for testing or repositioning.
   2. The outgoing RI must thoroughly brief the incoming RI on the status of the LOTO, including all isolations, energy dissipation devices, scope of work, completion status of the work, and expected changes to the LOTO that will be required as the work progresses. The incoming RI must inspect all isolations related to the LOTO and verify that each is properly locked out. At each energy isolation, the incoming RI must apply his or her RI lock first, and then the outgoing RI must remove his or her lock.
   3. When the incoming RI is satisfied that he or she is fully briefed on all aspects of the LOTO, the incoming RI must agree to assume the role of RI for the LOTO. The outgoing RI must then hand over the LOTO procedure to the incoming RI as part of the transfer. If transferring a group LOTO, the outgoing RI must also transfer all related lockboxes and procedures. Once transferred, the incoming RI assumes all RI responsibilities for the LOTO.
7. Re-verification of Zero Energy State
   1. As long as the RI locks remain in place on the isolations (or if in the case of a group LOTO with a lockbox, the group locks remain in place on the isolations, and the RI lock remains in place on the lockbox), then re-verification of zero-energy state is not required at the beginning of each shift or upon transfer of control. Should any 🚩isolation become unlocked at any time,🛑 re-verification of zero-energy state is required prior to allowing any LOTO Authorized Person to apply their personal LOTO lock.
   2. 🚩Supplementary Voltage Checks may be performed at any time, and must be performed under certain conditions outlined in the Electrical Safety Manual, section 9.5.  If the equipment is discovered energized again, the worker shall immediately stop work, notify the division ESO/ESA and notify the Laboratory ESO.  Do not proceed with work.  This is a formal stop work condition.  Establish a barricade and/or an attendant around the area.🛑

 

Work Process K. Temporary Partial Restoration

1. Temporary partial restoration is the process of restoring energy to a part of the system without clearing the entire LOTO. This is only done for a short period of time, under continuous supervision by an assigned Responsible Individual (RI).
2. This applies to a complex LOTO with two or more isolations and may be helpful when the equipment needs some level of energized testing or repositioning. Examples include:
   1. Energized testing
   2. Troubleshooting and diagnostics
   3. Rotation checks
   4. Rotating or repositioning a device for inspection
   5. Fan wheel balancing
3. RI Steps for Temporary Restoration for Testing or Repositioning
   1. Notify the Affected Persons.
   2. 🚩Direct all LOTO Authorized Persons to stop work, replace required guards or establish a barricade around the hazard zone, and clear the equipment of tools and materials.🛑
   3. Perform a LOTO briefing with all LOTO Authorized Persons participating in the lockout.
   4. Direct all LOTO Authorized Persons to remove their personal LOTO locks from the isolations that will be temporarily energized.
   5. Remove all stored energy dissipating devices (grounding/shorting conductors, hooks, or wands).
   6. Remove the RI lock.
   7. Energize and proceed with testing or repositioning.
   8. Once the testing or repositioning is complete, reestablish the LOTO, following all steps in Work Process F or Work Process G as required.
   9. Apply the RI lock.
   10. Perform a LOTO briefing with all LOTO Authorized Persons participating in the lockout.
   11. Direct all LOTO Authorized Persons to reapply their personal LOTO locks to the isolations that were temporarily energized.
   12. Authorize continuation of work.
        

Work Process L. LOTO Hardware

1. LOTO Locks
   1. LOTO locks are required to be RED. Conversely, any RED padlock is considered a LOTO lock. RED locks must not be used for any purpose other than LOTO.
   2. Administrative locks cannot be turned into LOTO Locks by painting or taping them red.
   3. LOTO locks are required to be keyed. Combination locks are not allowed at Berkeley Lab for the purpose of LOTO.
   4. LOTO locks must have only one key. There are to be no spare or emergency keys.
   5. LOTO locks may be keyed alike so long as responsibility for the locks is not shared: The locks are in use by only one person and the key to those locks are in the control of that person. If a set of locks is keyed alike for this purpose, only one key may be issued for that set of locks, and all spare keys must be destroyed.
   6. LOTO locks must be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as the use of bolt cutters or other cutting tools.
2. LOTO Tags
   1. Only LOTO tags may be used with LOTO locks. A LOTO tag must always be used in conjunction with a LOTO lock unless the energy isolation is not physically capable of being locked (see Work Process H). Since the tag indicates the purpose and ownership of the lock, the tag must be attached to the lock shackle, and never to the hasp or other LOTO device. 
   2. All LOTO tags must be red, white, and black; state “Danger – Do Not Operate;” and must have a statement prohibiting unauthorized removal of the lock.
   3. LOTO tags, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. 🚩Personal LOTO tags should be attached to the shackle of the lock they are accompanying. 🛑
   4. Tagout Tags (Work Process H) 🚩attachment means shall be of a non reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all-environment-tolerant nylon cable tie. 🛑
   5. LOTO tags must be of a material suitable for their environment. LOTO tags used outdoors must be resistant to weather and UV damage.
   6. There are four types of LOTO tags:
      1. Personal LOTO Tags: The LOTO Authorized Person performing LOTO must have his/her name and phone number on the tag. Subcontractors must also have his/her company name on the tag. This may be handwritten or permanently printed.
      2. Responsible Individual LOTO Tag: The RI LOTO tag must state “Responsible Individual Lock” or “RI Lock.” The RI must have his/her name and phone number on the tag. This may be handwritten or permanently printed.
      3. Group LOTO Tag: The Group LOTO tag must state “Group LOTO.” The RI must write his/her name and phone number on the tag, and the LOTO procedure or permit number if applicable.
      4. Tagout Only Tag: The Tagout Only tag must state “Tagged Out.” The RI must write his/her name and phone number on the tag, and the LOTO procedure or permit number if applicable. The Tagout Only tags are one-time use and are serialized with detachable stubs. The stubs are detached and placed into the lockbox.
3. LOTO Lockboxes
   1. Lockboxes are standalone lockable boxes used during group LOTO and Tag-Out Only LOTO. They come in a multitude of shapes and sizes to suit the needs of various users. Some are permanently mounted while others are portable.
   2. Lockboxes must be of sturdy construction and materials and be suitable for their intended environment. The lockbox must be constructed in such a way that permits multiple LOTO locks to be attached to the outside of the enclosure, preventing it from being opened except by removal of every last LOTO lock. The lockbox must be designed to securely contain the keys and not release them in the event of being shaken, dropped, or pried open.
   3. Many lockboxes come with a slot to insert keys after the box is already locked; however, this feature is not used at Berkeley Lab.
   4. Lockboxes must be fitted with a physical means to attach the completed LOTO procedure to the lockbox. This can be integral to the lockbox construction or retrofitted to the lockbox. This feature must be designed to display the front page of the LOTO procedure without folding or rolling, and must protect the LOTO procedure from damage from the elements.
4. LOTO Devices
   1. LOTO devices are mechanical attachments that affix to the energy isolation devices for the purpose of LOTO. They come in a multitude of shapes and sizes to match the wide variety of energy isolations found in the field.
   2. LOTO devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.
   3. Once applied to an energy isolation and fitted with a LOTO lock or LOTO hasp, the LOTO device must:
      1. Mechanically prevent the actuation of the energy isolation and
      2. Hold fast to the energy isolation until the LOTO lock or LOTO hasp has been removed
   4. The most common LOTO device is the LOTO hasp. The LOTO hasp is either applied directly to an energy isolation capable of being locked out, or to another LOTO device. Since most LOTO devices only hold a limited number of LOTO locks, the LOTO hasp is used to add multiple locks. LOTO hasps may be attached to each other (i.e., daisy-chained) to accommodate as many locks as needed.

A LOTO hasp

e. Other common LOTO devices include:

i. Cable LOTO devices
ii. Breaker LOTO devices
iii. Ball valve LOTO devices
iv. Globe valve LOTO devices
v. Custom LOTO devices

f. Energy isolations come in multitudes of configurations, and commercially available LOTO devices are typically used to apply the LOTO lock and hasp combination. In some instances, however, no commercially available LOTO device can fulfill the function. It is acceptable to custom design and build a LOTO device that fits the application.

Work Process M. Training and Authorization

1. General Requirements
   1. Only persons who have received the appropriate level of LOTO training may be authorized to perform LOTO functions.
   2. Specific training requirements, including EHS courses, prerequisites, required retraining and authorizations, are listed in Table M-1.
   3. Once the LOTO training is complete, specific line management authorization in the LBNL Activity Manager is required before a person can participate in any LOTO .
   4. 🚩Escorted:
      A person who has not completed the training requirements for LOTO Authorized Persons may be considered a LOTO Authorized Person and participate in an established LOTO provided that all of the following are true: 🛑
      1. The person is only accessing an area requiring LOTO and is not performing work.
      2. A Responsible Individual is assigned to the LOTO and performs a LOTO briefing.
      3. The person applies a personal LOTO lock and tag under the direction of the Responsible Individual.
      4. The Responsible Individual personally escorts the person 100% of the time the person is in the area requiring LOTO.
      5. 🚩Each instance shall require prior approval by the Division Electrical Safety Officer and the Responsible Individual for the LOTO. The person shall be considered a LOTO Authorized Person for the specific instance. 🛑
2. Line Management Authorization   
   1. Authorization to perform LOTO is covered by Chapter 6, Work Planning and Control Program.
   2. Specific authorization is to be provided by the supervisor after the employee satisfies the EHS course requirement and has received equipment-specific training. The supervisor must ensure that the employee is thoroughly familiar with the equipment (within the context of his or her job function) and with the energy-control procedures. 🚩For employees establishing complex LOTO, where they will be acting as the LOTO Person in Charge, this shall be documented by a field assessment performed by a LOTO Procedure Evaluator.
   3. 🛑Once the supervisor is satisfied that both the training and authorization requirements have been met, the supervisor may authorize an employee to perform LOTO in roles consistent with the training the person has received. This authorization stipulates the specific equipment or types of equipment on which the LOTO Authorized Person may perform LOTO.
   4. Line Managers who supervise persons that are required to perform LOTO must take the online course EHS0372, Lockout/Tagout Awareness for Line Management. Line Managers who are themselves LOTO Authorized Persons are not required to take EHS0372.
3. Non-Berkeley Lab Employees, Students, Affiliates, and Visitor LOTO Procedures
   1. All visiting scientists, engineers, affiliates, and students who work in areas in which LOTO is used are considered Affected Persons.  🚩Notification of Affected Employees in the area should be made by the LOTO Authorized Person before establishing a LOTO.🛑
   2. Visiting scientists or students who perform service, maintenance, or equipment modification are required to be trained as a LOTO Authorized Person 🚩or a Limited LOTO Authorized Person. 🛑
4. Subcontractors.
   1. Subcontractors performing LOTO (simple or complex) at Berkeley Lab are required to:
      1. Complete the course EHS0379, Subcontractor Lockout/Tagout Orientation, and
      2. Obtain a subcontractor LOTO permit when required.
   2. The subcontractor LOTO permit constitutes authorization to perform LOTO. See Work Process I for requirements.
   3. Subcontractors have the option of submitting their own company LOTO program for review to the EHS Electrical Safety Group.  This will be uploaded into a database and referenced in certain situations, one being any special notifications required in the instance a LOTO Lock needs to be cut under Work Process O.

🚩🚩Table M-1. LOTO Training and Authorization Matrix
Role/Hazard Description	Training Class	Refresher	Authorization
General LOTO Awareness
LOTO Awareness for Line Management	Prerequisite: None EHS0372, Lockout/Tagout Awareness for Line Management, repeat every three years	Every 3 years	Automatically added to their training profile when one of their employees requires EHS0370
Cord and Plug
Simple LOTO for Cord and Plug Equipment	Prerequisite: None EHS0389, Simple LOTO for Cord-and-Plug Equipment	Every 3 years🛑	Authorized by line management through an approved WPC Activity
Limited LOTO Authorized Person
Joining an Existing LOTO (Simple or Complex) That Has Already Been Established	Prerequisite: None EHS0388, Limited Lockout/Tagout for Authorized Persons	Every 3 years	Authorized by line management through an approved WPC Activity
Subcontractor LOTO Authorized Person	Prerequisites: None EHS0379, Subcontractor Lockout/Tagout Orientation	Every 3 years	Authorized by a Responsible Individual through an approved subcontractor LOTO permit
Qualified Person
Establishing Simple LOTO on Hardwired Equipment	Prerequisites: NoneEHS0370 Lockout Tagout for Authorized Persons	Every 3 years	Authorized by line management through an approved WPC Activity
Establishing Complex LOTO	Prerequisites: NoneEHS0370 Lockout Tagout for Authorized PersonsANDDocumentation of Division On the Job Training should be placed in Activity Manager or other Division Process	Every 3 years	Authorized by line management through an approved WPC Activity
Complex LOTO Procedure/Permit
Managing a Complex LOTO Procedure/Permit That Requires a Trained LOTO Responsible Individual (RI)	Prerequisite: EHS0370 Lockout/Tagout for Authorized Persons EHS0373, Lockout/Tagout for Responsible Individuals	None	Authorized by line management through an approved WPC Activity
LOTO Procedure Approver/Evaluator	EHS0370 Lockout/Tagout for Authorized Persons	Every 3 years	Authorized by line management through an approved WPC Activity

 

Work Process N. Developing LOTO Procedures

1. A LOTO procedure is a formal document detailing all the steps required to establish the lockout. It is specific both to the equipment or system and to the scope of work. A LOTO procedure is required for all complex LOTOs.
2. The LOTO procedure fulfills the following purposes:
   1. It documents the scope of work permitted under the LOTO.
   2. It documents the specific isolations established by the LOTO.
   3. It serves as the primary communication document for all parties involved in the LOTO.

🚩Additional information on LOTO procedures can be found in the LBNL LOTO Procedure Process document in Appendix A.🛑

Work Process O. Special Condition LOTO Lock Removal

1. Normal LOTO Lock removal takes place following Work Process D, Work Process E, Work Process F, or Work Process G. This work process describes LOTO lock removal under special conditions, such as lost keys or unavailable personnel.
2. Personal LOTO Lock Removal
   1. Any LOTO Authorized Person may remove his or her own personal LOTO lock. In the event the key to a lock is lost or misplaced, the lock may be cut by the LOTO Authorized Person.
   2. In the event that a LOTO Authorized Person is absent, or otherwise unavailable to remove his or her personal LOTO lock(s), the Responsible Individual (RI) may remove the LOTO lock(s) for the Authorized Person, subject to the restrictions in this section.
   3. If a Responsible Individual has not been assigned, then either the absent Authorized Person’s supervisor or 🚩the supervisor’s designee🛑  may perform the task.
   4. The following steps must be taken to remove an absent Authorized Person’s personal LOTO lock(s):
      1. Obtain a printed copy of the 🚩Absent Authorized Person LOTO Lock Removal Form in Appendix C.🛑
      2. Verify that the absent Authorized Person who applied his or her personal lock(s) is not present at the site.
      3. Make all reasonable efforts to inform the absent Authorized Person that his/her lockout or tagout device needs to be removed.
      4. Make all reasonable efforts to inform the absent Authorized Person’s supervisor that his/her employee’s lockout or tagout device needs to be removed.
      5. Permission to remove an absent Authorized Person’s lock must be obtained from each of the following parties:
         1. The absent Authorized Person or the absent Authorized Person’s line management and
         2. If assigned, the RI in charge of the specific LOTO (the EHS Electrical Safety Group can be contacted if the RI can not be reached) and🛑
         3. A Berkeley Lab senior line manager for the division
      6. For subcontractors, additional requirements may exist in the subcontractor’s LOTO program. The subcontractor’s LOTO program may be on file with the EHS Electrical Safety Group. The EHS Electrical Safety Group, or designee must consult the subcontractor’s LOTO program and follow any guidance therein prior to granting approval.
      7. After obtaining all required approvals, the RI (or EHS Electrical Safety Group, or designee) must remove the lock(s). If present, the absent person’s supervisor must physically witness the lock removal and must retain possession of the lock(s).
      8. Before the absent person returns to any work duty, the absent person’s supervisor must ensure that the person is presented with the removed lock and is informed of the reasons for the removal.
      9. The completed 🚩“Absent Person LOTO Lock Removal Form” 🛑must be returned to the EHS Electrical Safety Group for record keeping.
3. Responsible Individual (RI) Lock Removal:
   1. In the event the key to an RI Lock is lost or misplaced, the RI may cut their own RI Lock.
   2. In the event that a RI is absent, or otherwise unavailable to remove their RI Lock, a new RI may remove the LOTO lock for them, subject to the following restrictions:
      1. Follow all the requirements for removing an Absent Person’s Personal LOTO Lock.
      2. A new RI must be assigned and the LOTO must be transferred to the new RI.
      3. The new RI must ensure that all aspects of the LOTO are properly managed.
      4. Assistance may be required from a LOTO Coordinator or from the EHS Electrical Safety Group.
4. Removing a Group LOTO Lock
   1. Group LOTO lock removal requires extreme caution.  Since the key to a group LOTO lock is normally kept in a locked lockbox, a missing key suggests several alternatives. The lock could in fact belong to a separate Group LOTO with its key in a separate lockbox. Therefore, all due diligence is required to ensure that a separate active Group LOTO is not unknowingly defeated by cutting a group LOTO lock.
   2. Assistance from a LOTO Coordinator or from the LBNL Electrical Safety Group is recommended.

Work Process P. Periodic Inspections of LOTO Procedures

🚩Additional information on LOTO procedures inspections can be found in the LBNL LOTO Procedure Process document in Appendix A.🛑

🚩🚩Work Process P.1. LOTO Program Assurance Plan

1. The purpose of this Lockout Tagout (LOTO) program assurance plan is to document assurance elements designed to review and monitor performance, understand how well the program is performing, and identify opportunities for improvement.  EHS has identified LOTO as a higher risk program, and as such, this assurance plan follows a three-year (triennial) assurance model that ensures that each functional element is reviewed no less frequently than every 36 months.  
2. The LOTO program assurance plan is designed to assess performance of each functional element of the program, which include:
   1. Simple LOTO performance
   2. Complex LOTO performance
   3. Subcontractor LOTO performance
   4. Training and learning support
   5. Worker qualification and authorization
   6. Work planning and control (to include procedures and permits)
   7. LOTO procedure inspections 🛑

Work Process Q. – Physical Separation

1. Physical separation is the condition in which the sources of hazardous energy are physically removed from the work area and tools and/or materials are required to re-terminate the equipment. When Physical separation is established, Lockout/Tagout is not feasible and not necessary. Physical separation  is a natural step during either the new construction or the demolition phases of a project, or installation or removal of equipment. It is also applicable when machinery is temporarily relocated from its normal installation area to a separate work area for repair, servicing, or maintenance. Physical Separation is also known as an “Air Gap”.
   1. 🚩Condition 1: LOTO does not apply when the conductors, pipes, or lines are unterminated from the source(s) of energy on the supply side. Examples for Condition 1 include new construction that has not been terminated to a source of energy or demolition activities after physical separation is achieved.
   2. Condition 2: LOTO DOES apply when conductors, pipes, or lines are unterminated from the equipment (load side) such as in maintenance activities.  Physical separation for maintenance activities shall not be a substitute for LOTO.🛑
2. Physical separation shall not be used as a substitute for LOTO controls where LOTO controls are feasible.
3. Requirements for Physical Separation
   1. All energy sources must be physically and visibly separated from the work area to the extent that tools and/or materials are required to re-terminate the equipment.
   2. This separation must be visible without opening any cabinets or manhole covers, etc.
   3. The minimum separation distance is five feet.
      1. For electrical systems, this includes the conduit, cable tray, or other cable-supporting device.
      2. Where a five-feet physical separation is not achievable, additional controls must be implemented to prevent an unplanned reconnection of the energy source. These controls shall be approved by the EHS Electrical Safety Group on a case-by-case basis.
   4. Physical separation must be a documented part of the overall job plan.

4. Except for temporary relocation of machinery, quick-disconnects, 🚩cord and plug connections,🛑 or other temporary disconnections of wiring, piping, or waveguides are not considered suitable for physical separation .  🚩In this context, “temporary disconnection” means that re-connection is possible without the use of tools and/or materials.🛑
5. New Construction
   1. During new construction, work will proceed through various stages. At some point, energy sources are connected and the LOTO process comes into effect. Until that point, physical separation is sufficient.
   2. LOTO is required to perform the initial connection or tie-in to the energy source. After this time, all work performed downstream of the energy source on equipment requires the application of LOTO controls.
   3. The transition from work under a physical separation to work under LOTO must be managed under a documented energization and/or commissioning plan.
6. Demolition
   1. For demolition projects, LOTO is required to perform the initial demolition of the energy tie-ins.
   2. After initial disconnection, the conduit or piping must be removed at least five feet from the tie-in point, and in a way that cannot be immediately reconnected. After this point in time, the LOTO can be cleared, and LOTO controls are no longer applicable in the Safe Work Area.
   3. The transition from work under LOTO to work under a physical separation  must be managed under a documented decommissioning plan.
7. Temporary Relocation
   1. For work performed on equipment that has been physically removed from the normal installation area, LOTO is not required. 🚩Care must always be taken to ensure all possible sources of stored energy or other hazards have been removed.🛑
   2. LOTO is required to perform the initial disconnection.
   3. LOTO must remain in place to control the energy to the cables, pipes, or waveguides that are still in the area, unless these are made safe through enclosing, insulating, capping, blanking, or other methods suitable for the environment to prevent inadvertent release of energy.
   4. Any person performing work in the installation area must be personally locked out depending on their exposure.
   5. Prior to reinstalling the equipment, the LOTO must be re-established.
   6. The transition from work-under-LOTO to work-not-requiring-LOTO and vice-versa must be documented and managed in the work plan.

Work Process R. Interlock Systems 

1. Interlock systems are designed to automate certain safety functions and prevent injury during normal operation of equipment or some anticipated abnormal conditions. Interlocks consist of one or more devices engineered to detect an undesired condition and shut down the equipment or otherwise remove the immediate hazard. Interlocks are often electrical switches but can be mechanical in nature. Interlocks are often applied to area hazards where the hazard is unlikely to be recognized in time to prevent injury.
2. Interlocks are not a substitute for LOTO controls and shall not be used or otherwise relied upon for the purpose of protecting persons performing servicing or maintenance on equipment. Additionally, an interlock cannot serve as a LOTO energy isolation point since it does not constitute a positive energy isolation.
   1. Exception: Credited Control Radiation Safety Systems
      1. Credited control radiation safety systems are essentially interlock systems designed to protect personnel against radiological hazards. Radiological hazards covered by 10 CFR 835 are exempt from the scope of 10 CFR 851. 10 CFR 835 establishes credited control radiation safety systems designed for some of the radiological hazards at Berkeley Lab. They provide interlocked access controls to ionizing radiation area enclosures without requiring the LOTO of the radiation generating device (RGD).
      2. This exception applies only to the area protected by the credited control radiation safety system.
      3. This exception applies only to the radiological (ionizing radiation) hazard and not to other types of hazardous energy (e.g., high voltage, radio-frequency radiation, lasers, or cryogens) within the protected area, even though they may also be interlocked in conjunction with the RGD.
      4. Specific definitions and requirements for RGDs, radiation safety systems, and credited controls are found in Chapter 21 Radiation Safety, Chapter 9 -(Radiation Generating Device Program), and EHS Procedure 731 (RGD Interlock Program).
3. Trapped Key Interlock Systems
   1. A trapped key interlock system is an area access control system where a key is held captive until a certain condition is satisfied. Common types of trapped key interlock systems include Kirk keys and Castell locks, named after the inventors. When the condition is satisfied and the key is released, the key is carried to unlock another enclosure or set of keys. The key is again held captive in the new enclosure while the enclosure is unlocked. The trapped key interlock system is permanently installed on the equipment.
   2. Trapped key interlocks serve the primary purpose of enforcing a specific sequence. At Berkeley Lab, they are usually found in accelerator applications to prevent unauthorized access to hazardous areas. They are also commonly found in high-voltage applications, also to prevent unauthorized access.
   3. A trapped key interlock system may be used in conjunction with the Berkeley Lab LOTO Program, but by itself does not meet the requirement for personal LOTO. To use the system with LOTO, there must be at least one token key that can be kept on a person or locked in a lockbox. Ways to incorporate trapped key interlocks and also meet the requirements of the LOTO program include:
      1. Limiting the number of LOTO Authorized Persons to the number of token keys available. Each person accessing the controlled area must keep the token key on their person while in the area.
      2. Place at least one token key in a lockbox, then use the group LOTO procedure.
   4. A properly designed trapped key interlock system can significantly strengthen a LOTO procedure by making it physically impossible to violate key steps in the required sequence.
   5. Trapped key interlock systems where the last key is held captive in a lock do not meet the requirement for LOTO but can still be used to enforce the required sequence. In this case the LOTO process simply overlaps the trapped key interlock system.
   6. Trapped key interlock systems do not eliminate the need to follow all steps in the LOTO process, including the need for written LOTO procedures and verifying the absence of energy.
   7. Bypassing or defeating a trapped key interlock is expressly forbidden.

 

Work Process S. Administrative Control

1. Administrative Locks 
   1. A careful distinction must be made between LOTO controls and various other locking practices, collectively referred to as “administrative locking.” While LOTO locks are placed by individual workers to protect themselves against inadvertent energization of equipment, administrative locks are used when there is the need to provide “operational control” (control of a system, utility, or facility).
   2. Any lock that is used for a purpose other than LOTO is called an administrative lock. Administrative locks may serve a safety function other than LOTO, a configuration-control function, or any other purpose. Unlike LOTO lock keys, the keys to administrative locks may be controlled by one or more individuals.
   3. Administrative locks can be common locks with more than one key, so that anyone with access to the keys can open the control point as needed. The lock is not specific to an individual, but to a specialized working group or trade. Administrative tags, likewise, are also common to multiple people and do not need to have an individual’s name shown.
   4. Administrative locking does not provide individual personal protection for workers and is not a substitute for personal LOTO.
   5. An administrative lock shall not be red and shall not be labeled with a danger tag or sticker, or any other marking that resembles a LOTO marking. Conversely, a LOTO lock cannot be used as an administrative lock.
   6. Administrative locking may be used in conjunction with LOTO locks and using the same LOTO devices. For example, a controlling department may apply an administrative lock to a LOTO for the purpose of controlling the start-up of the equipment.
   7. Persons who have applied administrative locks shall not perform work or enter a hazardous zone without first applying personal LOTO locks.
   8. Administrative locks may not be cut unless communication has been made with either the person who applied the lock or with someone in the controlling department.
2. Tag On 
   1. Some systems, such as sump pumps, emergency lights, and refrigerators, must be shut down in a controlled manner. An informational tag may be placed on their isolations to warn the user against accidental de-energization. The use of a LOTO tag is not permitted for this purpose.
   2. When a circuit breaker, disconnect switch, or energy-securing device is readily accessible to any employee, the circuit breaker or disconnect switch may be tagged to indicate that it is not to be turned off.
   3. The energy-securing device must not be locked by any means that would prevent the device from being used as an emergency disconnect.
   4. The tag must include the name of the responsible person and an alternate, date, and phone number.

Work Process T. LOTO Coordination

1. Some large projects or events require the coordination of multiple LOTO procedures. These events include major maintenance outages, emergency outages, initial building energization, or other large projects.
2. The increased complexity may require the assignment of an overall LOTO Coordinator to ensure that conflicts in schedule, outage planning, and required energized events do not lead to confusion.
3. The assignment of a LOTO Coordinator is a line-management decision. The LOTO Coordinator is assigned by line management for a specific project, outage, or time period. This person must have effective communication skills, put safety first (not pressured by timelines) and be able to work effectively with groups from Facilities, PIM, as well as EHS.
4. The LOTO Coordinator must 🚩oversee and coordinate multiple LOTOs🛑 established during the time period covered by the event.
5. The LOTO Coordinator must participate in project planning and periodic update meetings to ensure that all scheduling conflicts affecting the LOTOs are resolved satisfactorily.
6. The LOTO Coordinator is not assigned the duties of Responsible Individual for the LOTOs. The LOTO Coordinator must instead ensure the various Responsible Individuals are properly informed of any changes that will affect their respective LOTO procedures. This can include a change in shutdown or start-up times, an unexpected temporary restoration of power, or a change in the scope of work.
7. Conversely, all Responsible Individuals must keep the LOTO Coordinator informed of changes that may affect the overall project schedule.
8. The LOTO Coordinator is considered a LOTO Affected Person for all LOTOs on the project and therefore must be notified as required in Work Process D, Work Process E, and Work Process F.

18.8 Source Requirements 

• 10 CFR 851.21, Hazard Identification and Assessment
• CCR, Title 8, Section 3314, The Control of Hazardous Energy for the Cleaning, Repairing, Servicing, Setting-Up, and Adjusting Operations of Prime Movers, Machinery and Equipment, Including Lockout/Tagout
• NFPA 70E, Standard for Electrical Safety in the Workplace

 

18.9 Reference Documents

Document Number	Document Title	Document Type
Chapter 6	Work Planning and Control	Program
Chapter 8	Electrical Safety Program	Program
🚩MA.MG.PRC.045	Facilities LOTO Operating Program Procedures	Program🛑
Chapter 16	Laser Safety	Program
Chapter 21	Radiation Protection	Program
Chapter 7	Pressure Safety	Program
Chapter 25	Machine Safeguarding – Shop and Laboratory Machine Safety	Program
Chapter 34	Confined Spaces	Program

 

Other Non-mandatory Reference Documents

• 🚩29 CFR Part 1910.147, The Control of Hazardous Energy (Lockout/Tagout)
• 29 CFR Part 1910.269, Electric Power Generation, Transmission, and Distribution
• 29 CFR Part 1910.333, Subpart S, Electrical, Selection and use of work practices
• 29 CFR Part 1926, Safety and Health Regulations for Construction
• California Code of Regulations, Title 24, Part 3, California Electrical Code
• OSHA Instruction CPL 02-00-147, Effective Date: 2/11/08, The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures
• ANSI/ASSE Z244.1-2016 (R2020), Control of Hazardous Energy, Lockout/Tagout and Alternative Energy Control Measures
• EFCOG Best Practice #180: LOTO Applicability to Physical Separation🛑

 

18.10 Appendices

🚩Additional Process Flows and Training Aids can be found here: https://electricalsafety.lbl.gov/loto/

Appendix A. LBNL LOTO Procedure Process

Appendix B. Written LOTO Procedure Alternate Format

Appendix C. Absent Person LOTO Lock Removal Form 🛑

🚩🚩Appendix A. LBNL LOTO Procedure Process

1. Scope

This program describes how LOTO procedures are created and inspected and supplements Pub 3000, Chapter 18.  This information previously resided in Work Process N, Work Process P.   A LOTO procedure is a formal document detailing all the steps required to establish a lockout.  It is specific both to the equipment or system and to the scope of work.  A LOTO procedure is required for all complex LOTO’s.  

2. Applicability

This applies to all Divisions who have at least one routine complex LOTO procedure that is performed at least once a year.  

This does not apply to the following:

• Subcontractor LOTO Permits where scopes of work are written for one and done jobs.  These are considered non-routine LOTO procedures and observed skills of authorized persons implementing these procedures will be captured during documented field audits.  
• Jobs where a LOTO Permit is in place only because a Subcontractor is performing “Simple” LOTO.

3. LOTO Procedures

3.1 Division LOTO Operating Program

Each Division should have a document in place that outlines how they manage the LOTO procedures for their Division; LOTO Operating Program.  This should also include any specific information that might not be covered in Pub. 3000, Chapter 18. Topics should include:

• Where LOTO procedures are stored, tracked and archived
• If applicable, special roles for individuals within the LOTO process
• Routing for the review, approval or field change process
• Grouping of LOTO procedures for annual inspection requirements

3.2 Storage of LOTO Procedures

An index or a searchable database of all procedures should be available and contain the date the procedures were developed, reviewed, validated and revised. For Divisions that do not already have an existing tracking system they can use the lab’s system; the Quickbase software system that is managed by the LBNL Electrical Safety Department.  Within this system, there are several applications;

• Complex LOTO Procedures (used by most divisions)
• Facilities LOTO Procedure (used by Facilities for in-house work)
• LOTO Permit Database (used labwide for Subcontractor LOTO Permits)
• LOTO Procedure Inspection (both the Complex LOTO Procedures as well as Facilities LOTO Procedures are linked to this application to store their documented annual procedure audits)

Most Divisions have chosen to manage their procedures within this software system, while others have not.    

Record	Retention Period
Completed Complex LOTO Procedure/Permit	2 years
Complex LOTO Procedure Inspection Form	5 years
Annual LOTO Certification Form	5 years

3.3        Developing a LOTO Procedure:

The LOTO procedure fulfills the following purposes:

1. It documents the scope of work permitted under the LOTO.
2. It documents the specific isolations established by the LOTO.
3. It serves as the primary communication document for all parties involved in the LOTO.

LOTO procedures must not describe multiple “scenarios” where energy isolations are selected based on different scopes of work. Instead, the LOTO procedure must establish only ONE LOTO Safe Zone, where ALL energy isolations listed on the procedure are locked out at the same time.  Multiple scenarios may only be addressed by creating separate LOTO procedures.

For example, in this case there were three different scopes of work.  Instead of trying to combine it all into one, they broke it out into 3 separate LOTO permits.

LOTO procedures can be developed by anyone familiar with the equipment.

All Berkeley Lab LOTO procedures shall follow the standard format included in the Quickbase LOTO Procedure application.  A Word template for a generic LOTO procedure can be found here.  Alternative formats specific to divisions or user facilities may be used, provided that they contain the elements described in Appendix B.

The LOTO procedure writer must consider the following 5 main points:

1. Scope of work:

Every LOTO procedure is dependent on properly identifying the scope of work. The LOTO procedure writer must perform the following to ensure that scope of work is properly understood and defined:

• Contact the lead worker in charge of the job.
• Have the lead worker describe in detail the scope of work, including all preparations and testing required.
• Walk down the job site to identify other hazards in the area that may need to be addressed.
• Ask detailed questions to determine whether other considerations are warranted.

The scope of work should be detailed enough so that a person that was not involved in the planning process can read the scope and have a clear understanding of the work to be accomplished.  It should answer Who, What and Where.  

For example:

Inadequate Scope:  Move electrical outlets around in the building.

Improved Scope: Subcontractor will relocate electrical outlets labeled (fed from 1234-33) in room 12 to the other side of the room in order to make space for a new piece of equipment.  This work will be performed after LBNL Electricians have established LOTO.

2. Hazardous Energy Analysis:

The LOTO procedure writer must perform a hazardous energy analysis to identify the required isolations. Available documentation should be consulted, such as equipment drawings, schematics, manuals, panel schedules, and process and instrumentation diagrams (P&IDs). In addition, the system should be visually inspected to ensure all hazards are properly identified.

• Identify hazardous energy sources and associated energy isolations.  Hazardous energy sources may include rotational energy, gravity, mechanical, heat, steam, chemical, electrical, etc. ,
• Identify proper test points for each of the energy isolations (to verify the absence of energy)
• Determine PPE requirements for each of the energy isolations
• Identify any source of hazardous stored energy
• Determine suitable method to dissipate the stored energy

3. Determine Suitable Energy Isolations:

Energy isolations shall be positive isolation devices such as a disconnect switch, circuit breaker, block valve, or blocking pin.

• Control actuators such as the emergency stop or the equipment controller shall not be used as lockout isolation points.
• Contactors, diodes, interlock switches, check valves, and automatically controlled valves are not positive isolation devices.

Energy isolations shall be capable (or made capable) of accepting an approved lockout device that physically prevents the actuation of the energy-isolating device.

• Where the desired isolation consists of removing a spool piece, removing fuses, lifting electrical wires, or otherwise disconnecting an energy source without a lockable isolation, follow Work Process H, Tagout Only, for that isolation.

Energy isolations must have an accessible test location to prove absence of energy. Interlocks, contactors, diodes, check valves, or automatically controlled devices must not be positioned between the isolation device and the test point used for verification of de-energization of the lockout point.

Energy isolations must be labeled clearly and uniquely, such as with an alphanumeric designator or a word description of its function.

4. Determine Methods to Dissipate Hazardous Stored Energy:

Releasing Hazardous Stored Energy

• In the case of hazardous stored mechanical energy, vent valves, spring releases, blocking devices, or equipment repositioning (as appropriate) must be utilized.
• In the case of hazardous stored electrical energy, approved grounding wands or discharge devices must be used.
• Stored energy that cannot be released must be locked out.

Preventing the Re-accumulation of Hazardous Stored Energy

• If there is a possibility of re-accumulation of stored energy to a hazardous level, a method to continuously discharge the energy shall be installed and maintained for the duration of the lockout.
• For electrical systems >600 V, temporary personal protective grounds are required.
• Other examples include the double-block-and-bleed method for high-pressure fluids where slow leakage past an energy isolation valve can result in undetected repressurization of a section of piping.

5. Determine Whether a Specific Sequence Is Required

Unless specifically stated otherwise, LOTO steps in the LOTO procedure may be performed in parallel or in series. Either perform all steps in sequence for each isolation, completing all the steps for an isolation before moving to the next isolation; or, equivalently, perform each step for all the isolations before moving to the next step. Either way, use the LOTO procedure checklist to ensure that all steps are positively completed for each and every energy isolation.

If a specific sequence is required for any part of the LOTO procedure, this sequence must be described in a written checklist.

A job aid can be found here that helps LOTO Permit writers submit all the required information for a Subcontractor LOTO Permit. <link here>

3.4     Approving a LOTO Procedure:

After development, this procedure must go through an optional review process and a required approval process.  The approver must have suitable competency in the equipment or systems for which the LOTO procedure is written. This approval process should be outlined in the Division LOTO Operating Program document.

Each division with LOTO procedures must designate one or more LOTO Approvers to meet the LOTO needs of the division. Should a division not have the competency required, the EHS Division may provide assistance in reviewing and approving LOTO procedures.

LOTO Approvers:

• A LOTO Approver is a competent person who has been designated by Line Management to approve LOTO procedures based on his or her level of technical knowledge and familiarity with the systems involved.
• The LOTO Approver must obtain technical assistance as required from Qualified Persons who are more familiar with the systems involved.
• The LOTO Approver will examine in detail every aspect of the LOTO, and become familiar with the scope of work and LOTO Safe Zone established by the LOTO procedure.
• Once the LOTO Approver has become satisfied that the LOTO Safe Zone adequately matches the scope of work, and all questions concerning the details of the LOTO are resolved, the LOTO Approver will approve the LOTO procedure.

4. Periodic Inspections of LOTO Procedures

An important part of the LBNL LOTO Program are annual inspections of LOTO Procedures. These inspections shall ensure the following:

• The authorized persons performing the procedure are following the procedure as it’s written
• The written procedure is capturing all the hazards and the scope outlines the correct LOTO safe zone
• The authorized persons are following the LBNL LOTO program in the field.  

Inspections shall be designed to correct any deviations or inadequacies observed. Audits should address all shifts and days of operation.  

Energy control procedures used less frequently than once a year (based on a twelve-month interval) need be inspected only when used.

An index, or a searchable database, of all procedures should be available.  This list shall contain the date the procedures were developed, reviewed, validated and revised.  

Normally LOTO procedures only describe one LOTO scenario and establish one LOTO Safe Zone and multiple scenarios may only be addressed by creating separate LOTO procedures.  This is not the case during inspection time. Grouping of LOTO procedures is allowed for the purposes of these inspections.  The Division grouping method must be defined in the Division LOTO Operating Program document. At least one procedure from each grouping of LOTO procedures needs to be inspected annually.

4.1     Grouping of LOTO Procedures

Multiple scopes of work may be performed under the same LOTO procedure inspection, provided that each scope is described on the LOTO procedure and that the LOTO Safe Zone is adequate.  For the purpose of periodic inspections, LOTO procedures may be assigned to groups that share the same or similar: 

• Procedural steps for shutting down, isolating, blocking, securing, and dissipating hazardous stored energy in machines or equipment
• Procedural steps for the placement, removal, and transfer of the lockout or tagout devices as well as the responsibility for them; and
• Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures

A grouping of individual LOTO procedures meeting these criteria would be considered one procedure for periodic inspection purposes.  If equipment is categorized into the same group, the equipment/machinery must have a similar type, energy source, or energy control measures. At least ONE procedure from each grouping of LOTO procedures needs to be inspected annually.

An examples of some of the current equipment categories in the database include:

Autoclave/Steam Generator	Test Stand	Accelerator	Air Compressor
Fermenter	X-Ray Machine	UPS	Bldg. 90
Blower	Power Supply	Laser	Vacuum Chamber
Solenoid Pulser	Cray Computer	Substations	Generator

4.2      LOTO Procedure Evaluator

The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.  This person shall be identified as the LOTO Procedure Evaluator and shall document any corrections or deviations they identify on the LOTO Procedure Inspection Form. A copy of the form can be found here, but if you are using the Quickbase Application, inspections shall be documented within the Quickbase Application.  

LOTO Procedure Evaluators must be identified by Division Line Management and  must correct any deviations or inadequacies observed on the spot. Should a division not have the competency required, the EHS Division may provide assistance in evaluating LOTO procedures.

Following the LOTO inspection, there must be a review of each employee’s responsibilities under the LOTO procedure that was inspected. Specifically, the evaluator must be able to determine:  

1. The steps in the energy control procedure are being followed;
2. The employees involved know their responsibilities under the procedure; and
3. The procedure is adequate to provide the necessary protection, and if inadequate, what modifications are needed.

If inadequacies are identified, they must be corrected and all authorized employees who perform that procedure must be consulted. Group meetings may be the most effective way to meet this requirement to re-establish employee procedure responsibilities and proficiency.

4.3     Annual Certification for Division with LOTO Procedures

EHS shall certify that the periodic inspections have been performed by all Divisions who have LOTO procedures. Each Division shall self certify using an Annual LOTO Certification Form found at the https://electricalsafety.lbl.gov/loto/ website.

5.     Roles and Responsibilities

Roles and Responsibilities as far as the procedure program. A full list of Roles and Responsibilities for LOTO can be found in Chapter 18.

Role	Responsibilities
Division Electrical Safety Officer (ESO) or Division Electrical Safety Advocate (ESA)	Participates in job walks, as needed, and assists with the development of new LOTO Procedures.
Environment, Health and Safety (EHS) Division (Electrical Safety Group)	Updates the Laboratory-wide LOTO Procedure Inspection Program as needed. Provides LOTO Procedure Inspection Forms and Annual LOTO Certification Form to be used to conduct the annual LOTO Inspection period. Every year, certifies that the annual inspections have been completed by each Division this program applies to. Shall communicate to line management any person acting within one of these roles who does not seem to understand or follow the LOTO inspection process.
Line Management	Maintains the Division’s index of all LOTO procedures that contains the date the procedures were developed, reviewed, validated and revised. Ensures consistent policy implementation and reinforcing LOTO rules and follows up with any individual who does not follow these rules. Ensures results from periodic LOTO procedure  inspections are submitted to EHS during the annual LOTO inspection period.
LOTO Authorized Person	Recognize the conditions of work that require LOTO and when a LOTO procedure needs to be written or followed by a LPIC.
LOTO Person in Charge (LPIC)	Must have extensive experience and/or technical knowledge of the system configuration and function of the equipment included in the work boundary. Conduct a LOTO Briefing before implementation of LOTO. Ensures LOTO procedures are followed and procedural steps are completed as written.
LOTO Procedure Approver	Designated by the Division to approve LOTO procedures for completeness and accuracy. Must have technical competence and familiarity with the equipment or systems for which the LOTO procedure is written. Verify that the scope of work is clearly defined, is described in the LOTO procedure, and that the LOTO Safe Zone established in the LOTO procedures fully encompasses the scope of work before approval.
LOTO Procedure Evaluator	Designated by the Division to observe the performance of LOTO procedures for the purpose of periodic inspections. Verify that the LOTO procedures are adequate, are understood, and are being followed by persons participating in the LOTO. Document the completion of the LOTO procedure inspections per Division requirements.
LOTO Procedure Reviewer (optional role within the Division)	Reviews submitted LOTO procedures before they go to a LOTO Approver. Verifies each procedure for its accuracy, completeness and hazardous energy control effectiveness Must be a person familiar with the task to be performed and might be someone the LOTO Approver collaborates with in order to obtain additional technical assistance regarding the system involved before they approve a procedure.

6.        Definitions

Term	Definition
LOTO Procedures	A formal written document, approved by a LOTO Approver, that details the scope of work performed under the LOTO, the energy isolations to be established, and all steps required to execute the LOTO.  These are used by lab employees who are not working with Subcontractors.
Subcontractor LOTO Permit	The subcontractor LOTO permit is a LOTO procedure designed for subcontractors who will be performing simple as well as complex LOTO. It incorporates the standard Berkeley Lab LOTO procedure format with a process to verify that subcontractors have received the appropriate training and supervision prior to participating in a LOTO.
Non-routine LOTO Procedure	LOTO procedures that are written for a specific scope of work that is generally not performed again after it’s been cleared.  Subcontractor LOTO permits are often non-routine.
Routine LOTO Procedure	Equipment specific LOTO procedures that are performed over and over without change. When used, it’s strongly suggested that routine LOTO procedures be posted at the equipment.

 

Appendix B. Written LOTO Procedure Alternate Format

If the standard LOTO procedure format in Quickbase is not used, an alternate format may be used provided it contains the following components:

1. Administrative Information. This includes information such as approval dates, locations, project name, persons involved, and other tracking information.
2. Scope of Work. This must clearly describe the scope of work covered by the LOTO procedure. The scope statement should be detailed and accurate enough to match the list of isolations in the isolation checklist. The target reader for the scope statement is the LOTO Authorized Person who is consulting the LOTO procedure to determine whether his/her task falls within the scope of work allowed by the procedure.
3. Energy Isolation Checklist. This section must identify each energy isolation in a checklist format. Each isolation must be presented on a single line item with the following information:
   1. Equipment or Load Being Isolated 
      1. This is a description of the load that names or otherwise designates in English the exact item being isolated.
      2. Examples are:
         1. #2 Chill Water Pump Motor
         2. Air Handling Unit 71-AHU-041
         3. Room 3210 Lighting Circuit
         4. Panel 450A2A
         5. Main Fresh Water Supply to B15
   2. Unique Alphanumeric Designator of the Energy Isolation 
      1. This is the number or designator found on the energy isolation itself. Breakers are typically identified by their location in an electrical panel. Valves often have metal tags with a stamped alphanumeric designator.
      2. Examples:
         1. 321A34A-14
         2. CH-12-RET
   3. Energy Type and Magnitude. This is a descriptive classification of the type of energy. For electrical sources, this is typically voltage, voltage type (AC/DC), and arc flash energy data.
   4. Isolation Position. This is typically “LOCKED OPEN,” “LOCKED CLOSED,” “TAGGED OPEN,” and “TAGGED CLOSED.” Other descriptors can be used for special circumstances.
   5. Initial Boxes for the Person In Charge. The Person In Charge initials these boxes to establish and clear each energy isolation.

4. Hazardous Stored Energy Continuous Dissipation Device Checklist. This section identifies each hazardous stored energy continuous dissipation device in a checklist format. Each hazardous stored energy continuous dissipation device must be listed on a single line item with the following information:
   1. Equipment or energy source being dissipated
   2. Dissipation point
   3. Stored energy type
   4. Stored energy magnitude
   5. PPE
   6. Initial boxes for the Person In Charge to establish and clear each dissipation device.

5. LOTO Sequence. Where a specific sequence is required to establish the LOTO, a step-by-step shutdown, switching, and/or valving checklist must be added to the LOTO procedure. 

Appendix C. Absent Person LOTO Lock Removal Form

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