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Use Both machine safeguarding and lockout tagout to protect employees (LOTO) from becoming caught in or struck by machines. The trick is to know when machine safeguarding doesn’t offer enough protection and lockout tagout is necessary.


OSHA’s machine guarding standard states at 1910.212(a)(1): “Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips, and sparks.”


Machine safeguards include:

Fixed barrier guards permanently attached to the machine

Interlocked barrier guards automatically shut down the machine when opened.

Adjustable barrier guards allow for various types and sizes of stock.

Self-adjusting barrier guards automatically open or close depending on the movement of the stock.

Interlocked gate guards move into place with each machine cycle. The equipment will not operate if they are not in position.

Presence-sensing devices use a light curtain or a radio frequency field that shuts off the machine when the beam is interrupted.

Pullback and restraint devices use cables worn by the operator to keep him from reaching the point of operation.

Safety trip control devices to quickly shut down the machine in case of an emergency.

Two-hand control devices force the operator to keep his hands and arms in a safe area.

Fixed or moveable shields guard operators and other workers from chips, splashes, sprays and sparks.

When using safeguarding devices instead of guards, it’s a good practice to use two or more devices or to supplement the device with a guard.

Additional protection can be provided by:

Awareness barriers that warn employees to stay out of a hazardous area.

Holding or handling tools to help the operator position stock.

Machine location sufficient to prevent access to a machine’s hazardous areas.

Hazard assessment

Periodically assess all of your machines, even those with safeguards installed by the equipment’s manufacturer, to determine if additional safeguards are necessary due to how you use the equipment in your facility.


It’s implied that machine guards protect workers during the equipment’s normal operation. Lockout tagout to protect employees(LOTO) is called for during machine servicing and maintenance.

The LOTO standard states at 1910.147(a) that it “covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees.” The standard “requires employers to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start-up or release of stored energy…”.

The definition of “servicing and/or maintenance” at 1910.147(b) is: “Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment.”

Lockout involves following an established machine-specific procedure to safely shut down a machine, disconnect it from its energy supplies, apply locks to energy control devices, and verify that the machine is shut down. When a machine is locked out, the machine safeguards can be removed and the equipment may be safely disassembled.

Lockout is the preferred method for energy control, but tagout is used if the machine’s energy isolation devices don’t accept a lock. Tagout follows the same procedures, but warning tags are applied instead of locks.

Tagout can also be used if the machine is able to be locked out, but you have to take additional steps to ensure full employee protection.

Minor servicing exception

The LOTO standard includes a provision that brings machine safeguards back into play.

If you’ve determined your operations meet the LOTO standard’s exception to 1910.147(a)(2)(ii) for minor tool changes and adjustments and other minor servicing activities that take place during normal production operations, then effective protection can be provided by machine safeguards. For example, guidance from OSHA indicates that an interlocked barrier guard is an effective control to meet the exception.

However, you must be certain your dependence on the machine safeguards meets OSHA’s expectations for when it’s appropriate to use the exception. OSHA provides guidance in chapter 3 section IV of its directive, CPL 02-00-147, The Control of Hazardous Energy — Enforcement Policy and Inspection Procedures, which includes the following:

“The first set of criteria for determining the application of the minor servicing exception is whether the activity must take place during, and is inherent to, normal production operations. These servicing activities must be necessary to allow production to proceed without interruption. Additionally, the minor servicing activity must be:

“A. Routine: The activity must be performed as part of a regular and prescribed course of procedure and be performed in accordance with established practices.

“B. Repetitive: The activity must be repeated regularly as part of the production process or cycle.

“C. Integral: The activity must be inherent to the production process.

“The employer must also demonstrate that the alternative measures provide effective protection from the hazardous energy. Most importantly, this exception applies only if each and every element of the exception is met.”

Lock Out Tag Out Software Solutions

IMEC’s Lock Out Tag Out Software Solutions allow a LOTO procedure to be defined for each piece of equipment that requires LOTO to be managed within the system. Equipment can be managed from both Mobile and Web App. Isolation points for the each piece of equipment are managed, images associated with both the piece of equipment and isolation points can be annotated to include energy source icon, arrows, sequence etc. Lock Out Tag Out Procedures can be authored using the Mobile App with version control and with an approval workflow. Lock Out Tag Out Procedures are executed using the Mobile App on any Smart Phone or Tablet. Lockout Tagout procedures are initiated by the user identifying the piece of equipment by either scanning QR Code or selecting the piece of equipment from a list. A complete history of completed Lockout Tagout Procedures is recorded. The status for the piece of equipment can be updated after LOTO is complete – Locked / Unlocked. An Audit option on the Mobile App allows a procedure to be reviewed without performing LOTO on the piece of equipment. Corrective Actions can be created for any Non-conformances or changes required recorded during the Procedure Review. Data Analytics within the IMEC Lock Out Tag Out Software Solutions provide machine downtime analysis to aid in operational efficiency and investment decisions.

Asset Inspection Management Software

IMEC’s Asset Inspection Management Software can be used to manage any type of Asset Inspection. This Asset Inspection Management Software solution can create corrective actions as a result of asset inspection failures for inspections.  Corrective actions are allocated to the appropriate persons, with deadlines for resolution which will greatly reduce the time, effort and cost of managing compliance inspections. Implementing an Asset Inspection management software solution, where users using a Mobile App can easily perform inspections in the field aids compliance, reduces risk and standardizes the inspection process within your organization.

IMEC Technologies provides Safety Management Software to increase worker safety and aid compliance. IMEC’s Safety Management Software will manage inspections and audits, provides hazard identificationincident reporting, management of corrective and preventative actions from generation to closure. IMEC provides lock out tag out software solutions that will allow users to create lockout tagout procedures using an intuitive Mobile App and Manage Lockout Tagout Procedures, also the Review and Execution of those Lockout Tagout Procedures using the Mobile App. Annual Lockout Tagout Procedures audits are conducted using a Mobile App. The Mobile Inspection App allow users to perform inspections and audits, for example the system can be used as a Fire Extinguisher Barcode Inspection Software system to manage monthly fire extinguisher inspections and general fire safety inspections and also to record safety observations and manage corrective actions, anywhere and anytime. The solution can be used as a fire extinguisher barcode inspection software system or life safety inspection system to aid compliance in Higher Education, Healthcare, Industrial and Commercial Organizations. Benefits from a Fire Extinguisher Barcode System include the elimination of paperwork and reducing the burden of compliance with regulations such as NFPA, The Joint Commission. The Mobile App can also be used as a Fire Door Inspection App and with the flexible Forms Manager the solution can be used as a Fire Door Inspection Software Solution also. Fire Door Inspection Software is used is large facilities with large quantities of Fire Doors like Hospitals, Universities and also Cruise Ships. The Incident Reporting App allows users to easily and quickly report incidents, hazards and near-misses, these are then sent to the appropriate people for action and are managed to closure.  Web Apps provide features such as, setup, management, scheduling tools, analysis, reporting and dashboards etc with the ability to report incidents to government bodies such as OSHA and RIDDORHazMat T&T is a hazardous waste management software solution designed for Environmental Service Companies and companies who generate a large quantity of hazardous waste. The solution tracks hazardous waste from cradle to grave aiding compliance, providing accurate waste inventory, increasing waste handling efficiency, reducing risk and also helps manage waste costs. HazMat T&T Hazardous Waste Management Software can be deployed in a number of deployment scenarios, from Large Hazardous Waste Generators, tracking their hazardous waste at their site to Environmental Service and Waste Management Companies using it track and manage hazardous waste at transfer and disposal sites. For more information visit our website