Initial Creation of Written Procedures
An EI safety professional will examine every piece of equipment and system within a facility, then identify and inventory all equipment and systems that are determined to need a written procedure under OSHA’s lockout standard. The professional will identify and document energy sources and potential for stored/residual energy. Next they will determine the most effective way and the appropriate sequence to lockout the equipment/system. Photographs are collected of all energy sources and lock out points. Lastly, machine specific electronic LOTO procedures are created in a mutually agreed upon format, usually an Excel document, PDF, or the use of a company’s existing commercial software.

In addition to sequenced steps and photographs of the lockout points, each procedure can include supporting documentation, such as equipment hazards, warnings, actions required prior to lockout, and references to related information. Hard copy and electronic versions of the lockout procedures can be created and edited as procedures are validated by the company’s staff.

Review of Existing Procedures
EI safety professionals can either review all the existing written procedures for a company or perform OSHA’s mandated annual audit of each written procedure. During standard review, all parts of the procedure such as photos, sequence of steps, accuracy of energy control measures, etc. will be reviewed for accuracy. Performing the OSHA mandated annual review includes all the steps in a standard review plus creating documentation of the review of each procedure which is necessary to meet the OSHA regulatory requirement.

Employee Training
EI can deliver on-site lockout training for a company’s Authorized Personnel and Affected Personnel. Affected personnel training is for all employees who work around equipment that may be lockout, but will not perform the physical lockout. Authorized Personnel initial training and periodic retraining is mandated by OSHA for all employees who have been authorized by an employer to perform lockouts on equipment.

Other Support
EI evaluates and inventories a facility’s lockout devices (locks, valve covers, chains, etc.) to ensure the appropriate equipment is on hand. EI can also create and attach identification labels/tags for energy sources, such as valves, breakers, etc., and for each lockout point. EI routinely prints, laminates, and posts the individual written procedures for clients to create a safer work environment and speed compliance.


The Safety Manager at Pactiv Evergeeen was very impressed with the LOTO procedure writing service offered by Grainger through The EI Group. Approximately 20 to 40 procedures are written a month, saving the Safety Manager a lot of time. Since this service has been offered, they have discovered a need for other service opportunities such as an Arc Flash assessment that they are looking to budget for H-2 of this year.

Will Gibson

W.W. Grainger, Inc.

Should You Lockout/Tagout Electrical Cords?

Should You Lockout/Tagout Electrical Cords?

No matter how frequently the control of hazardous energy is featured on OSHA’s annual list of the Top 10 Most Cited Violations (#6 for 2022), lockout/tagout fails to receive the attention it deserves at many manufacturing facilities and remains a black eye for safety programs across the nation.  Because LOTO procedures take time, the process impacts production and ultimately undermines the bottom line.