Keep Employees Safe During Vehicle Lockout/Tagout

By Mark Stromme

Tow professionals count on their vehicles and equipment to be in top-notch condition. After all, life is good at work when your machines are running smoothly. But, all good things come to an end, and you can count on your equipment needing service, maintenance, and repairs from time to time.

You want to keep downtime to a minimum, however, and workers can be tempted to make a quick fix without making absolutely sure the equipment won’t start up or release stored energy during the repair. If it does start up, there can easily be a serious injury or a death. That’s the reason for having lockout/tagout (LOTO) procedures.

OSHA’s Lockout/Tagout Standard

The Occupational Safety and Health Administration (OSHA) regulates lockout/tagout through the Control of Hazardous Energy standard, found at 29 CFR §1910.147. This standard mandates training, audits, and recordkeeping to ensure that workers will not be unintentionally injured by the unexpected energization, start-up, or release of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or any other type of energy.

Does It Apply to Vehicle Servicing and Maintenance?

Yes, it does. According to OSHA, accidents have occurred and continue to occur from inadequate hazardous energy control during vehicle servicing and maintenance activities.

In 1991, the U.S. Court of Appeals for the District of Columbia remanded the LOTO standard to OSHA for further consideration of the ways in which the final rule applies to all general industry workplaces. OSHA, in the March 30, 1993 Federal Register (Vol. 58, No. 59), reaffirmed and further explained the reasons for applying the standard to vehicle servicing and maintenance.

The scope and application sections of the preamble to the hazardous energy control standard provide that the LOTO standard applies to all “general industry workplaces.” The standard’s coverage includes vehicles, such as, but not limited to, automobiles, trucks, tractors, refrigeration transport vehicles, and material handling equipment.

What exactly is lockout/tagout and why is it so important?

The Basic Difference Is the Use of Locks

When you hear the term “lockout/tagout,” you might think lockout and tagout is the same thing or that you have to use both methods together. But, these are two different ways to isolate a machine from its energy supplies to keep it “off” during the repair job.

“Lockout” uses locks on the switches and valves that supply energy to a machine. The energy isolating devices can’t be moved from the “off” position because a padlock keeps them off.

“Tagout” uses warning tags on switches and valves. When you use tagout, there’s no lock to keep energy isolating devices in the off position. The tag has a clear warning on it to leave the equipment off, but tagout doesn’t provide the physical restraint that lockout provides.

You have to use tagout if the energy isolating device isn’t capable of being locked out. In this case, you really don’t have any choice — you can’t apply a lock, so you have to apply tagout. This may be the case with older equipment.

But, whenever you replace, or do a major repair, renovation, or modification of the machine, the energy isolating devices have to be upgraded to accept lockout. Also, whenever you install new machines or equipment, they must accept lockout. Basically, OSHA says that when the equipment can be locked out, you’re expected to use lockout procedures.

That being said, OSHA does allow you to still use tagout even if the equipment will accept lockout. To do this, your tagout system must provide “full employee protection,” and OSHA has additional requirements. You must use “additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle.” Taking these steps reduces the likelihood that the machine will start. Be sure to include these additional steps in your documented tagout procedure for the machine.

Whether you use lockout or tagout, both methods assure the mechanics that the machine won’t start up or release stored energy because someone operated a control to run the equipment or accidently hit a switch.

These are the LOTO basics. But what does OSHA say about the controlling of hazardous energy when working on your tow vehicles?

Controlling Hazardous Energy on Vehicles

The OSHA standard’s coverage includes vehicles, such as, but not limited to, automobiles, trucks, tractors, refrigeration transport vehicles, and material handling equipment.

For purposes of vehicle servicing and maintenance, hazardous energy refers to:

Mechanical motion;
Potential energy due to pressure, gravity, or springs;
Battery-generated electrical energy;
Thermal energy, including chemical energy; and
Other forms of energy, which can cause injury to employees working in, on, or around machines or equipment.

Any vehicle (e.g., internal combustion engines such as gasoline, natural gas and diesel powered vehicles; electric-powered vehicles; hybrid vehicles) may contain the following types of hazardous energy, such as, but not limited to:

Chemical energy due to contact with battery acid, coolant, lubricants;
Electric battery shock, arc, and burn hazards;
Explosion hazards associated with air bags;
Fire and explosion hazards associated with the fuel and fluid systems;
Gravitational energy (mechanical) hazards caused by elevated vehicles (e.g., unsafe use of automotive lift equipment) or vehicle components (e.g., unsupported elevated dump truck beds; unsupported elevated forklift carriage assembly);
Hot or cryogenic fluid, and surface (thermal) hazards;
Hydraulic hazards associated with fluid pressure and fluid loss (e.g., causing a carrier bed to drop);
Mechanical hazards associated with disc brake spring and tire components;
Mechanical motions due to moving power transmission components;
Premise wiring electric hazards associated with battery recharging (which are addressed by the Subpart S – Electrical standards); and
Mechanical hazards associated with unexpected start-up or unexpected energization of vehicles or vehicle components.

Energy Control Program

OSHA’s 29 CFR 1910.147 standard requires employers to develop an energy control program:

That is tailored to the workplace, and
Will protect employees performing servicing and maintenance tasks from the release of hazardous energy.

The performance-oriented language allows employers flexibility to design and implement the required energy control procedures, employee training requirements, and inspection requirements to fit the individual conditions present in their workplaces.

The selection of the specific method of control must reflect a thorough evaluation of the:

Extent of exposure to the hazard;
Risk of injury associated with the particular machine/equipment; and
Feasibility of applying a particular method of control.

Removing the Ignition Key

Due to the nature and unique aspects of vehicle maintenance and servicing activities, the control of hazardous energy final rule’s preamble recognizes feasible measures to prevent an engine from being started. OSHA references situations, involving vehicles, such as automobiles, buses, and over-the-road trucks, where the removal of the ignition key ensures that the engine cannot be started.

However, this simple control step of removing the ignition key may not, in all cases, adequately control other types of vehicle hazardous energy, such as is the case with the positioning of the vehicle or its components (e.g., buckets, blades, vehicle body parts). These and other hazards require careful evaluation and selection of additional hazard-specific control measures.

OSHA Says

It should be noted that turning off the engine with and removing the car key is not, strictly speaking, the same as applying a lockout or tagout device to an energy isolating device (EID) because neither the ignition switch, nor the key, are EIDs. See §§ 1910.147(b) and (d)(3) for the energy isolating device definition and application of control provisions. Based upon the above standard’s preamble discussion, OSHA allows such alternative vehicle control measures in these limited circumstances only when the key removal fully ensures employee protection.

Turning off the engine and removing the ignition key may provide a significant degree of protection in many situations in which an employee is performing vehicle repair or maintenance. The authorized employee performing the repair or maintenance would need to retain sole control of the key (assuming the keyed switch is the only means of vehicle start-up). An additional precaution for the employee retaining the key would be to lock the doors.

Although this control practice reasonably protects employees from inadvertent startup of the vehicle’s engine, it may not adequately control other energy sources that are independent of the ignition key subsystem.

One Person Is Performing the Servicing

These exclusive control practices, if incorporated into the energy control program, are feasible measures that significantly reduce the risk of exposure to the hazardous energy associated with the start-up of an internal combustion vehicle engine in situations in which a single individual is performing the servicing and/or maintenance work.

However, although turning off the engine and retaining exclusive control of the ignition key may provide significant protection in some instances, there may be circumstances where there are other keys and/or other employees involved in the work activity. In situations such as these or when the work itself may activate the ignition circuit, additional measures are necessary to protect employees from hazardous energy exposures.

For example, employees have been struck by and even run over by vehicles when the technician “shorted out” the ignition circuit, causing the vehicle to unexpectedly move. In another example, potential unexpected start-up hazards exist with older diesel engines because they could be “jump-started” by putting the vehicle in gear (without setting the brakes) and then simply pushing/rocking (“budging”) the vehicle enough to start it (with or without the ignition on).

That is why it is very important that the selected control measure(s) effectively protect exposed workers from all types of hazardous energy.

Manufacturers’ Servicing and Maintenance Guidelines

It is essential for employers to consult with and incorporate specific vehicle manufacturer servicing and maintenance guidelines (e.g., operating manuals and bulletins) and other relevant materials to establish the hazardous energy control procedures. These manuals and materials often provide specific step-by-step instructions on how to safely perform servicing or maintenance tasks.

For example, the removal of an ignition key is not sufficient to protect employees from devices that may operate or activate independently of the ignition system. That is why it may be necessary to disconnect the battery cable for some repair tasks, such as working on some cooling fans, which automatically start up even after the key has been removed.

Likewise, air bags may inadvertently deploy and cause employee injury if the system is not properly controlled and residual energy dissipated before servicing or maintenance begins.

Employers, who meet manufacturers’ servicing and maintenance guidelines, may be cited for a §1910.147 violation if the manufacturer guidelines inadequately control the vehicle’s energy sources and employee exposure exists to hazardous energy.

Troubleshooting, Testing, and Component Positioning

There are circumstances when it is necessary to re-energize the vehicle or a component to accomplish a particular task (e.g., diagnostic testing; maintenance troubleshooting; vehicle or component positioning). OSHA does allow energization for testing or positioning purposes, as specified in §1910.147(f)(1), but only for the limited time during which it is necessary to test or reposition the vehicle or component.

During these transition periods, employee exposure to hazards is high and a procedure needs to be developed to define the sequence of actions to accomplish the task safely. Under no circumstances is any part of an employee’s body ever permitted to be exposed within a hazardous area, such as the point-of-operation or in-going nip point area, during servicing and/or maintenance activities while the machine is running or energized.

The use of supplemental safeguarding actions, such as personal protective equipment to protect against hot surfaces, use of a tarp to shield a hot surface or in-going nip point, safe work positioning, etc., must be used in conjunction with established procedures to protect your employees

Working Safely

OSHA requires employers to develop LOTO procedures and to have workers follow them. If you cut corners on these procedures, the result is likely to be equipment downtime, accidents, OSHA inspections and citations, and, possibly, employee fatalities.