Vedanta Resources Plc

Sustainability Governance
System

Guidance Note GN20

Lock-Out / Tag-Out (LOTO)

Guidance Note – Lock-Out / Tag-Out (LOTO)

Guidance Lock-Out / Tag-Out Date of

10/01/2013
Document Title: (LOTO) Revision

Document VED/CORP/SUST/GN 20 Revision: v.1

Document Issue and Revision History

REVISION
DATE CHANGE SUMMARY
NUMBER
10/01/2013 V1. Initial Issue

Prepared by: K. Kiran Kumar Authorised by: Tony Henshaw

Signature Signature

Head of
Chief Sustainability
Position: Sustainability Position:
Officer
Assurance

Confidentiality
This document and its contents are the copyright property of Vedanta Resources Plc. The release of
this document to any third party outside of Vedanta is strictly prohibited without prior consent.

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1. INTRODUCTION

1.1. Who is this Guidance Note aimed at?

This Guidance Note is aimed at all Vedanta subsidiaries, operations and managed sites, including
new acquisitions, corporate offices and research facilities and to all new and existing employees and
contractor employees. This Guidance Note is applicable to the entire operation lifecycle (including
exploration and planning, evaluation, operation and closure).
This Guidance Note is for those operations and individuals responsible for the safe isolation of
hazardous energy sources at a Vedanta operation. The Guidance Note should be used in
conjunction with the Guidance Notes on Risk Assessment and Permit to Work together with
associated Standards as listed in the back of this Guidance Note.

1.2 What is the aim of this Guidance Note?

This aim of this Guidance Note is to outline Vedanta Resources’ requirements for Operations to
follow in order to safely isolate equipment, machinery and plant. This applies primarily
during the servicing and maintenance of equipment but also:
 during its normal operation if this requires operators to remove or by-pass a guard or safety
device, or place any part of their body into the danger zone or near the machine’s point
of operation; and
 during set-up/troubleshooting activities;
 in any other circumstances where the unexpected energization or start-up of the machine
or a release of stored energy could cause injury.

1.3 What issues does this Guidance Note address?

This Guidance Note presents the framework for hazardous energy isolations for all Vedanta
operations, showing the key technical activities that may apply in each of these contexts, and
identifying the main decisions to be taken at each stage.
The focus of the Guidance Note is on the provision of preferred methods and outcomes rather than
prescriptions whilst at the same time representing a practical “how to” guide for all Vedanta
operators. It is intended that the Guidance Notes will represent standard baseline guidance for all
Vedanta staff within all the operations whilst recognising the need for flexibility at a site depending
upon specific circumstances or regulatory specific requirements. In this sense, Guidance Notes are
not designed to be definitive text, nor are they designed to provide prescriptive methods and
procedures for undertaking tasks.

1.4 How should this Guidance Note be used?

This Guidance Note is not mandatory but is intended to reflect good practice and provide the basis
for continual improvement across the Vedanta business. However, where this Guidance Note is not
used, operations will need to demonstrate (and document) how an equivalent process is in place
and how this ensures the safe isolation of hazardous energy sources. Safe isolation is typically
either an explicit regulatory requirement or is considered to be a key element in the general duties
for the safe operation and maintenance of plant and equipment. General and equipment-specific
lock-out / tag-out (LOTO) procedures will need to be developed by each operation, taking into
account the range and technical specifications of equipment and plant on-site, local legal

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requirements and applicable standards etc. The guidance has been designed to be relevant to all
Vedanta operations.

The remainder of this Guidance Note is structured as follows:

 Section 2 – What Do We Mean by Hazardous Energy & LOTO?

 Section 3 – When Does LOTO Apply?
 Section 4 – General LOTO Programme Requirements
 Section 5 – Roles & Responsibilities,
 Section 6 – Competency & Training Requirements
 Section 7 – Isolation Procedures
 Section 8 – Monitoring

At the end of the Guidance Note there is information on Definitions and Related Documentation and
Annexes as follows:

Annex A – Example of a LOTO Register

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2. WHAT DO WE MEAN BY HAZARDOUS ENERGY & LOTO?

Serious injury or fatality can occur due to the unexpected start-up of equipment or the uncontrolled
release of energy during maintenance, servicing and set-up tasks. It is therefore critical when
carrying out such tasks that equipment cannot be started and that all hazardous energy sources are
properly de-energized, isolated, blocked and/or dissipated.

Types of hazardous energy sources include:

 Mechanical/kinetic – in the moving parts of mechanical systems (e.g. rotors, fan blades,
conveyers – note that there may be residual kinetic energy even after power has been
isolated);
 Electrical – from generated electrical power, static sources or electrical storage devices
(such as batteries or capacitors);
 Potential – stored in pressure vessels, gas tanks, fly wheels, hydraulic or pneumatic
systems, compressed or extended springs (potential energy can be released as hazardous
kinetic energy) and objects suspended at height (i.e. gravity).
 Pneumatic–gas, compressed air, vacuum.
 Thermal – high or low temperatures resulting from mechanical work, radiation, chemical
reaction or electrical resistance.
 Chemical– toxic, corrosive or flammable substances in chemical feed lines within processing
operations (1).
 Radiation – ionizing and non-ionizing radiation sources.

The following types of isolation are covered in this guidance document:

 Mechanical Isolation
 Electrical Isolation of all equipment.
 Instrument Isolation
 Isolation of other energy sources

These types of isolation are discussed further in the following sections of this guidance document.

Lock-out / tag-out (LOTO) refers to the specific practices and procedures to safeguard employees
from the unexpected energization or start-up of machinery, or the release of hazardous energy
during maintenance or servicing activities.

 Lock-out devices hold energy-isolation devices in a safe or “off” position. They provide
protection by preventing machines or equipment from becoming energized because they are
positive restraints that no one can remove without a key or other unlocking mechanism, or
through extraordinary means, such as bolt cutters.
 Tag-out devices, by contrast, are prominent warning devices that an authorized employee
fastens to energy-isolating devices to warn employees not to reenergize the machine while
he or she services or maintains it. Tag-out devices are easier to remove and, by themselves,
do not provide employees with sufficient protection.

The method of energy control depends on the form of energy involved and the available means to
control it. Energy is considered to be isolated or blocked when its flow or use cannot occur.

(1) Note also that inundation by water or by ore or other solid materials can be a significant risk in particular in the context of work in confined spaces, and
should, where relevant, also be addressed within the LOTO programme.

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3. WHEN DOES LOTO APPLY?

LOTO applies when employees or contract employees are involved in service or maintenance
activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and
maintaining or servicing machines or equipment. These activities include lubricating, cleaning or un-
jamming machines, and making adjustments or tool changes, where the worker may be exposed to
hazardous energy.

If a service or maintenance activity is part of the normal production operation, the employee
performing the servicing may be subjected to hazards not normally associated with the production
operation itself. Workers doing servicing or maintenance activities during normal production
operations must therefore follow lock-out/tag-out procedures if they:

 Remove or bypass machine guards or other safety devices,

 Place any part of their bodies in or near a machine’s point of operation, or
 Place any part of their bodies in a danger zone associated with machine operations.

Typical activities/equipment requiring isolation may include, but not be limited to:

 Vehicles (e.g. light and heavy vehicles, earth moving equipment, forklifts, haul trucks,
shovels, drag lines, locomotives, scoops);
 Confined spaces;
 Work on/in crushers, mills, chutes;
 Conveyers, material transfer and packing lines.
 Power hand tools (e.g. chainsaws, angle grinders, drills, nail guns);
 Line breaking;
 Electrical sub-stations, transformers, power lines, distribution panels.
 Motor control centres;
 Electrical motors, pumps, generators, drill rigs, winches.
 Pressure vessels, boilers and pipe work.

Whenever lock-out / tag-out is applicable, the machinery must be shut off and isolated from its
energy sources, and lock-out or tag-out devices must be applied to the energy-isolation devices. In
addition, all authorized person(s) must take steps to verify that the energy has been effectively
isolated including the use of one lock per person working on the isolated machinery. When there is
stored or residual energy, the authorized person(s) must take steps to render that energy safe. If the
possibility exists for re-accumulation of stored energy to hazardous levels, it must be ensured that
the person(s) perform verification steps regularly to detect such re-accumulation before it has the
potential to cause injury.

Exemptions from Lock-Out / Tag-Out

Exemptions from full lock-out / tag-out requirements will apply only in certain limited situations, for
example where:

 Exposure to hazardous energy is controlled completely by unplugging the equipment from an

electric outlet and where the employee doing the service or maintenance has exclusive
control of the plug. This applies only if electricity is the only form of hazardous energy to
which employee(s) may be exposed. This exception encompasses many portable hand tools
and some cord and plug connected machinery and equipment.

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 An employee performs hot-tap operations on pressurized pipelines that distribute gas,

steam, water, or petroleum products, for which it is shown that:
o Continuity of service is essential;
o Shutdown of the system is impractical; and
o The worker follows specific documented procedures and uses special equipment that
provides proven, effective employee protection.
 The worker is performing minor tool changes or other minor servicing activities that are
routine, repetitive, and integral to production, and that occur during normal production
operations. In these cases, workers must have effective, alternative protection.

4. GENERAL LOTO PROGRAMME REQUIREMENTS

All Vedanta operations should develop and implement a documented hazardous energy control
programme that, as a minimum:

 Establishes formal LOTO procedures;

 Trains all employees in the programme, and
 Enforces the use of the procedures at all times.

Hazardous energy control programmes should outline the following safe work practices to be carried
out by suitably competent personnel:

 Identify each piece of equipment, machine or plant that could deliver hazardous levels of
energy;
 Once the equipment has been identified, then identify tasks that may expose workers to
hazardous energy and therefore require LOTO;
 Identify a specific method to de-energize all hazardous energy sources, including those in
adjacent equipment – this will include:
o reviewing the physical ability/means of equipment to be locked out/isolated and making
modifications of existing equipment to allow for lockout where this is feasible (see Section
7.1);
o development of equipment-specific work instructions that detail the energy sources and all
locations of isolations needed to make the equipment safe prior to work being carried out
on it - ideally this should include diagrams/photographs of the relevant isolation methods
and locations.

The following steps should be followed for all isolations conducted:

1. Notify all employees who may be affected that a section of equipment is to be taken ‘out of
service’ and it will be isolated from all sources of Hazardous Energy.
2. The authorised employee shall refer to the company safe operating procedures to verify the
location, type and number of isolation points. In the absence of a procedure the additional
requirements of the Permit to Work Standard will apply.
3. Shut down the equipment using the normal shutdown sequence where possible. If possible
try to start the equipment to verify that the correct start controls have been identified and
then shut down again
4. Isolate the equipment from all sources of hazardous energy using the previously identified
isolation points and appropriate isolation devices.

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5. Lock-out all energy isolating devices to prevent inadvertent or unauthorised

reactivation/start-up(each person at risk should apply an individual Lock-out/Tag-out device
to each source of hazardous energy so there may be many locks or tags on each device)
6. Apply a Tag providing extra information if required by the local safe working procedure
7. Ensure that stored or residual energy (such as capacitors, springs, elevated machine parts,
fly wheels, hydraulic systems, and air, gas, steam or water pressure etc.) is dissipated or
restrained by methods such as grounding, repositioning, blocking, bleeding etc
8. Ensure that the equipment is disconnected from all energy sources by first checking that no
personnel are exposed, and then verify the isolation of the equipment by operating the
normal starting controls to test that the equipment will not operate.
9. The personnel working on the equipment shall complete a Risk Assessment to make a final
check that no potential hazard is overlooked and that all required safety equipment is
available and in use.
10. After work is complete, verify that all personnel are clear of danger points before re-
energizing the system. This is normally completed by the use of one lock per person
involved in the work programme.

Note: - If the equipment is left unattended a check must be made before work recommences to
verify that the lockout has not been removed or damaged.

The process flow provided below is an example of the various steps of a LOTO procedure.

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Identify:
Carry out hazard identification and
 equipment with hazardous energies
risk assessment
 tasks that could expose workers to those hazardous
energies
 potential modes of release/ways in which unexpected
Review equipment and ensure it is energization could occur
equipped and ready for lockout  necessary measures to de-energise / block energies
(May involve retrofitting to allow  specific isolation points
for lockout)

Prepare safe system of work Equipment-specific LOTO procedure

Work instruction/method statement
Permit to Work, if required;

Advise relevant parties

Isolate and lock
out / tag out
equipment Shut down equipment

Isolate

Lock/tag

Dissipate stored energy

Test isolation

Carry out risk assessment and

final check

Commence work

Carry out work Complete work

Check work

Clear area

Remove personal locks/tags

Remove isolation
Restore
equipment

Check area is safe, equipment is in

neutral and restore energy

Advise relevant parties

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Further guidance on the various elements of a LOTO programme is provided in the following
Sections.

5. ROLES & RESPONSIBILITIES

Isolations should only be carried out by appropriately trained, competent and authorised to do so.
Responsibilities and competency requirements in relation to isolations should be clearly described in
the operation’s LOTO procedure. The procedure should specify the following key roles:

 Competent (Responsible) Person –An employee who is responsible for ensuring there is a
safe procedure recorded for all aspects of the Control of Hazardous Energy in the
systems/areas for which they are responsible. This will either be an established local
procedure or referenced on a Permit to Work.

 Authorised Person– An employee or contractor who is permitted to lockout equipment to

perform a service or maintenance on that equipment. This includes both operators and
maintenance personnel. They will have received sufficient information and training to enable
them to carry out the safe efficient isolation of hazardous energy on nominated machines or
pieces of equipment. (Also sometimes referred to as an Isolation Officer).

 Affected Employees - Employees who operate the relevant machinery or whose jobs
require them to be in an area where service or maintenance is performed.

Registers/records of those authorised to carry out isolations (i.e. Authorised Persons/Isolation

Officers) must be maintained, including equipment competencies, site/work area limitations and
competency durations.

It should be ensured that all contractors carrying out isolations or working on isolated equipment on
behalf of Vedanta do so in accordance with the Vedanta Operation’s own procedure, that they are
competent (through provision of written evidence of training, examination etc.) and that they are
appropriately supervised. If, however, it is agreed that the contractor may use their own LOTO
procedures (for example in a defined work area where no Vedanta personnel could be present) then
this should be clearly communicated to all personnel who could be affected such that they
understand and comply with the requirements.

A communication plan should be developed to inform relevant employees and third parties about the
need for LOTO and the arrangements in place within the operation to manage energy isolation.

6. COMPETENCY & TRAINING REQUIREMENTS

The Competent (Responsible) Person will need sufficient knowledge, experience and training to
manage all aspects of safety on the Control of Hazardous Energy in the systems/areas for which
they are responsible.

Authorised Persons need the knowledge and skills necessary for the safe application, use and
removal of energy-isolating devices. Their training should cover aspects such as:

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 Recognition of applicable hazardous energy sources;

 Details about the type and magnitude of the hazardous energy sources present in the
workplace; and
 The methods and means necessary to isolate and control those energy sources (i.e. the
elements of the LOTO procedures, including relevant equipment-specific
procedures/instructions).

Affected Employees need to be trained in the purpose and use of LOTO procedures, including:

 Recognition of when the LOTO procedure is being used;

 Understanding of the purpose of the procedure;
 Understanding of the importance of not tampering with LOTO devices and not starting or
using equipment that has been locked or tagged out.
 Issuing with a personal lock.

Training requirements should be clearly documented within the LOTO programme and appropriate
records maintained. This should include arrangements to test understanding on the completion of
training and for the periodic testing of competency.

Re-training/refresher training should be considered in the event of significant changes to the

process, equipment, working practices and/or if workplace inspections, post-accident investigation
or risk assessment activity identifies shortcomings in the existing level of competency.

7. ISOLATION PROCEDURES

7.1 Identification of Relevant Equipment, Tasks and LOTO Methods

Hazard Identification and Risk Assessment

The LOTO programme should be based on a thorough review – using hazard and risk assessment
– of all items of equipment, machinery or plant that could deliver hazardous levels of energy, and
then the identification of tasks (both routine and non-routine) that may expose workers to hazardous
energy and will therefore require LOTO.

Equipment Review and Preparation

The review of the equipment referred to above should ensure that:

 All sources of potentially hazardous energy can be shut off and isolated.
 All sources of potentially hazardous energy that accumulate in a piece of equipment can be
dissipated or blocked.

It should be ensured that all new plant and equipment purchased or hired has the capability of being
physically isolated from all energy sources as required. An energy-isolating device is capable of
being locked out if it has a hasp or other means of attachment to which, or through which, a lock can
be affixed, or it has a locking mechanism built into it. Other energy-isolating devices are capable of
being locked out, if lockout can be achieved, without the need to dismantle, rebuild, or replace the
energy isolating device or permanently alter its energy control capability. Some examples of
lockable isolation devices are shown below.

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Lockable Valves
Examples of valves with integral lockout provision. If this is not provided then alternative lockout devices are available as
discussed in Section 7.3.

Distribution Panels
Electrical distribution panels should be provided with lockable switches/breakers.

Lockable Rotary Isolator Switches

These are a common means of isolating electrical power to specific items of plant/equipment. They may already be
installed or may need to be retrofitted to older items/circuits.

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If modification or reasonable adjustments cannot be made to facilitate lockout on existing plant and
equipment, then an alternative safe system of work will need to be developed that provides
equivalent levels of protection, e.g. tagging combined with at least one added safety measure that
prevents unexpected re-energization. Such measures might include removing an isolating circuit
element, blocking a controlling switch, opening an extra disconnecting device or removing a valve
handle

Dedicated isolation points should be identified and clearly and consistently labelled to identify the
circuit or system being isolated or locked out. The positions of state (i.e. open/closed) of cut-off,
isolation, dissipation and blocking points should be visible by means of an indicator. Switches and
other isolation points should be positioned in readily accessible locations.

Equipment-Specific Isolation Procedures

Based on the above, specific documented methods and procedures should be developed for the de-
energization, isolation and re-energization of each of the identified pieces of machinery/plant and
the associated tasks. These isolation procedures may include relevant line drawings, diagrams
and/or photographs of the relevant isolation methods and locations.

7.2 Planning & Documenting the Work

The person in charge of the operation of the equipment (the Operator) should be clearly identified,
and this should be recorded.

In order to ensure that that there is no confusion about the equipment that is to be worked on and
isolated (i.e. to prevent the wrong equipment being isolated),all parties involved – including the
Operator and those who will be carrying out the work - should identify the equipment before the
Authorised Person de-energizes, isolates or locks it out.

The Authorised Person shall refer to the defined isolation procedure to verify the location, type and
number of isolation points. In the absence of an equipment-specific procedure the general LOTO
procedure should be used (i.e. laying out the generic LOTO requirements) and the additional
requirements of the Permit to Work Standard will then also apply.

Once the Operator has handed control of the equipment in writing to an Authorised Person, they
may not operate or attempt to operate that equipment again, until the equipment has been handed
back in writing.

Any other Affected Persons should be notified that the equipment is to be taken out of service and
that it will be isolated from all sources of hazardous energy.
It is a good practice to document each isolation in a LOTO register which records:

 the equipment worked on;

 the work carried out;
 which isolations have been carried out, when and by whom;
 the names of all individuals who have applied personal locks;
 the date and time of removal of each isolation.

An example template of a LOTO register is provided in Annex A.

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7.3 Shutting Down the Equipment - Isolation of Energy Sources

All forms of hazardous energy should be de-energized, isolated, blocked and/or dissipated using the
previously identified isolation points. This may involve:

 Disconnecting or shutting down engines or motors that power mechanical systems;

 De-energizing electrical circuits by disconnecting the power source from the circuit; possible
disconnecting means include the power cord, power panels (look for primary and secondary
voltage), breakers, the operator's station, motor circuit, relays etc.;

 Blocking fluid (gas, liquid or vapour) flow in hydraulic, pneumatic, steam or chemical systems
by using control valves (1)or by disconnecting, capping or blanking pumps, compressors and
lines. Some systems may have electrically controlled valves. If so, they must be shut off and
locked/tagged out.

 Blocking machine parts against motion that might result from gravity (falling).

 Isolating control systems and instrumentation.

A wide variety of LOTO devices are available to enable the effective isolation of different energy
sources. Operations should ensure that they maintain a suitable stock of devices, the number and
type of which will depend on the size and complexity of operations and the nature of the isolations
that need to be carried out. Ready availability of such devices – for example in suitably located
lock-out stations – will help to promote the consistent application of the lock-out programme.

Devices should be readily accessible when needed. Good practice is to maintain a stock of devices
in lockout kits and/or at lockout stations positioned at appropriate locations around the operation.

Lockout Kits/Stations
Examples of portable lockout kits and lockout stations. Lockout stations are typically wall-mounted and are
available in a range of different sizes, allowing easy local access to lockout equipment.

(1) Depending on the energy source/risk it may be appropriate to specify that two valves in series are needed to be isolated rather than relying on a single
control valve.

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Devices should be:

 of appropriate durability – e.g. tags should not deteriorate or become illegible when used in
corrosive or wet environments);
 standardised – according to colour, shape, size and format;
 substantial – devices should be substantial enough to minimise early or accidental removal,
e.g. tag means of attachment should be non-reusable, attachable by hand, self-locking and
non-releasable; locks should be substantial enough to prevent removal without the use of
excessive force or unusual techniques such as with the use of bolt cutters or other metal
cutting tools;
 identifiable – locks and tags must clearly identify the employee who applies them; tags
should also warn against hazardous conditions if the machine or equipment is energized and
should include a legend such as: “Do Not Start”, “Do Not Open”, “Do Not Close”, “Do Not
Energize”, “Do Not Operate”;
 the only devices used for control of energy and should not be used for other purposes.

Some examples of the range of devices that are available for use on different types of energy
sources and controls are illustrated below.

Cable Lockout Electrical Plug Lockout

Integrated Safety Hasp and cable used for multiple circuit panel and Surrounds the electrical plug and protects against
side by side gate valve lockouts. accidental reconnection.

Universal Wall Switch Lockout Electrical/Pneumatic Lockout

Locks Out Both Toggle and Decora Paddle Wall Switches. Accommodates a large variety of electrical plugs
as well as male air hose connectors.

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Gate Valve Lockout

Completely surrounds the valve handle, ensuring it stays closed.
Available in a range of sizes.

Ball Valve Lockout

Example locks quarter-turn ball valves in OFF
position.

Fuse Blockout Gas Cylinder Lockout

Designed to be placed where fuses have been removed to prevent Surrounds the gas valve handle to protect against
accidental re-insertion of fuses. accidental valve opening.

Circuit Breaker Lockout

Example shown designed for breakers that have holes in the switch tongue.

A Note on the Use of Emergency Stops and Circuit Control Systems for Isolation

Emergency stops cannot be used as means of LOTO as (i) they do not physically disconnect the source of
power from downstream components and (ii) they do no release stored energy in the system.

Similarly, circuit control systems such as PLC systems and trip devices (e.g. interlocks, light beams) are not
energy isolating devices. Reliance on such systems to control machine or equipment safety functions, such
as stopping or preventing hazardous energy (motion), is not considered to provide effective employee
protection from injuries resulting from hazards such as component failure, programme errors, magnetic field
interference, electrical surges, and improper use or maintenance. However, if it can be demonstrated that a

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PLC or similar control system is an alternative measure which provides effective protection, the system may
be used only to protect employees who are performing minor tool changes and adjustments, and other minor
servicing activities that take place during normal production operations and are routine, repetitive, and integral
to the use of the equipment for production. To meet this exception, it must be demonstrated that there is
effective employee protection, through the use of a system hazard analysis. In other words, the PLC system,
on a case-by-case basis, would need to be designed, installed, used, and maintained in accordance with the
generally-recognized good engineering practices (e.g., applicable manufacturers' recommendations; prior
operating experience; reliability data) so as to protect employees from hazardous energy sources during the
minor servicing activities.

7.5 Lockout of Energy Isolating Devices

Each energy isolating device should then be locked out. Dedicated isolation locks (not normal
padlocks) should be used, and there should only be one key for each lock (combination locks are
not acceptable).

In most LOTO programmes, two types of locks are used:

 “Operations Lock”, “Job Lock” or “Project Lock”. These are dedicated isolation locks,
uniquely numbered or coded and normally distinguished by being a particular colour. They
are kept either by authorised individuals or at lockout stations and are then “booked out” for a
specific isolation (normally recorded in the Isolation Log).

 Personal locks. These are issued to individuals. They should be engraved ideally with
worker’s name and/or sequential numbering that can be traced to the individual together with
a durable tag to identify the worker assigned to the lock. They can also have photo
identification document applied.

Although not mandatory, locks can also be colour coded according to the department owners or
according to the type of energy.

The lock-out procedures should ensure that all workers secure energy control devices with their own
individually assigned locks.

If more than one worker is relying on the protection of an isolation, then all workers should apply
their own locks, e.g. using a multi-lock hasp or lock box. Each worker has the right to inspect all the
energy sources to ensure they are properly locked out before they apply their personal locks.

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If the Authorised Person is working on equipment which requires isolation but where no one else is
involved and the work is no longer than one shift, then it is normally acceptable for them to apply
only their own personal lock (i.e. an Operations Lock”, “Job Lock” or “Project Lock” is not needed).

Master Lockout Box

Prevents keys from being accessed until last padlock or lockout
Multi-lock Hasp
hasp is removed from the box. Provides the highest level of
Allows a number of users to apply their personal
security available in a group lock box. Each lockout point on a
locks to the same isolation. This can be applied
piece of equipment is secured with a single padlock. Keys are
directly to the lockout point or to a lockout box if
placed in the group lock box and then each authorised employee
needed.
places their personal padlock on the lock box. When work is
complete, employees take their personal padlocks off the lock
box, freeing the keys inside. Keys inside cannot be accessed
until the last employee removes their padlock.

7.6 Application of Tags

All designated isolation points fitted with a locking device should be tagged. The tagging system
should ensure that:

 Isolation points are positively identified, including the name of the person locking out;
 The reason for the isolation is clearly identified;
 Isolation tags are highly visible to prevent inadvertent operation.

Examples of tags are shown below.

A typical tag, either attached to a lock or applied This example includes photo ID of the worker who is
solely as a tag-out. applying the isolation.

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Dedicated “Out of Service” tags may also be used to differentiate between equipment that is out of
service (which could be for an extended period of time) and that which is subject to an active
isolation.

When the use of lockout devices and procedures is impossible, a tag must be placed to indicate that
the operation or movement of energy isolating devices from the "safe" or "off" position is prohibited.
When possible, the tags must be placed at the same point at which a lockout would have been
attached. If this is not feasible, the tag must be placed as closely as safety allows to the device in a
position that will be immediately obvious to anyone who attempts to operate the device. Additional
means should be implemented to provide an equivalent level of employee protection to that
provided by lockout. This may include measures such as removal of an isolating circuit element,
blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve
handle to reduce the likelihood of inadvertent energization.

7.7 Dissipation of Stored Energy

Some forms of energy must be dissipated or restrained (by grounding, re-positioning, blocking,
bleeding down etc.) after a system has been de-energized. System components such as electrical
capacitors, hydraulic accumulators, or air reservoirs may retain sufficient energy to cause serious
injury or death. For example, energy can be dissipated by taking the following steps:

 Vent fluids from pressure vessels, tanks or accumulators until internal pressure is at
atmospheric levels (but do not vent vessels or tanks containing toxic, flammable or explosive
substances directly to the atmosphere).
 Discharge capacitors by grounding.
 Release or block springs that are under tension or compression.
 Dissipate inertial forces by allowing the system to come to a complete stop after the machine
or equipment has been shut down and isolated from its energy sources.

All machinery or equipment in the immediate area, or linked mechanically, electrically or through a
control system, must also be made safe, and the work area controlled to prevent unauthorised
access.

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7.8 Verification of the Isolation

Once the isolation has been carried out, the Authorised Person should safely test that the
equipment has been made safe and has zero energy. The type of test will depend on the
equipment, but in all cases, all potential and other forms of stored energy must be discharged or
controlled. This test should be described in the isolation procedure for the equipment. Only
instruments approved for the purpose should be used. Tests may include (but not be limited to):

 Pressure;
 Voltage (including induced voltage);
 Redundant charges;
 Elevated equipment;
 Enclosed areas;
 Hazardous chemicals (particularly in confined spaces);
 Stored electrical energy;
 Temperature;
 Equipment under tension (e.g. cables, conveyer belts);
 Sources of gas.

Finally, after checking that no personnel are exposed, the isolation of the equipment should be
verified by operating the normal starting controls to test that the equipment will not operate. Return
operating control(s) to neutral or "off" position after verifying the isolation of the equipment.

Before beginning work, the personnel working on the equipment should complete a risk assessment
to make a final check that no potential hazards have been overlooked and that all required safety
equipment is available and in use.

If there is a possibility of re-accumulation of stored energy to a hazardous level, verification of

isolation should be continued until the servicing or maintenance is completed, or until the possibility
of such accumulation no longer exists.

7.9 Maintaining Continuity of the Isolation - Shift/Personnel Changes

The operation’s LOTO procedures should provide for continuity of LOTO protection. This includes
the orderly transfer of LOTO devices between outgoing and incoming shifts. Whilst there are a
number of different ways that this can be achieved, the following two typical scenarios provide an
example of an appropriate approach:

 Isolation involving a single personal lock (i.e. where an Authorised Person is carrying out a
job on their own and where they have used their own personal lock to isolate)

In this scenario there should be a handover between the outgoing and incoming Authorised
Persons. The outgoing Authorised Person will remove their personal lock and the incoming
Authorised Person will apply theirs.

Another method used in some operations is that of a “shift change lock” to which only authorised
employees have access. The shift change lock is applied until the next Authorised Person is ready
to start their work – note, however, that as more than one person has access to this type of lock –

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and therefore the ability to remove it - it does not provide personal protection. If using this approach
it is important to train employees are trained never to use shift change locks for personal protection.

 Work involving multiple persons (i.e. where “job” isolation lock(s) have been applied by an
Authorised Person and then each member of the work team applies their personal lock(s)).

Control of the job lock(s) used to effect the isolation will then be transferred between the outgoing
and incoming Authorised Person (as this is not a personal lock it may remain in place and only
control of the device – i.e. the key – is transferred). The incoming work team will then apply their
personal locks to the isolation and the outgoing work team will then remove their personal locks

When LOTO devices remain on energy isolation devices from a previous shift, the incoming shift
members should verify for themselves that the machinery is effectively isolated and de-energized.

If the equipment is left unattended a check must be made before work recommences to verify that
the lockout has not been removed or damaged.

7.10 Removing the Isolation

When work has been completed a check should be made that all employees and contractors have
completed the necessary tasks and the work area should be inspected to ensure that it has been
made safe (guards replaced, tools removed, personnel removed to a safe area etc.).

After verifying that any controls (where appropriate) are in neutral, workers will then remove their
personal locks and tags followed by the Authorised Person, who will then remove their own lock, tag
and lock-out device.

Re-energization of the equipment or systems will then occur in line with normal start-up procedures
after communication to all staff affected by the isolation.

A final check should be made that normal operation has resumed correctly and the lock-out register
and/or permit to work completed and closed.

It is critical that the worker who installs a lock should be the one who removes it after work is
completed. If for any reason this is not possible then a specific procedure must be followed (this
should be documented in the operation’s lock-out tag-out procedure). Only the site manager or
appointed nominee may then authorise removal of the lock after:

1. Determining why the owner cannot remove the lock;

2. Making every reasonable effort to contact the lock owner or establishing their whereabouts;
3. Ensuring that the area and equipment is safe for the removal of the lock;
4. Authorising the removal of the lock in writing (often an Abnormal Lock Removal Form is
established for this purpose); and
5. Advising the owner at the earliest opportunity that the lock has been removed.

8. MONITORING

The consistent application and effectiveness of the LOTO programme should be monitored through
an appropriate audit/inspection regime carried out by suitably competent personnel. This should
include review of:

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 competencies (through observation, discussion and review of records);

 written LOTO records/registers and completed permits to work;
 content and adequacy of procedures; and
 on-site observations of the application of LOTO.
 Number of audits conducted
 Number and type of non-compliances identified

Changes to procedures and systems (including training and competency assessment, where
appropriate) must be made and documented to eliminate non-compliance.

The operation’s Management of Change programme should trigger a review of LOTO requirements
when there are modification to plant or equipment, or when new equipment is installed.

The isolation LOTO programme should be periodically reviewed (at least annually).

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DEFINITIONS

Definitions of key terms used in this document are shown in the following table.

Term Definition

An employee whose job requires him/her to operate or use a machine or

piece of equipment on which servicing or maintenance is being
Affected Person/Employee performed under lock-out or tag-out, or whose job requires him/her to
work in an area in which the servicing or maintenance is being
performed.

A person who locks out or tags out machines or equipment in order to

Authorised Person/Employee
perform servicing or maintenance on that machine or equipment.

An energy-isolating device is capable of being locked out if it has a hasp

or other means of attachment to which, or through which, a lock can be
affixed, or it has a locking mechanism built into it. Other energy-isolating
Capable of being locked out
devices are capable of being locked out, if lockout can be achieved,
without the need to dismantle, rebuild, or replace the energy isolating
device or permanently alter its energy control capability.

A person with sufficient knowledge, experience and training to manage

all aspects of safety on the Control of Hazardous Energy in the systems
for which they are responsible. This person ensures there is a safe
procedure recorded for all aspects of the Control of Hazardous Energy.
Competent (Responsible) This will either be an established local procedure or referenced on a
Person Permit to Work. (Depending on the size and complexity of the operation,
there may be a single Responsible Engineer / Competent (Responsible)
Person or there may be a number of competent persons responsible for
the LOTO programmes in different parts of the organisation, all reporting
to a single Responsible Engineer).
An employee of a contracted company engaged or commissioned by
Vedanta to undertake work or provide services, but who are not directly
Contractor / Contract Employee
employed by Vedanta. For example, contractor employees working on
/ Contract Worker
Vedanta operations, persons working for Vedanta through
staff/employment agencies, contract cleaners etc.

Energized Connected to an energy source or containing residual or stored energy.

A mechanical device that physically prevents the transmission or release

of energy, including but not limited to the following: a manually operated
electrical circuit breaker; a disconnect switch; a manually operated
switch by which the conductors of a circuit can be disconnected from all
Energy-isolating device
ungrounded supply conductors, and in addition, no pole can be operated
independently; a line valve; a block; and any similar device used to block
or isolate energy. Push buttons, selector switches and other control
circuit-type devices are not energy-isolating devices.
Any source of electrical, mechanical, hydraulic, pneumatic, chemical,
Energy source
thermal, or other energy, including sources of potential energy.

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Term Definition

An individual who is engaged to work directly for Vedanta on either a

part-time or full-time basis and for a fixed period or on permanent basis
and is salaried. By virtue of the individual’s contract of employment, the
Employee employee is obliged to adhere to Vedanta’s terms and conditions of
employment (specific to Group or the subsidiary employing the
individual), and is protected by national (where it exists) and
international laws concerning labour and working conditions.

Recognised, accepted and prescribed training with a set and replicable

Formal Training
structure.
An object, property or an activity that can cause adverse effects e.g. a
Hazard high voltage electricity supply or a toxic chemical may present a hazard,
meaning that they present the potential for harm.
A procedure used in the repair, maintenance, and services activities,
which involve welding on a piece of equipment (pipelines, vessels, or
tanks) under pressure, in order to install connections or appurtenances.
Hot tap
It is commonly used to replace or add sections of pipeline without the
interruption of service for air, gas, water, steam, and petrochemical
distribution systems.
The placement of a lock-out device on an energy-isolating device, in
accordance with an established procedure, ensuring that the energy-
Lock-out
isolating device and the equipment being controlled cannot be operated
until the lock-out device is removed.
A device that uses a positive means such as a lock to hold an energy
Lockout device isolating device in the safe position and prevent the energizing of a
machine or equipment. Included are blank flanges and bolted slip blinds.
A location or activity that is operated by a Vedanta Company and is part
of the Vedanta Group. Locations could include mines, refineries, ports or
Operation(s) transportation activities, wind farms, oil and gas development sites,
offices including corporate head offices, and research and development
facilities.
A single person with overall responsibility for the content, application and
regular review of the isolation programme and LOTO procedure. This
Responsible Engineer
person will also typically be responsible for the creation of equipment-
specific isolation procedures or method statements.
The effect of uncertainty on objectives (as defined by the ISO 31001
Risk Standard). Uncertainties include events (which may or not happen) and
uncertainties caused by a lack of information or ambiguity.
The formal process of identifying, assessing and evaluating the health
Risk assessment
and environmental risks that may be associated with a hazard.
Workplace activities such as constructing, installing, setting up,
adjusting, inspecting, modifying, and maintaining and/or servicing
machines or equipment. These activities include lubricating, cleaning or
Servicing and/or maintenance un-jamming machines or equipment and making adjustments or tool
changes where the employee may be exposed to the unexpected
energization or start-up of the equipment or release of hazardous
energy.
Any work performed to prepare a machine or equipment to perform its
Setting up
normal production operation.

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Term Definition

The placement of a tag-out device on an energy isolating device, in

accordance with an established procedure, to indicate that the energy-
Tag-out
isolating device and the equipment being controlled may not be operated
until the tag-out device is removed.
A prominent warning device, such as a tag and a means of attachment,
which can be fastened securely to an energy-isolating device in
Tag-out device accordance with an established procedure, It indicates that the energy-
isolating device and the equipment being controlled may not be operated
until the tag-out device is removed.
A subsidiary of Vedanta Group either fully or majority owned that has its
Vedanta Company own management structure (e.g. Hindustan Zinc Limited, Vedanta
Aluminium Limited, Sterlite Industries Limited, etc.)

RELATED DOCUMENTATION
A summary of the references and supporting documents relevant to this document is provided in the
following table.

Doc. Ref. Document name

POL 06 HSE Policy
MS 1 Leadership, Responsibilities and Resources
MS 3 New Projects, Planning Processes and Site Closure
MS 6 Competency, Training and Awareness
MS 9 Documentation and Records Management
MS 11 Incident Reporting and Investigation
MS 12 Auditing and Assurance
MS 14 Management Review and Continual Improvement
TS 06 Supplier and Contractor Management
GN 07 Risk Assessment
GN 10 PPE
GN 19 Permit to Work

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ANNEX A – EXAMPLE OF A LOTO REGISTER

Equipment to be Activities to be Isolation method Isolation Lock Person applying the Removal of Signature
isolated undertaken and location/Work implemented Number isolation isolation
permit number (date/time) (Printed name and (date/time)
signature)

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