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Authorized vs affected employee: LOTO roles and training under OSHA 1910.147

For training, the lockout/tagout standard covers three groups of employees, and each group gets different training. Getting the groups right is the first step of a training program that stands up at an inspection. Here is what 29 CFR 1910.147 says about each.

The three groups

Authorized employeeAffected employeeOther employees
WhoA person who locks out or tags out machines or equipment in order to perform servicing or maintenance on them.An employee whose job requires them to operate or use a machine on which servicing or maintenance is being performed under lockout or tagout, or to work in an area where it is being performed.Employees whose work operations are or may be in an area where energy control procedures may be used.
Typical examples (not defined by the standard)Maintenance technicians, electricians, millwrights, setup technicians who service the machineMachine operators, line workers in the areaMaterial handlers, supervisors from other areas, office staff whose work takes them into the area
TrainingRecognition of applicable hazardous energy sources, the type and magnitude of energy available in the workplace, and the methods and means for energy isolation and control; plus the limitations of tags where tagout is used ((c)(7)(ii))The purpose and use of the energy control procedureInstruction about the procedure, and about the prohibition on attempting to restart or re-energize machines that are locked out or tagged out
Source(b); (c)(7)(i)(A)(b); (c)(7)(i)(B)(c)(7)(i)(C)

The definition adds one important rule: an affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered by the standard ((b)). An operator who clears jams or changes tooling in a way the standard covers is doing servicing, and needs authorized-employee training for that task. The exception is minor servicing during normal production that is routine, repetitive and integral to using the equipment, where alternative measures give effective protection (note to (a)(2)(ii)).

What only authorized employees may do

What affected employees are owed

Affected employees shall be notified by the employer or authorized employee of the application and removal of lockout or tagout devices: before the controls are applied, and after they are removed ((c)(9)). Where tagout is used, the annual periodic inspection review includes affected employees too ((c)(6)(i)(D)), and they are trained in the limitations of tags ((c)(7)(ii)).

When retraining is required

Retraining shall be provided for all authorized and affected employees whenever there is ((c)(7)(iii)(A)):

Additional retraining is also required whenever a periodic inspection reveals, or the employer has reason to believe, that there are deviations from or inadequacies in an employee's knowledge or use of the procedures ((c)(7)(iii)(B)). Retraining shall re-establish proficiency and introduce new or revised methods and procedures as necessary ((c)(7)(iii)(C)).

The training certification

The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training ((c)(7)(iv)). Those two items are the minimum; most plants also record the role (authorized, affected, other), the trainer, initial versus retraining, and the reason for any retraining, so the record answers an inspector's follow-up questions without a search.

Free procedure generator, $49 program kit

Write a machine-specific procedure for free. The kit includes a training record workbook (name, role, dates, initial or retraining and reason), the annual inspection certification form, and the written program template.

Questions

What is the difference between an authorized and an affected employee?

Under 29 CFR 1910.147(b), an authorized employee locks out or tags out machines to perform servicing or maintenance on them. An affected employee operates or uses a machine on which servicing or maintenance is being done under lockout or tagout, or works in the area where it is being done. Authorized employees apply the locks; affected employees must be notified before locks are applied and after they are removed ((c)(9)).

Can a machine operator be an authorized employee?

Yes. An affected employee becomes an authorized employee when their duties include performing servicing or maintenance covered by the standard, and then needs the authorized-employee training in (c)(7)(i)(A).

How often is LOTO training required?

The standard does not set a fixed refresher interval. It requires training under (c)(7)(i), retraining on the triggers in (c)(7)(iii) (job change, new hazard, procedure change, or deviations found), and a certification that training has been accomplished and is being kept up to date ((c)(7)(iv)).

What must the LOTO training record contain?

Each employee's name and dates of training ((c)(7)(iv)). Role, trainer and retraining reason are common additions but are not listed in the standard.

Related: Lockout vs tagout · Group lockout/tagout procedure · Lockout/tagout program template · Lockout/tagout for contractors

General information based on the text of 29 CFR 1910.147 on OSHA.gov; not legal advice. Check whether an OSHA-approved state plan applies to your workplace.