Lockout / Tagout - Ohio Bureau of Workers' Compensation

WHY THIS LOCKOUT IMPLEMENTATION KIT
Lockout is the most important single safety program in UAW-represented worksites. From 1973 to this
writing, 94 members have been killed by incidents which full application of lockout would have prevented.
About 1.000.000 injuries could have been prevented. The training provisions of the standard give us an
opportunity to improve safety at the same time as we reach our membership with a positive union
message.
The OSHA Lockout Standard was published in August 1989 to become effective in January 1990.
However, there was little enforcement of the new rule because OSHA had not published its compliance
directive explaining to inspectors how to enforce the standard. In addition to the delay in implementation,
there is currently no parallel standard for Lockout enforceable by the Michigan Department of Labor
(MIOSHA) or other state regulatory agencies (state OSHA plans).
On September 14, 1990, OSHA finally published corrections to the standard, changes in the explanation
of the standard, and the final compliance directive. The UAW filed suit against OSHA, seeking
improvements in the standard. Unfortunately, the lawsuit was unsuccessful.
The OSHA lockout standard contains some requirements not necessarily found in advanced lockout
programs. The standard requires written lockout procedures for each piece of equipment in a facility, as
well as periodic employer self inspections to determine compliance with the procedures. In addition to
these new features, the standard requires the general approach to lockout and training of the nature
implemented in many major facilities.
Unfortunately, the standard also contains some substantial deficiencies. The standard permits tags to be
used instead of locks in some circumstances; it permits employers to delay modifying equipment to be
locked out until replacement or major renovation, and it accepts group lockout procedures other than one
person-one lock. In addition, the standard does not require the worker and union participation in devising
lockout procedures and training, which have been shown necessary in advanced programs.
The lockout/tagout standard is now fully in effect, and OSHA enforcement is now going on, with frequent
citations being issued. Therefore, all local unions should meet with management to review the standard,
and determine how the employer intends to implement the program. The review is also an opportunity to
negotiate = some of the potential problems with implementation, and negotiate in union involvement and
other improvements.
This kit includes extensive explanatory materials. In addition, it has a "fill-in-the-blanks" lockout
compliance program. Your employer is required to have a written lockout program and keep records on
its implementation. The fill-in-the-blanks document covers all the issues required by the lockout standard.
The draft program also specifies how certain procedures should be carded out and provides
recordkeeping forms. Most important, it fills in the holes left in the standard, including specifying the
union involvement needed to make the program work. Existing lockout programs should be compared to
this draft program, and management should be asked to adopt this program, with the blanks filled in, as
its own.
Questions about this compliance plan may be addressed to:
Health & Safety Department,
International Union, U.A.W.
8000 East Jefferson,
Detroit, Michigan 48214.
(telephone (313) 926-5566)
(fax (313) 824-4473)
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