Safety Leader

LOTO Requirements and Procedures: OSHA standards and 2021 NFPA 70E revisions

Published On
Feb 14, 2022

NFPA 70E requires that each employer implement and document an electrical safety program (ESP). During the 2021 revision cycle of NFPA 70E, new requirements were added to include an electrically safe work condition (ESWC) policy and a lockout/tagout (LOTO) program in the employer’s written ESP.

The ESWC policy must simply mirror the requirements of NFPA 70E Section 110.3, which mandates that an ESWC be implemented before an employee performs work inside of the limited approach boundary or where the employee is interacting with equipment where conductors or circuit parts are not exposed but an increased likelihood of arc flash exists. The required written LOTO program must be in accordance with NFPA 70E Section 120.1(A) and may be included in or referenced in the ESP.

NFPA 70E includes requirements for locking out and tagging equipment and circuits in Article 120, Establishing an Electrically Safe Work Condition. These requirements are far more prescriptive (providing clarity for employers and employees) than federal regulation enforced by OSHA, which does not use the term ESWC.

NFPA 70E requires an ESWC (more than just LOTO), mandating that we create a state in which electrical conductors or circuit parts are disconnected from energized parts, then locked/tagged in accordance with the employer’s prescriptive LOTO procedures and tested to verify the absence of voltage.

NFPA 70E also requires that, if necessary, electrical conductors or circuit parts are temporarily grounded for personnel protection. The use of “ESWC” in NFPA 70E provides significant clarity and usability. It is a state that temporarily eliminates electrical hazards for the period of time for which the state is maintained. It is extremely important to note that NFPA 70E Section 110.2 clarifies that electrical conductors and circuit parts are not considered to be in an ESWC until all of Article 120’s requirements are met. Employers cannot simply provide a prescriptive LOTO procedure and consider the job done. The ESP must address all of Article 120’s requirements and the practical application of creating an ESWC.

The NFPA Standards Council formed the technical committee for NFPA 70E to assist OSHA in preparing an electrical safety standard to serve OSHA’s needs that could help expedite the OSHA promulgation process. Requirements for LOTO in NFPA 70E are an excellent example of one day achieving that goal.

The OSHA requirements for LOTO vary significantly between standards, and as OSHA standards are revised, the requirements of NFPA 70E Article 120 can be modified into federal regulation. The 1926 Construction standard is Section 1926.417, Lockout and tagging of circuits. However, a requirement to “lock out” circuits does not exist there. The only OSHA requirement for equipment or circuits that are deenergized by employees working in construction (OSHA 1926) is to ensure that the circuit is “rendered inoperative,” and tags are attached at all points where the equipment or circuits can be energized.

A standing letter of interpretation supports this requirement and explains that OSHA uses the phrase “rendered inoperative,” rather than “locked out” to indicate that methods other than lock-out would be permissible, provided the equipment or deenergized circuit is rendered inoperative, for example, by the removal of fuses or some other circuit element for each phase conductor or disconnecting the circuit conductors.

The LOTO requirements of the OSHA 1910 General Industry Standard are more prescriptive, and employers must provide step-by-step LOTO procedures of 1910.333(b)(2) in writing. This procedure must also be made available to all employees and OSHA. A note in the General Industry Standard permits employers to copy and paste the written procedures in 1910.332(b).

The prescriptive LOTO procedures in 1910.332(b) are mirrored in and significantly clarified in NFPA 70E Section 120.5, “Process for Establishing and Verifying an ESWC.” There is much more to the LOTO procedures in NFPA 70E located in Section 120.4.

Two subdivisions here address LOTO planning and elements of control including, but not limited to, the use of up-to-date single-line drawings or other effective means to locate all sources of power. The plan must also identify the “person in charge” and all others who may be exposed to an electrical hazard.

The procedures can be applied as simple or complex LOTO, and must also identify the person who will perform switching as well as where and how to deenergize the load. Procedures must also include the release of stored electrical or mechanical energy and how to verify that the circuit is deenergized (such as visually verifying that disconnect blades are open). Also addressed is responsibility, verification, testing, grounding, shift changes, coordination with other jobs or tasks, accountability for all personnel, the LOTO application including the use of tagout procedures where a lock cannot be installed, the removal of LOTO devices and the return of equipment to normal service.

About the Author

Jim Dollard

Code Columnist

Jim Dollard is the safety coordinator for IBEW Local 98 in Philadelphia. He is a member of the NEC Correlating Committee, NEC CMP-10, NEC CMP-13, NFPA 70E, NFPA 90A/B and the UL Electrical Council. He can be reached at codefaqs@gmail.com.

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