Does OSHA require a JHA for lockout?

OSHA does not require a written JHA for lockout. The general industry standard does require documented energy control procedures, with one narrow exception, plus training and periodic inspections (29 CFR 1910.147(c)(1) and (c)(4)(i)). A JHA is a good way to build and test that procedure.

What goes in a lockout JHA?

Include energy sources, notification and shutdown, isolation, lock and tag, stored energy, verification, the service work and restart. Name the authorized employees, the lock owners and each isolation point.

What if the machine cannot be locked out?

If an energy isolating device cannot be locked out, the energy control program must use a tagout system (29 CFR 1910.147(c)(2)(i)). A tag warns; it does not physically stop anyone from restarting the machine, so follow every tagout rule in your program.

FREE JHA TEMPLATE

Lockout job hazard analysis (JHA) template

Servicing a machine that starts, moves or releases stored energy by surprise can crush, catch or shock a worker. The general industry lockout/tagout standard requires an energy control program with procedures, training and periodic inspections (29 CFR 1910.147(c)(1)). Follow the same steps every time, in order, with your own lock.

Open in the generator Download PDF

The task

Locking out and tagging a powered machine, such as a mixer, pump, conveyor or compressor, before servicing or maintenance, and restoring it afterward.

Steps, hazards and controls

Controls run from most effective to least. A citation beside a control means an OSHA paragraph requires it; with no citation it is good practice.

Step	Hazard	Controls
1. Know the machine and its energy sources	A hidden energy source is missed	Administrative control: Use the written energy control procedure for the machine; it must outline the scope, purpose, authorization, rules and techniques. (29 CFR 1910.147(c)(4)(ii)) Administrative control: Before shutdown, learn the type and size of the energy, the hazards and the method to control it. (29 CFR 1910.147(d)(1)) Administrative control: Walk the machine and list electrical, hydraulic, pneumatic, gravity, spring and thermal sources, including any that feed from other machines.
2. Notify people and shut down	Operator or a nearby worker is surprised by the shutdown	Administrative control: Tell affected employees that a lockout is about to happen and why. Administrative control: Shut the machine down in an orderly way using its established procedure to avoid creating a new hazard. (29 CFR 1910.147(d)(2)) Administrative control: Use the operator to confirm the process is safe to stop before isolating.
3. Isolate the machine	Machine can still receive power	Eliminate: Locate and operate every energy isolating device so the machine is isolated from its sources. (29 CFR 1910.147(d)(3)) Engineering control: Use the machine disconnect, valve or breaker; a control switch such as a push button is not an isolating device. Administrative control: Isolate the equipment from all sources, including from other equipment that could feed it.
4. Apply your lock and tag	Someone else restarts the machine	Administrative control: Have the authorized employee affix lockout or tagout devices to each energy isolating device. (29 CFR 1910.147(d)(4)(i)) Administrative control: If an energy isolating device cannot be locked out, use a tagout system under the energy control program. (29 CFR 1910.147(c)(2)(i)) Administrative control: Use the employer-provided locks, tags, chains, wedges and blocks. (29 CFR 1910.147(c)(5)(i)) Administrative control: For crew work, use a group lockout procedure that gives each person protection equal to a personal lock. (29 CFR 1910.147(f)(3)(i))
5. Relieve stored energy	Stored or residual energy releases during work	Engineering control: Bleed, block, ground, vent or restrain all stored or residual energy, such as springs, pressure and raised parts. (29 CFR 1910.147(d)(5)(i)) Administrative control: Recheck for build-up of stored energy while the work is under way. PPE: Wear eye and face protection when bleeding pressurized lines.
6. Verify isolation	The machine is not actually dead	Administrative control: Verify isolation and deenergization before work starts. Trying the start control with everyone clear is a common way to check. (29 CFR 1910.147(d)(6)) Administrative control: Return controls to off after the test.
7. Perform the service work	Pinch points, hot parts and surprise movement while working	Administrative control: Keep your own lock on until the job is done, and do not let anyone else remove it. Administrative control: Only the authorized employees doing the servicing may perform the lockout. (29 CFR 1910.147(c)(8)) PPE: Wear gloves, safety glasses and other PPE for the task.
8. Remove devices and restart	Machine restarts with someone inside or clamped to it	Administrative control: Inspect the work area, remove nonessential items and confirm machine parts are intact. (29 CFR 1910.147(e)(1)) Administrative control: Have the employee who applied each lock or tag remove it. (29 CFR 1910.147(e)(3)) Administrative control: Tell affected employees the machine is going back into service, and do a visual check that everyone is clear.

Required PPE

Personal lock and tag (29 CFR 1910.147(c)(5)(i))
Safety glasses
Gloves for the task
Hard hat where overhead hazards exist
Insulating gloves and tester when electrical work is involved

What the standard says

An energy control program with procedures, training and inspections is required. (29 CFR 1910.147(c)(1))
“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”
Procedures must clearly and specifically outline the scope, purpose, authorization, rules and techniques for controlling hazardous energy. (29 CFR 1910.147(c)(4)(ii))
“The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy”
Release stored energy after applying devices. (29 CFR 1910.147(d)(5)(i))
“Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, and otherwise rendered safe.”
Verify isolation before starting work. (29 CFR 1910.147(d)(6))
“Prior to starting work on machines or equipment that have been locked out or tagged out, the authorized employee shall verify that isolation and deenergization of the machine or equipment have been accomplished.”
Only the person who applied a device removes it. (29 CFR 1910.147(e)(3))
“Each lockout or tagout device shall be removed from each energy isolating device by the employee who applied the device.”
Lockout is performed only by the authorized employees doing the work. (29 CFR 1910.147(c)(8))
“Energy isolation. Lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance.”
Concrete and masonry equipment such as mixers and pumps must be locked out and tagged before maintenance or repair where it could start by accident. (29 CFR 1926.702(j)(1))
“No employee shall be permitted to perform maintenance or repair activity on equipment (such as compressors, mixers, screens or pumps used for concrete and masonry construction activities) where the inadvertent operation of the equipment could occur and cause injury,”

Training

Each authorized employee must be trained to recognize hazardous energy sources and the methods to control them. Affected employees must be instructed in the purpose and use of the procedure, and other employees in the area must be told not to restart locked-out equipment (29 CFR 1910.147(c)(7)(i)(A), (B) and (C)).

Frequently asked questions

Does OSHA require a JHA for lockout?: OSHA does not require a written JHA for lockout. The general industry standard does require documented energy control procedures, with one narrow exception, plus training and periodic inspections (29 CFR 1910.147(c)(1) and (c)(4)(i)). A JHA is a good way to build and test that procedure.
What goes in a lockout JHA?: Include energy sources, notification and shutdown, isolation, lock and tag, stored energy, verification, the service work and restart. Name the authorized employees, the lock owners and each isolation point.
What if the machine cannot be locked out?: If an energy isolating device cannot be locked out, the energy control program must use a tagout system (29 CFR 1910.147(c)(2)(i)). A tag warns; it does not physically stop anyone from restarting the machine, so follow every tagout rule in your program.

Related toolbox talks

Lockout/tagout (LOTO): the free talk and the training kit
Machine guarding: the free talk and the training kit
Electrical safety: the free talk and the training kit
Pinch points: the free talk and the training kit

PRINT AND EDIT

JHA template pack, $29

All 20 task templates as editable Word and Excel files and as PDF, in English and Spanish, plus a blank master form. Change them for your site and your equipment and use them inside your company.

20 task JHA templates, editable Word (DOCX)
The same 20 as Excel (XLSX) and PDF
English and Spanish versions
A blank master JHA form
Hazards, ranked controls, PPE and the OSHA paragraphs for each task

Instant download. 30-day refund, no questions.

See the JHA generator and all tasks