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You Make the Call – Did this Worker Get Adequate LOTO Training?

OHS laws require employers to establish safe procedures and policies to ensure that machinery and equipment is effectively de-energized and isolated from its source of power before work is carried out on it, and that it is then safely re-energized and restored to service after the work is completed. Employers must also verify that workers involved in LOTO operations get the training they need to understand and be capable of carrying out their roles and responsibilities under those procedures. This scenario illustrates the training required for what’s known as an “authorized” or “qualified” worker who’s got the technical electrical background necessary to perform LOTO and other low-voltage electrical operations at a workplace.

Situation

May Tennance, a machine technician at the ABC Auto Parts Manufacturing Plant, is an “authorized” worker allowed to perform lockout tagout operations to ensure machinery or equipment is completely deenergized before it’s serviced. May received comprehensive LOTO training covering all the machines she was assigned to work on 2 years ago. A year later, the plant reassigns her to work on a different machine without training her how to lock it out. But the plant did give her a copy of the LOTO procedure for the machine at the time of reassignment. May also receives general safety training not covering LOTO every year.

Question

Did the plant provide proper May proper LOTO training?

  1. Yes, because it furnished her comprehensive LOTO training 2 years ago.
  2. Yes, because it gave her the LOTO procedure for the machine when reassigning her to work on it.
  3. Yes, because it provided and continues to provide her general safety training.
  4. Yes, because it provided her all of the above.
  5. No.

Answer

  1. No, the plant didn’t provide May adequate LOTO training because it didn’t train her how to lockout the specific machine to which she was reassigned.

Explanation

While OHS rules vary slightly by province, authorized/qualified workers engaged in LOTO operations generally need to be trained in:

  • The recognition of energy sources in the workplace.
  • The type and magnitude of energy available in the workplace.
  • The methods and means necessary for energy isolation and control.

As we’ll see below, the various safety training May received from the plant falls short of this standard because it didn’t show her to safely carry out the LOTO procedure for the machinery to which she was reassigned. So E is the correct answer.

Why Wrong Answers Are Wrong

A is wrong because the original LOTO training May received 2 years ago covered all of the machines she was assigned to work on at that time. The problem is that it didn’t cover the machine to which she would be reassigned a year later. So, May should have received new training in the LOTO procedure for that particular machine after being reassigned to and before being allowed to work on that machine.

B is wrong because simply handing a worker a copy of the LOTO procedure isn’t enough to meet the standard for proper LOTO training. The employer must also ensure that workers actually understand the LOTO procedure and acquired the knowledge and skills necessary to carry it out safely.

C is wrong because general safety training that doesn’t even cover LOTO isn’t adequate LOTO training.

D is wrong because none of the “LOTO training” May received provided her what she needs to safely perform her duties as an “authorized worker,” namely, training on the specific LOTO procedure that applies to the machine to which she’s been reassigned.

3 Takeaways

  1. LOTO training for authorized workers must be machine-specific—general LOTO training purporting to cover every kind of machine in the workplace isn’t enough.
  2. Workers must receive new LOTO training when they’re reassigned to machines that their previous LOTO training didn’t cover.
  3. LOTO training for any worker must be verified to ensure that workers actually understood and acquired the knowledge and skills necessary to carry out their roles and responsibilities under your companies LOTO program and procedures.