If you’re looking to understand more about forklift lockout/tagout, you’re in the right place.
Because we’ve put together the ultimate guide!
Here’s what you can expect to learn:
- What exactly ‘lockout/tagout’ means
- What OSHA’s rules are for locking/tagging out forklifts
- How to lockout/tagout a forklift
- Common forklift lockout/tagout mistakes to avoid
- A simple forklift lockout/tagout checklist
- And lots more…
Let’s dive in!
Table of Contents
- What Is Forklift Lockout/Tagout?
- When Does Forklift Lockout/Tagout Apply?
- OSHA’s Lockout/Tagout Requirements
- What Is Part of a Proper Forklift Lockout/Tagout Program?
- What a Forklift Lockout/Tagout Procedure Looks Like
- How to Lockout/Tagout a Forklift
- 6 Common Forklift Lockout/Tagout Mistakes
- The Top 5 OSHA Lockout/Tagout Violations
- Common Forklift Lockout/Tagout Questions
What Is Forklift Lockout/Tagout?
Lockout/tagout (often abbreviated as ‘LOTO’) is a safety procedure used to ensure that forklifts and other equipment are properly rendered unusable before repairs or maintenance commence on them.
When Does Forklift Lockout/Tagout Apply?
Lockout/tagout procedures apply in the following circumstances:
- When workers face the potential danger of an unplanned machine startup or the release of stored energy when performing equipment maintenance and service.
- When operators must bypass or remove a guard or safety device.
- When operators need to place any part of their body into the danger zone or near the forklift machine’s point of operation.
- During all forklift set-up activities.
OSHA’s Lockout/Tagout Requirements
These procedures are designed to protect workers from the startup of the machine or sudden release of energy during servicing and maintenance.
OSHA Title 29 CFR 1910.147 establishes the minimum performance requirements employers must do to control such hazardous energy. These include:
- Energy control program. Develop, implement, and enforce an energy control program, employee training, and periodic inspections to ensure that before any servicing or maintenance on a forklift or equipment, it’s rendered inoperative.
- Lockout/tagout. Use lockout devices for forklifts (one that can be locked out). Tagout devices should only be used in conjunction with lockout devices if the tagout program offers the same level of worker protection as a lockout program.
- Employee protection. Ensure that new or overhauled equipment can be locked out.
- Tagout program. Develop, implement, and enforce a clear tagout program if forklifts/ equipment cannot be locked out.
- Energy control procedure. Create, document, implement, and enforce effective energy control procedures [with exceptions provided in 29 CFR 1910.147(c)(4)(i)]
- Forklift-authorized lockout/tagout devices. Only use lockout/tagout devices that are approved for the equipment in question, and that meet the requirements of being durable, standardized, and robust.
- Identify users. Ensure that lockout/tagout devices identify the individual users.
- Lockout/tagout application and removal policy. Develop a lockout/tagout policy that authorizes the removal of devices solely by the worker who installed them, to maintain control over the equipment.
- LOTO inspection. Inspect energy control procedures at least annually.
- LOTO training. Provide effective LOTO training as mandated for all workers, who are involved in LOTO as covered by the standard.
- Compliance. Comply with all other additional energy control provisions in the OSHA standards. This includes group lockout situations when the forklift equipment must be tested or repositioned, when outside contractors work at the site, and during personnel/shift changes.
What Is Part of a Proper Forklift Lockout/Tagout Program?
Note: Employers should consult the OSHA standards and other relevant resources to ensure that their program meets all applicable requirements.
A forklift lockout/tagout program has to have 3 core components at a minimum to be compliant with the Occupational Safety and Health Administration’s (OSHA) standards:
- Lockout/tagout procedures
- Periodic inspections
- Training provisions
1. Forklift Lockout/Tagout Procedures
Forklift lockout/tagout procedures are the steps involved to ensure the machine is disabled and energy flow stopped for operators’ safety when the forklift is under maintenance/repair.
OSHA requires any facility with forklifts to have a forklift lockout/tagout procedure in place.
When done correctly, a lockout/tagout procedure disables powered forklifts from releasing hazardous energy or starting unexpectedly during servicing/maintenance activities.
A lockout/tagout procedure must include at least the following:
- A statement of the specific intended use of the procedure
- Steps for powering down and securing the forklift.
- Steps for placing, removing, and transferring the lockout/tagout devices
- Authorization or description of persons responsible for lockout/tagout devices and processes.
- A description of the specific requirements for testing the forklift to verify the lockout/tagout devices’ effectiveness.
2. Periodic Lockout/Tagout Inspections
Lockout/tagout inspections must be conducted at least annually. Only a safety supervisor or authorized employee can conduct a LOTO inspection. And, the authorized employee must NOT have been involved in the lockout/tagout procedure being inspected.
To conduct a successful LOTO inspection, the safety supervisor or authorized employee is required to do the following:
- Identify the equipment or isolation point that the LOTO procedure is for.
- Specify the date (and time) of the workers included in the LOTO inspection.
- Check the forklift lockout/tagout log book and dates.
- Correct any gaps or shortcomings in the LOTO program.
- Review the responsibilities of authorized and affected workers for lockout, tagout, and training.
- Sign and add their name to verify that they’ve conducted the LOTO inspection.
3. Lockout/Tagout Training
There is no specific OSHA requirement that employees trained in lockout/tagout procedures must be formally ‘certified’ to do so.
Instead, what is required is employees be trained so that they understand “the purpose and function of the energy control program” and that each employee has “the knowledge and skills required for the safe application, usage, and removal of the energy controls…”
Just as there are different levels of access for lockout/tagout, there are also different training levels for each type of access:
- Authorized employees. Training includes hazardous energy sources, hazardous energy types and magnitudes, forklift lockout devices, and energy isolation/control methods.
- Affected employees. Training includes the purpose and use of LOTO procedures.
- Other employees. For workers who are or could be in the LOTO area during the procedure, training includes prohibition rules on restarting the locked-out equipment. This helps ensure they maintain operator and pedestrian safety in the facility.
What a Forklift Lockout/Tagout Procedure Looks Like
There’s no one-size-fits-all forklift lockout/tagout procedure. Every operation must develop their own guidelines that suit their particular equipment, workflows, and so on. That said, this section will give you an idea of some common activities involved in forklift lockout/tagout procedures:
- Provide training to all employees with proper LOTO procedures so they familiarize themselves with the procedure.
- Prepare for the shutdown. Identify and isolate the forklift to be locked out and tagged out.
- Install a locking device approved for the particular forklift to ensure it can’t be powered on.
- Shut down the unit.
- Isolate the lift truck from its energy source(s)
- Attach a locked box to the forklift.
- Place a red and white warning tag on the steering wheel. The tag should include detailed information about why the forklift is locked out.
- Attach the lockout or tagout device(s) where energy must be isolated. This helps prevent energy activation of the forklift trucks.
- Any potentially hazardous stored or residual energy must be released, restrained, or rendered safe, which may include removing the key.
- Cordon off the lockout/tagout area. Keep employees and staff at a safe distance away from the forklift during the procedure.
- Search the lockout/tagout area for potential hazards, including flammable materials, and remove them. This includes the LPG tank, if applicable.
- Establish and enforce a policy stating that only the employee who installed the LOTO can remove it once the equipment is no longer considered a threat.
- Have a procedure for work resumption. Once it’s safe to resume operating the forklift/equipment, remove LOTO devices and advise staff that the threat is over.
How to Lockout/Tagout a Forklift
Note: What follows is a lockout/tagout procedure example for material handling equipment. The exact procedure requirements can change depending on the specific equipment involved. Consult your owner’s manual for specifics on the recommended lockout/tagout procedure.
Step 1: Detail your procedure to staff and operators in full, including location.
Step 2: Notify all affected associates. Before starting the lockout/tagout procedure, communicate to ALL impacted associates that a lockout/tagout is about to begin.
Step 3. Prepare to shut down:
- Identify and isolate the forklift to be locked out and tagged out.
- Familiarize yourself with the type and strength of energy, the hazards posed by the energy to be controlled, and the methods of energy control.
- Look for and remove any flammable materials and other potential hazards in the lockout/tagout area.
- Check and ensure lockout/tagout kits for forklifts are in place.
Step 4: Shut down your forklift, following detailed shutdown procedures provided by the manufacturer. For example, turn off the ignition, remove the key, and ensure that the forklift is completely stationary.
Step 5: Lock out the power sources. Use a lockout box or other energy-isolating device to interrupt energy output. If the forklift is battery-powered, remove the battery and lock it out. If it is gas-powered, turn off the fuel supply and lock it out.
Step 6: Eliminate residual energy sources. Follow procedures to eliminate any residual energy sources. Any residual or stored energy that could pose a risk must be dissipated, secured, or eliminated.
Step 7: Test the forklift. You can attempt to start the forklift/equipment to make sure it will not start under any circumstance. If there is a possibility of reaccumulating of energy to a hazardous level, continue verifying isolation until servicing is finished.
Step 8: Tag out the forklift: Use a tag to indicate that the forklift is undergoing lockout/tagout procedures. The tag should include the date, time, and name of the employee who is performing the lockout/tagout.
Step 9: Perform maintenance. Continue with the forklift repair or maintenance as required.
Step 10: Communicate to shifts. Make sure to communicate the breakdown across shifts to ensure no employee is out of knowledge.
Step 11. Clean up the lockout/tagout area:
- Remove non-essential items such as parts, tools, etc.
- Counter-check if all equipment components are operationally intact.
- Counter-check if all staff are in safe positions or have cleared the area.
- Notify all affected workers that the lockout/tagout devices will be removed.
Step 12: Remove the lockout/tagout devices. Only the person who attached the devices should remove them. If not, do not attempt removal and notify the warehouse safety supervisor.
Step 13. Resume work. Once the lockout/tagout is complete:
- Put affected employees on notice that the lift truck will be re-energized.
- Restore energy to the equipment.
- Begin equipment startup.
- Reintegrate equipment into operation.
6 Common Forklift Lockout/Tagout Mistakes
1. Only Removing the Key
Simply removing the forklift key does not constitute locking it out and neither does use an interlock device.
You must fully disconnect and discharge the energy source. The lift truck must be properly shut down to ensure that no energy sources are active.
Failure to correctly lockout and discharge the forklift can cause serious injury to operators and technicians.
2. “Setting and Forgetting”
Inspecting and assessing your lockout/tagout procedure is mandatory, and at least once a year.
Conduct an inspection, and during that time ask for input from your staff. Ensure you update your documentation/retrain as necessary.
3. Not Keeping Employees in the Loop
You must notify all relevant employees of the lockout/tagout procedure or schedule.
Also, ensure all employees are trained to recognize hazardous energy sources, lockout/tagout procedures, and know where to find them.
OSHA requires that you document this training, ensuring that team members know where/who to go to for reference.
You also need to schedule periodic retraining.
4. Not Tagging Machinery with a Lockout/Tagout Tag
The tag is necessary to indicate that the machinery is undergoing lockout/tagout procedures. Otherwise, unknowing employees may walk into the lockout/tagout area and risk exposure to hazards and unsafe situations.
5. Failing to Lock Out All Energy Sources
6. Removing Lockout/Tagout Devices Before Work Is Complete
All lockout/tagout devices must remain in place until work is completed and the machinery is tested. Recall that the person who locked/tagged the forklift out is the only person who can remove the locking devices.
The Top 5 OSHA Lockout/Tagout Violations
The lockout/tagout standard (OSHA Control of Hazardous Energy 29 CFR 1910.147) is the fourth-most-commonly cited OSHA standard.
It is one of OSHA’s persistent inspection priorities and is punishable by fines. For example, a single violation can result in a fine of $15,625!
Top OSHA lockout/tagout violations include:
1. Failing to Have Equipment-Specific Lockout/Tagout Procedures
This is OSHA requirement 29 CFR 1910.147(c)(4) and a common citation.
Machines or equipment that can create a hazard during servicing or maintenance if they start up or cycle unexpectedly, or release stored energy, must have a document lockout/tagout procedure.
The procedure addresses how to control each type of hazardous energy associated with the machine. It also specifics how a worker can safely lock out those power sources.
Maintaining only a generic lockout/tagout procedure on file may be considered a violation by regulatory agencies.
2. Failing to Train Workers in Lockout/Tagout
This is OSHA requirement 1910.147(c)(7).
To ensure compliance with safety regulations, employers must train workers on the purpose and function of the lockout/tagout program. They must also equip employees with the necessary knowledge and skills to understand the program.
Employees fall into three different categories for training:
- Authorized employees. Persons who actually perform servicing and maintenance on locked-out equipment. Their training ensures they recognize the types of hazardous energy sources that exist in the workplace, and know how to isolate and control them.
- Affected employees. These are operators of the forklift that is being serviced or workers in an area where equipment is being serviced. Their training ensures they understand lockout/tagout and know not to interfere or place themselves in danger.
- All other employees. This includes all workers in a workplace where energy control procedures are used. They need a basic understanding of lockout/tagout, and the importance of not attempting to restart or re-energize the forklift under locked/tagged out.
3. Failing to Establish a Lockout/Tagout Program
OSHA requires that you establish a lockout/tagout program. [1910.147(c)(1)]
You need a written program that covers training, your energy control procedures, and periodic inspections. Sometimes employers neglect to create an entire written lockout/tagout program. Other times they just omit certain required elements. Both scenarios can result in a violation.
4. Failing to Follow the Proper Sequence of Lockout/Tagout
OSHA, under requirement 1910.147(d), requires that written procedures for lockout/tagout have certain elements, including:
- Specific shutdown procedures and preparation for shutdown
- Apply energy-isolating devices
- Apply locks or tags to energy-isolating devices
- Verification of isolation
- Procedures for release or restraint of stored energy
- Release from lockout or tagout
- Removal of lockout/tagout devices
Employers must ensure that workers follow these steps whenever performing lockout/tagout operations. Otherwise, it’s a risk of violation, especially if an incident occurs and an investigation reveals that the procedure wasn’t followed.
5. Failing to Protect Workers During Group Lockout/Tagout Operations
The rules for group lockout/tagout, in OSHA requirement 1910.147(f)(3), sometimes trip up employers.
When more than one person is involved in a lockout/tagout operation, all workers must “affix a personal lockout or tagout device” to the group lockout device.
Failing to make it possible for workers to successfully conduct group lockout/tagout is a violation.
Forklift Lockout/Tagout Checklist
Forklift lockout/tagout procedures can vary depending on the industry or type of equipment. That said, key sections of a forklift lockout/tagout checklist include:
1. Equipment Information
Machine information identifies the following:
- The forklift equipment that will be shut down for a lockout/tagout procedure and record the purpose of the procedure such as servicing, maintenance, or repair.
- The energy sources could cause harm if not isolated. Energy sources include electrical, mechanical, hydraulic, thermal, pneumatic, and chemical sources.
2. Area Inspection
A checklist must identify the area of inspection with the following information:
- Check that the area surrounding the forklift has no items that could pose a risk to the workers during the maintenance/servicing.
- Workers who won’t be working on the maintenance/servicing are clear of the area.
Employers have a role to employees as follows:
- Notify employees and make them aware of their responsibilities during the LOTO procedure and forklift maintenance/servicing.
- Inform workers that the forklift is about to be serviced/maintained and that there will be a lockout/tagout procedure.
4. Preparing Lockout/Tagout Devices
- Ensure that the proper, authorized, forklift-specific LOTO devices are available.
- Identify and record the responsible persons who will apply the devices.
- Ensure they’re trained and have the skills to operate the LOTO devices.
5. Applying Lockout/Tagout Devices
- Identify all sources of energy (primary and possibly secondary) and de-energize them.
- Isolate all sources of power before applying the LOTO devices properly to each energy-isolating device.
- Lock out the forklift machine, verify shut off, and ensure that workers know that it is out of service during lockout/tagout.
6. Removing Lockout/Tagout Devices
- Clear the lockout/tagout area, including the tools, and place back machine guarding equipment.
- Ensure the LOTO devices are removed by the same person who applied them.
- Restore energy to the forklift.
- Inform all the affected workers that the forklift is back in operation.
Common Forklift Lockout/Tagout Questions
What Does Lockout/Tagout Mean?
Lockout Tagout (LOTO) is a safety procedure used to ensure that machinery – including forklifts – is properly shut off and cannot be restarted while maintenance or servicing is being performed.
In the LOTO procedure a lockout device, such as a padlock, secures the energy isolating device to prevent the release of hazardous energy while a tagout device (i.e., a tag) warns employees not to use the equipment.
What is the Difference Between Lockout and Tagout?
Lockout meaning: Lockout involves physically disabling the energy source of a machine like a forklift that prevents energy release.
Tagout meaning: Tagout involves placing a tag, a switch, or another shut-off device on the forklift to indicate that it should not be operated.
Lockout is more secure because it prevents anyone from accidentally turning the machine on while maintenance or servicing is being performed.
What Are the Color Codes for Lockout/Tagout?
Lockout/tagout devices should be easily recognizable and clearly labeled. OSHA’s recommended color codes for lockout/tagout are:
- Red = Stop
- Yellow = Caution
- Orange = Warning
- Fluorescent orange or orange-red = Biological Hazard
- Green = Safety
Do Forklifts Need Lockout/Tagout?
Forklifts require lockout/tagout procedures when under maintenance or servicing. This helps prevent the release of hazardous energy that could cause injury or damage to the equipment.
Where Should Lockout Tags for Forklifts Be Placed?
Lockout tags should be placed on the energy-isolating device(s) that have been locked out so that the equipment controls cannot be activated until the lockout device is removed. That includes the forklift's control levers, steering wheel, or other critical components that are necessary for operation.
They should be clearly visible, easily recognizable, and contain the necessary information, such as the reason for the lockout/tagout, the name of the worker/technician who applied the lock/tag, and the date and time of the lockout/tagout.
What Is the Lockout/Tagout Forklift Battery Procedure?
To lockout/tagout a forklift battery, the following steps should be taken:
- Turn off the forklift: Make sure that the forklift is completely shut down before attempting to disconnect the battery.
- Remove the key: This will prevent the forklift from being started accidentally.
- Disconnect the battery: Disconnect all electrical cables between the battery and the lift truck chassis.
- Lock out the battery: Use a lockout device to prevent the battery from being reconnected. The lockout device key should be kept by the person performing the lockout/tagout.
Watch this YouTube video to see how a forklift battery lockout procedure is done: Brady BatteryBlock Power Connector Lockout | How To Install
Does Removing a Key ‘Lock Out’ a Forklift?
Simply removing the key from a forklift does not lock out the equipment. The forklift will still be connected to the power source, whether it's powered by an LPG tank or a battery. And since the hazardous energy isn't isolated, it can cause an unexpected energy release, risking both operators and technicians to an accident. Proper LOTO procedures require the energy source to be physically disabled by locking and tagging the energy-isolating device(s) to prevent the release of hazardous energy.
When Should You Lock Out a Forklift?
A forklift should be locked out whenever maintenance or servicing is being performed. LOTO procedures should also be followed if a forklift is involved in an accident or if there is a malfunction that requires maintenance.
Can Anyone Perform Lock Out/Tag Out?
Not just anyone can perform the lockout/tagout procedure. OSHA defines the people who can perform lockout/tagout as only authorized employees who have been trained in LOTO procedures and have been designated by their employer to perform lockout/tagout procedures.
Who Is Responsible for Lock Out/Tag Out?
Employers are responsible for ensuring that proper LOTO procedures are established and that employees are trained in those procedures. Employees are responsible for following those procedures and using LOTO devices properly. The key personnel involved in a lockout/tagout are: the safety supervisor, authorized staff, and affected employees
- Safety supervisor. This is the individual responsible for lockout/tagout, and other keys.
- Authorized employees. These are employees who lock or tag equipment so that they can safely perform servicing or maintenance.
- Affected employees. These are employees who operate the forklift on which servicing is performed or who work in the area where the servicing is performed.
Do Your Employees Need Forklift Lockout/Tagout Training?
Employees who operate or service forklifts must receive training in LOTO procedures to ensure that they understand the potential hazards and how to properly lock and tag equipment to prevent those hazards. They should also undergo periodic refresher training to keep up with the lockout/tagout procedures, equipment, and guidelines.
What Is a Lockout/Tagout Violation?
A lockout/tagout violation occurs when an employer fails to establish, implement, or enforce proper LOTO procedures, or when employees do not follow those procedures correctly. This can result in serious injuries, fatalities, or damage to equipment as defined by OSHA. Examples of violations include failure to do the following:
- Provide lockout/tagout training
- Establish a lockout/tagout program
- Identify and isolate all energy sources.
- Drain residual energy.
- Create equipment-specific LOTO procedures.
- Develop and enforce a lockout/tagout policy.
- Conduct periodic LOTO inspections.
What Is the Fine for OSHA Lockout/Tagout Violations?
The fine for OSHA lockout/tagout violations can vary depending on the severity of the violation but can be as high as $134,937 per violation for willful or repeat violations. Employers can also face additional penalties, such as being required to implement corrective actions or being placed on OSHA's Severe Violator Enforcement Program list.
The OSHA lockout/tagout standard garnered 1,440 citations and a total penalty of $9,369,143 between October 2020 and September 2021. This equates to an average lockout/tagout penalty of $6,506 for the period.
That’s it: everything you need to know about forklift lockout/tagout.
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