Everything About LOTO Tags Requirements and Limitations

wax pencil on loto tag

Communication is an essential safety measure to help keep everyone informed of any potential hazards in the workplace. One excellent tool for effective safety communication during repair or maintenance work is the use of LOTO tags.

LOTO tags or lockout tagout tags are used as part of a complete lockout/tagout (LOTO) program. They are usually made of durable materials, such as plastic or metal, and are designed to be attached to the energy isolation devices used to secure machinery or equipment in a safe or OFF position. These safety tags are used to communicate important information about the energy control procedures being used, such as the reason for the lockout, the person who performed the lockout, and the expected time for the lockout to be released.

In this article, we will further discuss everything related to lockout tagout tags, from OSHA requirements to their usage limitations. So, if you're curious and want to learn more, then keep reading!

OSHA Requirements for LOTO Tags

OSHA has provided guidance on the use of tagout devices in various standards, such as the 29 CFR 1910.147 The Control Of Hazardous Energy (Lockout/Tagout). Below is a brief discussion for each one.

osha requirements for loto tags

Durable

Tagout devices must be built and printed in such a way that exposure to weather or damp environments does not cause the lockout tag to deteriorate or the message on the lockout tag to become unreadable. When utilized in corrosive conditions, such as locations where acid and alkali chemicals are handled and stored, tags must not also deteriorate.

Substantial

Tagout devices, including their attachment methods, must be sturdy enough to prevent unintentional or accidental removal. Tagout device attachment methods must be non-reusable and attachable by hand. It should also require a minimum unlocking strength of 50 pounds and be designed in a way that is comparable to a durable nylon cable tie that can be used in all types of environments.

Identifiable

Lockout and tagout devices must indicate the identity of the employee who applied them, and tagout devices must also provide warnings of hazardous conditions and include a clear legend to prevent machines or equipment from starting or operating. This includes legends such as Do Not Start, Do Not Open, Do Not Close, Do Not Energize, Do Not Operate. 

Moreover, 29 CFR 1910.145 Specifications for Accident Prevention Signs and Tags states that tags must include specific signal words, such as "Danger," "Caution," or "Biological Hazard," "BIOHAZARD," or the biological hazard symbol, and clearly identify the hazard and safety precautions necessary to be communicated to the employees.

The tag should also provide details of who attached it, including its date and time. Ultimately, tags must securely attach to the hazard as closely as possible using reliable means such as string, wire, or adhesive to prevent unintentional removal.

ANSI Requirements for LOTO Tags

ANSI also provides guidelines for the design, format, and content of safety tags outlined in ANSI Z535.5-2011. Some of the key requirements for LOTO tags include the following:

  • Use of standardized header and signal word formats to convey the severity of the hazard and the urgency of the message.
  • Use of standardized colors, with red indicating immediate danger, orange indicating a warning, and yellow indicating caution.
  • Use of standardized text to clearly and concisely communicate the specific hazard and the action required to avoid the hazard.
  • Use of standardized symbols and pictograms to convey information when language barriers or low literacy levels may be a concern.

Are LOTO Tags Required in Lockout/Tagout Procedures?

Yes, LOTO Tags are required in Lockout/Tagout procedures as per OSHA. The lockout/tagout standard, 29 CFR 1910.147, specifies that tags must be used as an integral part of the LOTO program to indicate that the equipment is being serviced or maintained and should not be turned on until the maintenance or servicing is complete.

Can Lockout Tags Be Reused?

No, lockout tags cannot be reused, as stated by OSHA. Rightly so, because then it can cause confusion and compromise the safety of workers who rely on these safety tags to keep them safe from dangerous energy sources.

Information on a Lockout Tag

Lockout tags must specify the service or maintenance work being done in addition to the general message of warning employees not to remove the tag or restore power to a machine. Additionally, it is imperative that the person who attached their own tag and lock to the system includes their name, department, and date of attachment on the safety lockout tagout tags.

information required on loto tag

Should LOTO Tags Have a Specific Color?

Yes, LOTO tags should have a specific color to help ensure that they are easily identifiable as part of a lockout/tagout program. OSHA and ANSI have provided guidelines for using colors in workplace safety to help identify hazards, communicate information, and prevent accidents.

color code for signs and tags

According to OSHA 1910.144, Red is the basic color for identifying danger, emergency stop bars or stop buttons, and fire protection equipment. Meanwhile, Yellow shall be the basic color for designating caution and for marking physical hazards such as: Striking against, stumbling, falling, tripping, and "caught in between."

Benefits of LOTO Tags

Below are some practical advantages of implementing LOTO tags in the workplace:

  1. Using a lockout tag enhances the safety of employees at work by alerting them of potential danger.
  2. Lockout tags serve as a last line of defense against hazards in certain situations, particularly when the proper application for these devices is followed.
  3. Safety LOTO tags clearly indicate that the machine or equipment should not be used, which helps prevent accidental startups or operations.
  4. The essential safety information written in lockout tagout tags prevents worker confusion and miscommunication.
  5. Lockout tags can be a helpful solution in situations where it is impossible to physically lock out an energy-isolating device.
  6. Lockout tagout tags are designed with clear and universally recognized symbols, colors, and pictograms, which help communicate safety information to the multiracial workforce.

Limitations of Tagout Devices

While a tag provides many practical and prominent benefits and advantages, these tools do have limitations, and OSHA specifically identifies these limits in its Control of Hazardous Energy (Lockout/Tagout) regulation (29 CFR 1910.147).

According to OSHA, tags only serve as warning devices and do not provide the same level of physical restraint as a lock. Tagout devices may also evoke a false sense of security; thus, their significance must be recognized as part of the entire energy control program.

Other Types of Safety Tags

Keeping your workplace safe starts with understanding the importance of safety tags — and not just lockout tagout tags. Listed below are five different types of safety tags, along with a guide on when to use them and why they're essential.

1. Lockout/Do Not Operate Tags

As OSHA requires, Do Not Operate Lockout Tags are used during lockout/tagout procedures alone. Because they communicate high-risk dangers and critical information about the equipment being serviced or maintained, utilizing lockout tags for any other purpose can lead to confusion and misinformation, compromising worker safety and equipment integrity.

Failure to follow these regulations may result in OSHA penalties of up to $15,625 per violation, with additional fines of up to $15,625 per violation every day over the deadline to resolve the matter. Meanwhile, the maximum penalty for willful or repeated violations can be fined up to $156,259 per violation. In 2021, Lockout/Tagout was the fifth most cited violation.

2. Inspection Tags

Inspection tags are safety tags used to communicate which equipment has been through an inspection process. It keeps track of the date and time of the last inspection, the results of the equipment inspected, the name of the person who did the inspection, and when the next service is due. Without these safety inspection tags, it can be challenging to keep track of equipment information and may risk missing critical inspections, which could lead to equipment failure, accidents, or other safety hazards.

The most common types of inspection tags used in the workplace include Ladders & Scaffolds, Fire Extinguishers, Emergency Shower and Eyewash Stations, Forklifts, and more.

3. Equipment Tags

An equipment tag is a physical label or tag that is affixed to a piece of equipment, machinery, or other assets to provide information about the equipment. It may include details such as the equipment's identification number, maintenance or inspection schedule, safety warnings, operating instructions, or other relevant information. They are commonly used in industrial or commercial settings to help ensure equipment is properly maintained and operated safely.

4. Barricade Tags

Barricade Tags are tags that are used to alert employees or individuals that an area is off-limits or temporarily inaccessible. They are frequently used in industrial and construction sites or other areas where it is important to notify workers or the public that an area is in a hazardous situation.

Workplace tags like this one typically have a bright color, such as red or orange to make them highly visible. Barricade Tags also communicate additional safety information, such as the potential hazard or reason the barricade is installed, the date and time of installation, and the contact information for the responsible party.

5. Confined Space Tags

When there are confined spaces present at work, it is crucial to label them with Confined Space Tags. Proper labeling helps communicate confined spaces' dangers to workers, contractors, and visitors. It aids in ensuring that everybody entering the space is aware of the possible hazards and takes the necessary safety measures.

OSHA classifies a space as a "Permit-required Confined Space" if it possesses one or more of the following characteristics:

  • Potentially hazardous atmosphere
  • Contains materials capable of engulfing an entrant
  • Possesses inwardly convergent walls or floors that slope downhill and taper into a smaller space, potentially trapping or asphyxiating an entrant
  • Contains any other known safety or health threat, such as unsupervised machinery, exposed live wires, or heat stress

Who Can Remove Tagout Devices?

According to OSHA 29 CFR 1910.147(e)(3), each lockout or tagout device must only be removed from the energy-isolating device by the employee who applied the device. However, there are some exceptional circumstances where someone else may be permitted to remove the device.

In situations when the authorized employee who applied the lockout tag is not present, and it is necessary to remove the tag for safety reasons, the lockout tag can be removed by another authorized employee who has been designated to perform the same job or task and who has been trained in the lockout/tagout procedures.

Can Tagout Devices Be Used in Place of Lockout Devices?

According to OSHA, tagout devices can be used in place of lockout devices when there is no way to lock out a device, and the employer can demonstrate that tags will ensure full employee protection. It is important to note, though, that while tagout devices can be used instead of lockout devices, they are not as effective.

Is Lockout Safer Than Tagout?

Essentially, lockout is safer than tagout. Lockout provides a physical barrier to prevent accidental re-energization, which helps ensure that the equipment remains off until work is complete. Meanwhile, tagout is a procedure typically done in conjunction with lockout to provide additional information about the status of equipment being serviced or maintained.

While the above statements are true, it is imperative to note that lockout and tagout procedures must always be performed together to ensure complete lockout and securing hazardous energy sources, thereby minimizing the potential for unintended startup or energy release during maintenance or repair operations.

In Conclusion…

Effective tagout procedures are crucial for maintaining employee safety when working with machinery or equipment being repaired or maintained. OSHA requires employers to follow specific guidelines for using lockout and tagout devices. Besides facing penalties and citations, failure to comply with these guidelines can result in serious accidents or injuries.

While lockout tags are a crucial safety measure, it is important to note that they are not a substitute for proper lockout/tagout procedures. By following OSHA guidelines for lockout tagout tags and taking a proactive approach to safety, employers can help prevent accidents and injuries and create a safer work environment for everyone.

The material provided in this article is for general information purposes only. It is not intended to replace professional/legal advice or substitute government regulations, industry standards, or other requirements specific to any business/activity. While we made sure to provide accurate and reliable information, we make no representation that the details or sources are up-to-date, complete or remain available. Readers should consult with an industrial safety expert, qualified professional, or attorney for any specific concerns and questions.

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Author: Herbert Post

Born in the Philadelphia area and raised in Houston by a family who was predominately employed in heavy manufacturing. Herb took a liking to factory processes and later safety compliance where he has spent the last 13 years facilitating best practices and teaching updated regulations. He is married with two children and a St Bernard named Jose. Herb is a self-described compliance geek. When he isn’t studying safety reports and regulatory interpretations he enjoys racquetball and watching his favorite football team, the Dallas Cowboys.