Lockout Tagout Procedure Guide for Manufacturers

Lockout tagout failures are the leading cause of machine-related fatalities and amputations in Australian manufacturing. The failure pattern is remarkably consistent across incidents. A worker needs to clean, maintain, adjust, or clear a jam on a machine. Time pressure drives a decision to skip the isolation procedure or to use an incomplete isolation that does not address all energy sources. The machine starts unexpectedly — either because another worker activates it, a stored energy source releases, or an automated cycle resumes — and the worker in the danger zone is killed or seriously injured. The WHS Regulation 2025 requires PCBUs to ensure that plant is isolated from all energy sources and that the isolation is verified before any person enters a danger zone. After Section 26A commences in July 2026, the Managing Risks of Plant Code of Practice becomes legally binding, making the detailed LOTO requirements in the code enforceable as standalone obligations. Manufacturers that do not have documented, machine-specific LOTO procedures with trained and authorised personnel are operating outside the law.

A compliant lockout tagout procedure follows eight sequential steps that must be completed in order for every isolation. Step one is notification — inform all affected workers that the machine will be shut down and locked out. Step two is shutdown — stop the machine using the normal operating controls. Step three is isolation — operate every energy isolation device to disconnect the machine from all energy sources including electrical, pneumatic, hydraulic, gravitational, and thermal. Step four is lockout — apply a personal lock and tag to every energy isolation device. Each worker in the danger zone must apply their own lock. Step five is stored energy dissipation — release, disconnect, restrain, or otherwise render safe all stored or residual energy including capacitors, springs, compressed air, hydraulic accumulators, and elevated components. Step six is verification — attempt to start the machine using the normal operating controls to verify that all energy sources are effectively isolated. Step seven is the work activity — perform the cleaning, maintenance, or repair work. Step eight is removal — remove tools, replace guards, verify all workers are clear, remove locks and tags in reverse order, and restore energy in a controlled manner.

Generic LOTO procedures are insufficient for manufacturing because every machine has a unique combination of energy sources and isolation points. A CNC machining centre has electrical supply, pneumatic clamping, hydraulic tool change, coolant pump, and spindle inertia. A hydraulic press has electrical supply, hydraulic power unit, hydraulic accumulator stored energy, and gravitational energy from the raised ram. A conveyor system has electrical supply, multiple drive motors, and gravitational energy from elevated loads. Each machine requires a documented procedure that identifies every energy source, the location and type of every isolation device, the method of stored energy dissipation for each energy type, and the verification method for confirming zero energy state. These procedures should be developed by a competent person who physically traces every energy source on the machine, documented with diagrams and photographs showing isolation point locations, reviewed and approved by maintenance supervision, and made available at each machine for reference during isolation. The procedure development process is a one-time investment that saves lives.

When multiple workers need to work on the same machine simultaneously, a multi-lock hasp system ensures that the machine cannot be restarted until every worker has removed their personal lock. Each hasp accommodates multiple padlocks, and the isolation device cannot be operated until all locks are removed. Every worker in the danger zone must apply their own uniquely keyed lock — sharing locks between workers defeats the purpose of personal lockout. For complex isolations involving multiple machines or shared energy systems, a group lockout procedure uses a lockbox system where all isolation keys are placed in a locked box. Each worker applies their personal lock to the lockbox. The isolation keys cannot be retrieved to remove lockout devices until every worker has removed their lock from the lockbox. Group lockout procedures require an authorised person to coordinate the isolation, verify zero energy, and manage the lockbox. This role must be formally assigned, trained, and documented. All multi-lock and group lockout equipment must be standardised across the facility so that workers are familiar with the system regardless of which machine they are working on.

Every worker who performs or is affected by lockout tagout must be trained in the procedure. Training should be role-specific. Authorised workers who apply locks must understand the full eight-step procedure, energy source identification, stored energy dissipation, and verification methods for every machine they work on. Affected workers who operate machines that may be locked out must understand the meaning of locks and tags and the prohibition against removing them. Training must include practical demonstration and competency assessment, not just classroom instruction. Annual refresher training reinforces correct procedure and addresses any changes to machines or isolation points. LOTO procedure audits should be conducted at least annually by observing actual isolations in progress and comparing the worker's actions against the documented procedure. Any deviation between the documented procedure and actual practice must be investigated and corrected. Common audit findings include workers skipping the verification step, incomplete stored energy dissipation, missing locks on shared energy isolation points, and outdated procedures that do not reflect machine modifications. EHS Atlas tracks LOTO training records, audit schedules, and corrective actions with automated reminders for all due dates.