Paper to Production: Why "Compliant" LOTO Fails In The Field

This month we’re tackling one of the most cited OSHA topics out there — Lockout/Tagout (LOTO). If your company has a program that checks all of the audit boxes, but your employees are still having injuries, this episode explains why.

⚙️ Top 3 LOTO Problems We’re Seeing in the Field

1️⃣ Bad or outdated templates.
If your LOTO template or format is wrong, every single lockout procedure built from it can have problems. 

2️⃣ Verification is clear as mud
“Verify” doesn’t mean much if no one knows how, where, or who does it. Joint verification? Remote lockout? Elevated disconnects? If your verification step creates more hazards, your program gaps.

3️⃣ Confusion about when LOTO actually applies.
Some equipment can fall into gray zones where employees “sort of” lock out or skip steps altogether. That’s how culture gaps start. Its important to align  your training, your task steps, and your documentation, with a focus on risk reduction, not perceived "faster" ways.

💡 Bonus : Validate Procedures During Retraining

Your annual lockout/tagout retraining is one of the best times to validate your procedures. Walk the floor with your maintenance team, observe how employees actually perform the work, and capture those missed hazards like residual pressure, gravity, or access height risks.

🧰 Why It Matters

You can have a binder full of lockout procedures and still have injuries.
 A strong LOTO program isn’t just compliance — it has to be customized for your facility.  

🧤 Support the Channel

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 ✔️ Like, Share, and Subscribe to help this content reach more safety professionals.
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📈 Keywords for SEO

Lockout Tagout Safety, LOTO Training, OSHA Compliance, Machine Guarding, Energy Isolation, Verification Step, Safety Culture, Manufacturing Safety, Industrial Safety, Food Plant Safety, Safety Leadership, Maintenance Safety, Allen Safety, Safety Program Audit, Hazard Control, Employee Safety, Safety Podcast, Allen Safety Coaching, Confined Space Safety, OSHA 1910.147

🔖 Hashtags

#LockoutTagout #LOTO #SafetyTraining #WorkplaceSafety #AllenSafety #SafetyCulture #OSHACompliance #IndustrialSafety #ManufacturingSafety #SafetyPodcast #EnergyIsolation #HazardControl



This video is intended for educational purposes.  Solutions offered are not designed to take the place of an attorney or medical professional, and should not be taken as legal or medical advice.  It is recommended that viewers consult a safety consultant, medical provider or an occupational safety legal team as applicable to help navigate their specific circumstances.  

For educational purposes, videos may show the inside of manufacturing facilities, including meat and poultry production facilities, commercial farming, feed milling, and petrochemical facilities.  Images shown may depict individual lines and show trained employees working in their daily jobs, however these visuals may not be suitable for all audiences.  Specific job tasks shown are being completed by trained professionals, and should not be attempted without proper training and equipment under the supervision of a professional.  Viewer discretion is advised.

Episode Transcript

SPEAKER_00 (00:00):
Welcome back to the channel.
This month we're going to becovering lockout tag out.
It's one of the most frequentlycited subjects.
We've done a couple of episodeson machine guarding in the past,
but it's been a minute.
It's been a while.
It's been a minute since we'vetalked about lockout.
So we just figured, you knowwhat?
We will give you our top threethings in regards to lockout
that we're seeing right now.

(00:21):
Um, so here we go.

SPEAKER_01 (00:28):
Welcome back, everybody.

SPEAKER_00 (00:30):
Welcome back, happy tag out.

SPEAKER_01 (00:32):
What is this?
Halloween?

SPEAKER_00 (00:33):
Happy October.
We're in the Burr months.

SPEAKER_01 (00:35):
Oh, there we go.

SPEAKER_00 (00:36):
Happy, happy October, happy fall.
So that's my orange.

SPEAKER_01 (00:41):
Anyway, back to lockout tag.
So procedures.
We're out of here.
That's the one everybody wantsto know.
Okay.
I need a lockout procedure for apiece of equipment.
I come to you, I say, hey, um, Ineed one.
You're gonna go to share driveand whatever.

SPEAKER_00 (00:57):
I'm gonna hope that we have one.
And inevitably, when I pull itup, we either A, don't have it.
Which is weird.
Because we we have a masterinventory and we have one for
everything except inevitably theone that you need right now.

SPEAKER_01 (01:10):
Especially if it's an audit.
If it's an audit, it's the exactone.

SPEAKER_00 (01:13):
We're probably in the yeah, we're probably in an
audit.
And then it's gonna be on someweird, really dated template.
Then I'm like, where did thiseven come from?
We moved all of this stuff oversix months ago forever to this
new format that's so muchbetter.
Like, where why does it looklike this?
And that's usually the cyclethat starts.
Now I'm not saying that thathappens every time, I'm just

(01:33):
saying we've we've experiencedthat firsthand, that cycle many
times.

SPEAKER_01 (01:37):
So that's the start of your top three.
So there you go.
The procedure itself.

SPEAKER_00 (01:41):
Yeah, is it the template?

SPEAKER_01 (01:43):
The template, yes.

SPEAKER_00 (01:44):
What is on it?
Because this is one of thosesubjects that if the template's
wrong, your 300 lockoutprocedures are irrelevant to a
certain degree on that specificsubject.
Then they're completely likeit's the multiplier is so huge,
that's gotta be right.
The template's gonna be right.
Yes, we do.

SPEAKER_01 (02:05):
So it has to be correct.

SPEAKER_00 (02:06):
I'm sorry, I'm having a tickle.

SPEAKER_01 (02:08):
Yeah, so if the format right there with that new
cup, like what's going on there?

SPEAKER_00 (02:12):
All right, so um brief interlude, brief
interlude.
Um, part of what I've beenspending my time doing is safety
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We don't have any sponsors.
We wanted some fun stuff towear, fun stuff to have.
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(02:35):
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(02:55):
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Something kind of fun.
There you go.

SPEAKER_01 (03:14):
All right, back to logout.
So now we have the procedure,the formatting, and then it's
gonna say things on there likeverify.
Yep, and that is number two.

SPEAKER_00 (03:23):
With what?

SPEAKER_01 (03:24):
Right, so you're using the procedure, and now it
ties in number two because theverify itself could be unlimited
choices because uh one procedureit may be remote, another
procedure it may be two or threepieces.
That one line item can just takeoff on you.

SPEAKER_00 (03:41):
My brain's going in like 15 different directions
because it feels like becausethere's so there's so many
variations of the word verifythat we've seen, and it's kind
of like oh okay, it'll just saythe word verify, and you're
like, who?
How doing what?
Where?
How many people?

(04:02):
Because there's this thingfloating around that's called
joint verification, and that's athing for some locations, and
they are okay with that, andsome are not.

SPEAKER_01 (04:11):
Verify could be the disconnect is 10 feet up air,
but the verify is somewherecompletely different.
So now you make them do elevatorwork as a hand.

SPEAKER_00 (04:18):
Or there's no way, really, or yeah, or there's no
way there's no computer system,you can't do that.
There's no yeah, there's no safeway.
The verification puts them atmore risk than we really want
them to, and so they don't feelcomfortable doing that process,
so they just don't verify.
And arguably, verify andverification is the most
critical part of lockout becausethere's always I am new, stuff

(04:42):
was mislabeled, I was tired ofputting on the weekend, put it
on the wrong, you know,disconnect, wrong, right, wrong
ball valve.
I mean, there's all thesethings, or there's just residual
and we didn't bleed out thelines.

SPEAKER_01 (04:53):
I mean, that we've seen airlines 30 feet long, and
people say, Oh, it takes liketwo seconds, you stand there, it
takes it goes forever.

SPEAKER_00 (05:00):
You're just standing there waiting and waiting.
They never did it for thatlength of time.
They're like, Shh, got it, andthen we move on.

SPEAKER_01 (05:07):
Absolutely.
So you gotta look at your soyou've got the lockout, the
procedure that could be ahazard.

SPEAKER_00 (05:12):
Yep.

SPEAKER_01 (05:13):
Then you got I gotta verify, which now that could be
a hazard.
And now I go back to now I'm whosays it's even right.
So it could be the person thatsigned it, verified whatever,
may not even know if it's rightor not.

SPEAKER_00 (05:26):
It it's it goes back to who's writing it, right?
So we have, and this is this isnot a plug, it's just a reality.
We have a app that I developedwith the help of some IT people
that we created to speed up theprocess of writing lockout
procedures, and because we wereable to accomplish that, we were
able to cut the time it toalmost a third of what it would

(05:50):
take.
And so and they're picturedriven, they're amazing.
And we had several companiesapproach us that wanted to
either have a subscription tothis or like have some kind of
service or buy it, and I won'tdo it.
And the reason why I won't sellit because that's because it
matters who's doing it, if theydo it and write the the

(06:10):
procedure, but it's wrong, itstill doesn't matter.
They don't understand theprocedure, they don't understand
the equipment, they don't knowthe mechanics, who cares?
So in our company's still wrong.

SPEAKER_01 (06:19):
So in our company, we even select who goes to that
location to write those like ourprocedures.

SPEAKER_00 (06:23):
Based on who's the expert.
I've got a cattle expert, a caseready expert, mill expert.
Yep.
We have someone that covers allof those things that understands
the mechanics of the equipmentand also the weird stuff, and
then when where they can likeoverride stuff, they know all of
those weird things, and so we doselect that and then we still

(06:43):
validate with the people andwork with them maintenance for
that area, yeah, uh, wastewaterfor that area, wherever their
department experts are.

SPEAKER_01 (06:51):
Because, like, for example, we we worked with the
manufacturer, built some of therobots for years.
Yeah, and as we did that, wewould come back and they would
say, Oh, lockout, tag out, youdo this.
But we know there was more toit.
If you don't have thatknowledge, and or if you don't
ask that maintenance person setsup the equipment, finds out you
don't always lock it out the wayduring the setup, do you have to
use air to set it up?
Oh, you can have confusing partsof the lockout procedure.

SPEAKER_00 (07:14):
Yeah, so that is really part of the deal, too, is
is it's not always the safetyperson that is writing or
reviewing these.
Now they're a stakeholder forsure.
They need to make sure that theright components are in the
template.
Right.
But they may not always knowsanitation has to do XYZ or
maintenance to troubleshoot thisequipment, to unjam it during

(07:36):
production with film, to dothings like setup.
We have to sometimes have powerto certain things, and we use
other means of guarding bythings like distance, but we
still have to have power to someof it.
And so we have different safetythings that we put into place.
But if they're not there to seethat, or they don't know that
room, that department, thatequipment, or they haven't been

(07:59):
at the location that long,that's getting missed.
And that's where we're seeingsome of these injuries still
because it's not being capturedin the procedure that we're
training everyone on and sayingfollow this, but then no one's
following it because well, whatwe do is really safer, but it's
never been captured.
And so now there's this weirdthing of we don't follow the
procedure.
Well, now that's weirdculturally, you know, from a

(08:21):
safety culture standpoint oflike sometimes we follow the
procedure and sometimes we justflat out ignore it, you know.
Like that's so it gets reallyweird.

SPEAKER_01 (08:28):
And then you also get um probably my my last one
is when does it apply when yeahyou take a you take a dump and
you got guards inside of it,yep.
So so the cable that runs infront of it.

SPEAKER_00 (08:42):
So just I'll throw up a picture, but a combo dump
or so lifts and then dumps intoa blender.

SPEAKER_01 (08:47):
There's so many variations when you have to lock
that out, yeah, because theyhaven't decided when you break
the plane.

SPEAKER_00 (08:54):
Yeah, what is the plane and what's the guarding
look like on the outside?
Are we still doing a chain orhave we beefed it up a little
bit?

SPEAKER_01 (09:01):
You'll get different pieces of equipment.
People say, Oh, I didn't reallybreak the plane, or I don't have
to lock it out for that task, orI'm only taking a sample, and
you're like, we use a tool so wenever do, or we never use a tool
and we go in with our wholebody.
Yeah, there's all of that ispart of the process.

SPEAKER_00 (09:15):
Yeah, so part of it is breaking it down by the
employee behavior.
So some of that can obviously bechanged by training and then
managing the behavior from thenout after that training happens.
So it's a culture issue, right?
Yep, we've got the theverification piece of how, when,
where, who, what, jointverification, can we or not?

(09:37):
Am I doing it on a radio?
Can I actually push the buttonnext to it?
Or did I take the PLC computerscreen down?
Yeah, because do I have to do itin a control room?
Well, I'll just cut you rightoff.
Don't worry, I get excited.

SPEAKER_01 (09:49):
Because the new computer systems won't allow you
to lock it out sometimes withoutthe computer being down forever.

SPEAKER_00 (09:57):
Well, you d here's my theory on this.
It's because it costs more moneyto separate that out and wire it
apart from everything else.
Like a glue pot.
So if we didn't specifically askfor that to be done and
understand that's going to be anadded cost, that may that
probably wasn't done, you know.

SPEAKER_01 (10:17):
So, and then the final part is that final final.
Yeah, that's right.

SPEAKER_00 (10:20):
Is this the bonus?

SPEAKER_01 (10:22):
I guess call it bonus, is that during the year
when you retrain your employeesand you're validating lockout
tag out, that is the best timeto validate the lockout tag out
procedure.
100%.
Because if you're going throughit, it's line four, and you're
like, that's weird, we don't doit there.
That's when you got to capturethat data.
If you don't, if you're kind oflike, oh, I got my employee
trained, and you don't reallypush that number four was off,

(10:44):
you can cycle the next person,an expert, and you miss it.

SPEAKER_00 (10:47):
But only, only caveat to that is if you have
someone who's an expert that atthat department, right training
on equipment that's in thatdepartment, right?
That's not a single sourceconveyor.

SPEAKER_01 (10:58):
Right.
So theoretically, you don't wantto train on the least items of
disconnect the person's workingon.

SPEAKER_00 (11:04):
And everyone gets trained on the same item.

SPEAKER_01 (11:06):
Everybody gets trained on conveyor number three
in the front office.
No, what you want is you're youdo a task, you have five things
you have to lock out, and that'sthe worst one you have during
the air, you that's the one youshould be trained on.

SPEAKER_00 (11:17):
Yeah.

SPEAKER_01 (11:18):
Because you need to understand the hydraulic, the
pneumatics, and how everything,gravity, how everything's gonna
work for that.
You take a mixer blender andlift up the lid.
If you don't lift it up acertain way and put the pin in a
certain way, you have to worryabout the lid coming down.

SPEAKER_00 (11:30):
So it's it's yeah, well, and it's under it's
understanding that the lidcloses and you have to even have
that included in that.
I mean, like most people justdon't have that in their
understanding.

SPEAKER_01 (11:39):
It doesn't talk about you're talking about the
elevator, it don't even talkabout how far you have to climb
a ladder to lock something up.
That's a risk.
In closing, you want to look atyour procedure, take it out
there during the differenttimes, basically, see how they
do the task, and then look forthose random safety risks that
are created because of theprocedure, make sure you capture
that as well.

SPEAKER_00 (11:58):
Different times of day, grab the look the the
department expert that reallyknows, knows how and when we
just shove this piece of woodfrom a pallet or this cardboard
from a combo in here.
We can override the safety andthen like unjam stuff real
quick.
Yeah.
You want those people that havebeen there for a minute and know
what's going on.

(12:18):
So, yes, this is a safetyfunction.
Yes, it feels as the safetyperson very overwhelming
sometimes to realize hey, I'vegot 300 lockout procedures.

SPEAKER_01 (12:27):
And they take about 30 minutes or more each to write
them from scratch.

SPEAKER_00 (12:32):
But also, if you're going to go out and physically
validate, that takes time.
That takes forever.
But also, most safety peoplearen't mechanics.
So that's why I want toencourage you grab a mechanic
with you.
Um, great, great cross-trainingoption right there.
I mean, great continuededucation that's a hundred
percent relevant.
You didn't have to go anywhereor leave and and you're getting

(12:53):
an awesome education, it's gonnabetter you as a safety person.
But also you have confidencethat it's correct.
So it's not we have a sheet ofpaper and they still got hurt
because that's what we see alot.
We have we have the procedureand they still got hurt.
So yeah, that's it.
That's our opinion.
Take it how you want.
Take what you can from this.

(13:13):
And if it was helpful orbeneficial at all to you, please
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Um, this is a community servicefor Joe and I doing this.
Um, the only intent that we havein doing these is we want to get
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Um, those who maybe don't havethe information.
We recognize there are a lot ofpeople that are walking into
safety that maybe don't haveformalized training in it.

(13:35):
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(13:55):
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