Table of Contents
- Purpose & Scope
- Legal Requirements
- Types of Hazardous Energy
- Lockout Procedure Steps
- Tagout — When Lockout Is Not Possible
- Group Lockout Procedures
- Lock Removal & Re-Energization
- HCMI LOTO Policy & Lock Assignment
- LOTO Verification Checklist
1. Purpose & Scope
Lockout/tagout (LOTO) procedures protect workers from the unexpected release of hazardous energy during maintenance, repair, installation, or servicing of equipment and systems. On HCMI church construction projects, LOTO is critical during electrical rough-in and panel work, mechanical system installation, elevator installation, HVAC commissioning, and any work on equipment with stored energy.
This training applies to all HCMI employees and sub-trades who perform work on or near equipment, machinery, electrical systems, piping systems, or any other source of hazardous energy. Every worker must understand LOTO procedures whether they are performing the lockout themselves or working in an area where LOTO is in effect.
2. Legal Requirements
- O. Reg. 213/91 s.190 (Construction Projects): Requires that before work begins on electrical equipment or an electrical installation, all hazardous sources of electrical supply be disconnected, locked out, and tagged. Workers must verify de-energization by testing.
- OHSA s.25(1)(d): Employers must ensure that equipment, materials, and protective devices required by the regulations are provided, maintained, and used as prescribed.
- OHSA s.25(2)(h): General duty to take every precaution reasonable in the circumstances for worker protection.
- O. Reg. 851/90 s.75-76 (Industrial Establishments): While primarily applicable to industrial settings, these sections provide additional guidance on energy isolation that HCMI applies as best practice on all projects.
- CSA Z460 — Control of Hazardous Energy: The Canadian standard for lockout/tagout programs, referenced as the HCMI program framework.
Regulatory Note: Under O. Reg. 213/91 s.190, an electrical installation must be disconnected from the power supply and the disconnecting means must be locked and tagged before any worker performs work on the installation. Violation of this requirement can result in a stop-work order, fines, and criminal charges in the event of a serious injury.
3. Types of Hazardous Energy
LOTO applies to all forms of hazardous energy, not just electricity. Workers must identify and control every energy source before beginning work:
Electrical Energy
The most common hazard on HCMI projects. Includes power distribution panels, temporary construction power, permanent building electrical systems under installation, and battery-powered systems. Even after disconnection, capacitors may retain a dangerous charge.
Mechanical Energy
Moving parts such as motors, fans, pumps, compressors, conveyors, and elevators. Mechanical energy can also be stored in springs, flywheels, or tensioned cables. Equipment that is "off" may still have stored mechanical energy that can cause movement.
Hydraulic Energy
Pressurized fluid in hydraulic systems found in construction equipment, lifts, doors, and building systems. Hydraulic pressure can remain in lines and cylinders even after the pump is shut off. Residual pressure must be bled off before work begins.
Pneumatic Energy
Compressed air systems used for power tools, HVAC controls, and building automation. Like hydraulic systems, pneumatic lines can retain pressure after the compressor is shut down. Bleed air lines and verify zero pressure before working on pneumatic components.
Thermal Energy
Hot surfaces, steam, hot water, and heated fluids in boilers, heating systems, and process piping. On church projects, this includes hydronic heating systems, domestic hot water systems, and temporary heating equipment. Allow adequate cool-down time and verify temperatures before working on thermal systems.
Chemical Energy
Stored chemical energy in fuels, solvents, adhesives, and reactive materials. This includes propane systems, natural gas piping, and chemical storage systems. Isolate chemical supply lines and verify that residual chemicals have been purged before maintenance.
Gravitational Energy
Suspended loads, elevated components, and items that could fall if a support mechanism is released. This includes suspended ceiling systems, elevator counterweights, overhead doors, and any component held in place by a mechanical device. Block or crib suspended components before removing their support mechanism.
Critical Point: A single piece of equipment can involve multiple types of hazardous energy. For example, an elevator system involves electrical (motor and controls), mechanical (cables, sheaves, brake), hydraulic (in hydraulic elevators), and gravitational (car and counterweight) energy. All sources must be identified and controlled.
4. Lockout Procedure Steps
Follow these steps in order for every lockout operation:
Step 1 — Preparation
- Identify the equipment or system to be locked out.
- Identify all sources of hazardous energy associated with the equipment.
- Identify all energy isolation devices (disconnects, valves, breakers, blocks).
- Notify all affected workers that a lockout is about to take place and why.
- Gather the required lockout hardware: personal padlock(s), hasp(s), lockout tags, and any specialized isolation devices.
Step 2 — Shutdown
- Shut down the equipment using the normal operating controls (stop button, switch, valve).
- Allow all moving parts to come to a complete stop.
- Verify that all operators and workers are clear of the equipment.
Step 3 — Isolation
- Operate the energy isolation devices to disconnect the equipment from all energy sources.
- Open electrical disconnects, close and blank valves, block mechanical components, and relieve stored energy (bleed hydraulic/pneumatic lines, discharge capacitors, block elevated components).
Step 4 — Lockout & Tag
- Apply your personal padlock to each energy isolation device. Use a hasp (multi-lock device) if multiple workers need to lock out the same isolation point.
- Attach a lockout tag to each lock identifying: your name, the date and time of lockout, the reason for lockout, and your contact information.
- Each worker who will be exposed to the hazard applies their own lock — one person, one lock. No one else may remove your lock.
Step 5 — Verify De-Energization
- Attempt to start the equipment using the normal operating controls to confirm it cannot be energized. Return controls to the "off" position after testing.
- Use a voltage tester, pressure gauge, or other appropriate instrument to verify zero energy state.
- Check for residual or stored energy (capacitors, springs, elevated components, pressurized lines). Dissipate or block any stored energy found.
Never Skip Verification: The verification step is the most critical part of the lockout procedure. Workers have been killed by equipment that was thought to be locked out but was connected to an unidentified energy source. Always test — never assume.
Step 6 — Perform the Work
- Proceed with the maintenance, repair, or installation work only after successful verification of the zero energy state.
- If work extends beyond a single shift, the incoming worker must apply their own lock before the outgoing worker removes theirs.
5. Tagout — When Lockout Is Not Possible
Tagout alone (without a lock) is permitted only when an energy isolation device is not capable of being locked out and only as a temporary measure until the device can be modified to accept a lock. When tagout alone is used:
- The tag must be attached directly to the energy isolation device.
- The tag must clearly state "Do Not Operate" and include the worker's name, date, and reason.
- Additional safety measures must be implemented: removal of a fuse, blocking of a valve, physical disconnection of a coupling, or continuous monitoring by a dedicated observer.
- All affected workers must be notified that tagout (rather than lockout) is in effect and understand the heightened risk.
- The HCMI site superintendent must approve any tagout-only procedure in writing before work begins.
HCMI Policy: Tagout alone is considered a last resort on HCMI projects. If an energy isolation device cannot accept a lock, the site superintendent must explore all alternatives (portable lockout devices, valve lockout devices, breaker lock clamps) before approving tagout only.
6. Group Lockout Procedures
When multiple workers from different trades need to work on the same equipment (common during mechanical and electrical commissioning on church projects), a group lockout procedure is used:
- Authorized Person: A single authorized person (typically the HCMI site superintendent or designated competent person) performs the primary lockout on all energy isolation devices.
- Lockout Box: The key to the primary lock is placed in a group lockout box (key box) on-site.
- Individual Locks: Each worker who will be exposed to the hazard applies their personal lock to the group lockout box. No one can access the primary key until all individual locks are removed.
- Shift Changes: When a worker completes their work or leaves for the day, they remove only their personal lock. The equipment remains locked out until the last lock is removed.
- Final Removal: Only after all individual locks are removed can the authorized person retrieve the primary key and remove the primary lock from the energy isolation devices.
7. Lock Removal & Re-Energization
Removing a lockout and re-energizing equipment is as critical as the lockout itself. Follow these steps:
- Inspect the work area to ensure all tools, materials, and temporary items are removed from the equipment.
- Verify all guards, covers, and safety devices have been reinstalled.
- Confirm all workers are clear of the equipment and aware that it will be re-energized.
- Remove your personal lock from the isolation device. Only you may remove your lock.
- Re-energize the equipment in a controlled manner, verifying proper operation at each step.
- Notify all affected workers that the lockout has been removed and the equipment is live.
Emergency Lock Removal
If a worker leaves the site without removing their lock, the following procedure applies under HCMI policy:
- Every reasonable effort must be made to contact the worker and have them return to remove the lock.
- If the worker cannot be reached, only the HCMI site superintendent may authorize lock removal.
- Before removal, the superintendent must verify that the worker is not on-site and is not in danger from re-energization.
- The lock is cut by the superintendent (or designate), and the removal is documented including the date, time, reason, and names of those present.
- The worker is notified as soon as possible that their lock was removed and the reason for removal.
8. HCMI LOTO Policy & Lock Assignment
- Personal Locks: Every HCMI employee who may perform or be affected by lockout is issued a personal padlock set (red lock body with a unique key). Locks are engraved with the employee's name or employee number. Each worker is responsible for their lock and key — locks must never be shared or borrowed.
- Lock Issuance: Locks are issued by the HCMI Safety Coordinator during orientation. A record of lock serial numbers and assignments is maintained at the HCMI head office.
- Training Requirement: All workers must complete LOTO training before being issued a lock. Training covers this procedure and includes hands-on practice with lockout hardware. Refresher training is required annually.
- Sub-Trade LOTO: Sub-trades working on HCMI projects must demonstrate that they have their own LOTO program and that their workers are trained and equipped with personal locks. The HCMI site superintendent verifies sub-trade LOTO compliance before work begins.
- Multi-Trade Coordination: When multiple trades need to lock out the same system, the HCMI group lockout procedure (Section 6 above) must be used. The HCMI site superintendent serves as the authorized person for group lockouts.
- Documentation: All lockout events on HCMI projects must be documented on the HCMI LOTO Log, which is maintained in the site trailer. The log records: equipment locked out, energy sources isolated, workers applying locks, and time of lockout and restoration.
- Annual Audit: The HCMI Safety Coordinator audits LOTO procedures on active projects at least once per year to verify compliance and identify opportunities for improvement.
9. LOTO Verification Checklist
Complete for every lockout event:
- All energy sources identified for the equipment or system
- All affected workers notified of the lockout
- Equipment shut down using normal operating controls
- All energy isolation devices operated (disconnects open, valves closed, etc.)
- Stored energy dissipated or blocked (capacitors discharged, springs released, elevated components blocked, pressure bled)
- Personal padlock applied to each energy isolation device
- Lockout tag attached with name, date, time, and reason
- De-energization verified by attempting to start equipment
- Zero energy state confirmed with testing instrument (voltmeter, pressure gauge)
- LOTO Log entry completed in the site trailer
- Work area clear before re-energization
- All guards and safety devices reinstalled before re-energization
- All workers clear and notified before re-energization
- Personal lock removed only by the worker who applied it
Remember: Lockout/tagout saves lives. Never work on energized equipment. Never remove someone else's lock. Never bypass a lockout. If you are unsure about any part of the LOTO procedure, stop and ask your supervisor before proceeding.
