Lockout/Tagout in Construction - Cal/OSHA

Ask most crews whether lockout/tagout applies on a construction site and they will call it a factory rule. Under federal OSHA they are close: the general lockout standard, 29 CFR 1910.147, says in its own scope that it does not cover construction. California is different. The Construction Safety Orders send any machine or operation they do not specifically cover to the General Industry Safety Orders — and one of those is Title 8, Section 3314, California's control of hazardous energy rule. This Cal/OSHA Lockout/Tagout in Construction Toolbox Talk covers how that rule reaches a job site, what it requires, and what a crew member does when a machine needs to be cleared, fixed, or adjusted.

Where the boundary of this talk sits#

This talk covers California's lockout rule and how it reaches construction machinery. Basic lockout steps, energized electrical work, and specific machines belong to their own talks.

The anchor#

Here is the distinction that carries this whole talk: on a California job site, lockout is not a factory rule you can leave at the plant gate — Section 1502 sends every machine the Construction Safety Orders do not specifically cover to the general orders, and Section 3314 then requires a written hazardous energy control procedure, locks or seals on the controls, and an annual review of the procedure; so the mixer, the conveyor, the saw, or the pump a crew is about to reach into is under the same lockout rule as the machine in a factory, and "we're construction, that doesn't apply" is the federal answer, not California's.

How a factory rule reaches a job site#

Section 1502(b) says that at construction projects the Construction Safety Orders take precedence over other general orders that are inconsistent with them. Section 1502(c) fills the gaps: machines, equipment, processes, and operations not specifically covered by the Construction Safety Orders are governed by the other applicable general safety orders. Section 3314 is one of them.

Section 3314(a) applies to the cleaning, repairing, servicing, setting-up, and adjusting of machines and equipment where the unexpected energization or start-up of the machine, or the release of stored energy, could injure employees.

Compare the federal side. 29 CFR 1910.147(a)(1)(ii)(A) says the federal lockout standard does not cover construction employment. Federal construction rules do require tagging in specific situations — 29 CFR 1926.417, for example, requires that de-energized equipment or circuits be rendered inoperative and tagged at all points where they can be energized — but there is no general federal construction lockout standard of the kind California applies.

Stop it, and lock it#

Section 3314(c) covers cleaning, servicing, and adjusting: machinery or equipment capable of movement is stopped and the power source de-energized or disengaged, and, if necessary, the moveable parts are mechanically blocked or locked out to prevent inadvertent movement or the release of stored energy. If a machine has to move during cleaning, the employer must minimize the hazard by providing and requiring extension tools, and train employees in their use.

Section 3314(d) covers repair work and setting-up: prime movers, equipment, or power-driven machines equipped with lockable controls, or readily adaptable to lockable controls, are locked out or positively sealed in the "off" position. Accident prevention signs or tags, or both, are placed on the controls.

The rule counts every kind of hazardous energy. Its definition of "locked out" covers isolating or securing prime movers, machinery, and equipment from mechanical, hydraulic, pneumatic, chemical, electrical, thermal, or other hazardous energy sources. A pump with pressure in the line or a raised boom is not safe just because the engine is off.

There are narrow exceptions. Cord-and-plug-connected electric equipment is excluded when the hazard is controlled by unplugging it and the plug stays under the exclusive control of the employee doing the work. Minor routine adjustments during normal production can be excluded if alternative measures provide effective protection. And locks with unique personal identification can take the place of the sign requirement.

A written procedure for each machine#

Section 3314(g) requires the employer to develop and use a hazardous energy control procedure when employees clean, repair, service, set up, or adjust prime movers, machinery, and equipment, and the procedure must be documented in writing, with separate procedural steps for each machine or piece of equipment it covers. It must clearly and specifically outline the scope, purpose, authorization, rules, and techniques for controlling hazardous energy, and the means to enforce compliance, including at least:

• a statement of the intended use of the procedure;
• the procedural steps for shutting down, isolating, blocking, and securing the machine or equipment;
• the procedural steps for placing, removing, and transferring lockout and tagout devices; and
• the requirements for testing the machine or equipment to determine and verify that the lockout and other control measures are effective.

That last item is the one crews skip. Trying the start, with everyone clear, is how you prove the lock did its job.

Crews, shift changes, and outside contractors#

Construction rarely has one worker on one machine, and Section 3314 addresses that. Under subsection (h), when a crew, craft, or other group does the work, it uses a procedure that gives each employee protection equivalent to a personal lockout or tagout device. Primary responsibility is vested in an authorized employee for a set number of workers; when more than one crew is involved, overall job control is assigned to a designated coordinator; and each authorized employee affixes a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when starting work and removes it when finished.

Under subsection (i), specific procedures must be used during shift or personnel changes to keep lockout or tagout protection continuous, including the orderly transfer of protection between off-going and oncoming employees. Under subsection (k), when outside servicing personnel do work covered by the rule, the on-site employer's lockout or tagout procedures are followed.

Inspect it every year, and train people on it#

Section 3314(j) requires the employer to inspect the energy control procedures at least annually to evaluate their continued effectiveness and decide whether they need updating. The inspection is performed by an authorized employee or person other than the ones using the procedure being inspected.

Section 3314(l) requires authorized employees — the qualified people who lock out equipment to work on it — to be trained on the hazardous energy control procedures and the related hazards. Affected employees, who operate the equipment or work in the area, are instructed in the purpose and use of the procedure. Training is documented as required by Section 3203.

Where the duty sits#

8 CCR 1502(c) brings general orders onto the job site. 8 CCR 3314 carries the lockout duty, from written procedures to the annual inspection and training, documented under 8 CCR 3203. For contrast, federal 29 CFR 1910.147 excludes construction, and 29 CFR 1926.417 covers tagging of circuits.

What can go wrong?#

• A laborer reaches into a mixer to clear a jam with the engine idling.
• The mechanic locks the disconnect but nobody tries the start button to verify.
• Two crews work on the same conveyor, one lock is on, and the first crew removes it when they finish.
• The rental company's technician uses his own habits instead of the site procedure.

How do we manage this properly?#

• Stop and de-energize — every energy source, including pressure, gravity, and springs.
• Lock or seal the controls — and tag them unless the lock is uniquely identified.
• Follow the written procedure — for this machine, including the verification step.
• One lock per person in group work — on the group lockbox, removed only when that person is done.
• Transfer protection at shift change — no gap between crews.
• Outside personnel follow the site procedure.
• Review the procedure every year — by someone other than those who use it.

Before you start#

Name the machines crews will service or adjust today, and find each one's written procedure and lockout points. Confirm everyone has their own lock and knows the verification step.

Talk it over#

• Which machine on this job would you be most tempted to reach into without locking out?
• How do you verify a machine is really de-energized?
• What happens to your lock at the end of your shift if the job isn't finished?

The bottom line#

In California, lockout is not just a factory rule. Section 1502(c) brings Section 3314 onto the job site for machinery the Construction Safety Orders do not specifically cover. Stop and de-energize, lock or seal the controls, follow a written procedure that includes verification, protect every worker in group jobs and at shift changes, and review the procedures every year.

Frequently asked questions about Cal/OSHA lockout/tagout in construction#

Does lockout/tagout apply to construction in California?

Yes, for machines and equipment the Construction Safety Orders do not specifically cover. Section 1502(c) says those are governed by the other applicable general safety orders, which includes Section 3314. Federal 29 CFR 1910.147 excludes construction.

Download the Cal/OSHA lockout/tagout in construction toolbox talk PDF#

Download this Cal/OSHA Lockout/Tagout in Construction Toolbox Talk as a printable PDF in English and Spanish, and walk it through at the machine before anyone reaches in.

Related toolbox talks#

• Lockout/Tagout
• Energized vs. De-Energized Work
• Machine Guarding
• Conveyor Belt Safety

Sources#

• Cal/OSHA, Title 8 CCR §1502 — Application ((b) Construction Safety Orders take precedence over inconsistent general orders at construction projects; (c) machines, equipment, processes, and operations not specifically covered are governed by other applicable general safety orders): https://www.dir.ca.gov/title8/1502.html
• Cal/OSHA, Title 8 CCR §3314 — The Control of Hazardous Energy ((a) scope; exceptions to (c) and (d) for cord-and-plug equipment, minor servicing, and unique personal locks; (b) definitions of authorized employee, affected employee, locked out; (c) stop, de-energize, block, extension tools; (d) lock out or positively seal, signs or tags on controls; (g) written hazardous energy control procedure, its minimum contents, and separate steps for each machine; (h) group lockout; (i) shift and personnel changes; (j) inspection at least annually by someone other than those using the procedure; (k) outside servicing personnel follow on-site procedures; (l) training documented per §3203; operative 4-1-2018): https://www.dir.ca.gov/title8/3314.html
• OSHA, 29 CFR 1910.147(a)(1)(ii)(A) (federal lockout standard does not cover construction): https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147
• OSHA, 29 CFR 1926.417 (federal construction: de-energized equipment or circuits rendered inoperative and tagged at all points where they can be energized): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.417

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

Hazards covered