Lockout Tagout in a Locomotive Shop: OSHA 1910.147 and FRA Blue Signal Coordination

A lockout tagout locomotive shop program has two parts: OSHA 1910.147 energy control procedures for each piece of equipment, and FRA blue signal protection for workers on, under or between rolling equipment. Write the procedures machine by machine, then make sure the two systems do not contradict each other.

Key Points

• 29 CFR 1910.147 requires procedures to be “developed, documented and utilized” and the control steps to follow a set sequence.
• 49 CFR Part 218, Subpart B governs blue signals and locked switches protecting workers on, under or between rolling equipment.
• The two systems answer different hazards. One isolates energy. The other prevents movement and coupling.
• Locks, tags and the places to keep them are your responsibility as the employer. 1910.147(c)(5) says the hardware “shall be provided.”

What the OSHA standard requires

1910.147(a)(1)(i) states that the standard “covers the servicing and maintenance of machines and equipment” where unexpected energization, startup or release of stored energy could injure employees. Under (a)(2)(ii), “Normal production operations are not covered by this standard.”

Three paragraphs shape a shop program:

• (c)(4)(i): procedures “shall be developed, documented and utilized for the control of potentially hazardous energy.”
• (c)(5): “Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware shall be provided.”
• (c)(6): the employer inspects the procedure “at least annually” and certifies the inspection.

The application steps under paragraph (d) must be done in sequence: preparation for shutdown, shutdown, isolation, lockout or tagout device application, stored energy, and verification of isolation. Do not skip the last step. A lock on a disconnect proves nothing until someone verifies the equipment cannot start.

Writing a lockout tagout locomotive shop procedure for each machine

One generic sheet for the whole shop will not hold up. Write a procedure for each machine or equipment type, and base it on the energy sources actually present. For locomotive work, walk through these categories:

1. Stored air. Identify the line valves that isolate the supply, the points where air is bled off, and how the worker confirms pressure is gone.
2. Traction motor and electrical power. Name the disconnects or breakers that isolate the circuit and the locking point for each.
3. Engine start systems. List every way the engine could be started, from the cab and elsewhere, and the isolating step for each.
4. Lifting equipment. Cover hydraulic or electrical energy, plus any load that can fall or shift. Blocks and wedges belong on this list, since 1910.147(c)(5) names them as hardware.

Each procedure should state scope, purpose, authorization, rules and techniques. It should identify the specific device that counts as the isolating point. Push buttons and selector switches are control circuit devices and are not energy isolating devices under the standard’s definitions.

Group lockout for shop crews

Locomotive work rarely involves one person. 1910.147(f)(3)(ii) says group lockout or tagout devices “shall be used in accordance with the procedures” required by (c)(4). Your procedure must therefore state who holds primary responsibility, how each worker adds a personal lock, and how the crew knows the group lock is fully released.

Removal is personal. Under (e)(3), “Each lockout or tagout device shall be removed from each energy isolating device by the employee who applied the device.” The standard allows a limited exception under employer-directed procedures when that employee is unavailable. Write that exception into your procedure in plain steps if you use it.

Blue signal protection under FRA Part 218

Blue signal rules protect workers from movement of the equipment. Section 218.21 sets the minimum protection for railroad employees working on, under or between rolling equipment. While blue signals are displayed, the equipment cannot be coupled to or moved, and a train cannot pass the signal (§218.23).

Two points matter on the shop floor:

• Other than main track. Under §218.27, a blue signal is displayed at or near each manually operated switch providing access to the track, and the switch is locked against movement onto the track.
• Locomotive servicing areas. Section 218.29 allows an alternate method where workers are on, under or between equipment in a locomotive servicing track area. Blue signals and locked switches are placed at the area’s entrance and departure points.

Only the same craft or group that displayed a blue signal may remove it (§218.23). Match that in your shop rules, so a mechanical crew’s signal is never pulled by someone else.

For the equipment side, see our blue flag safety equipment for railroads.

Where the two systems meet

A locomotive on a shop track can need both. The blue signal and locked switch keep a movement from reaching the unit. The lockout procedure keeps the unit’s own energy from hurting the person working on it. Neither replaces the other.

Part 218 covers positional protection. It is not a rule that sets how you isolate stored air, traction motor power or engine start systems. Those details come from your 1910.147 procedures. Which agency has authority over a particular task can depend on the work involved, so ask your safety office to confirm the boundary for each task before you finalize the procedures. Where your railroad’s own rules are stricter, follow the stricter rule.

Hardware and storage

The standard says the employer provides the locks, tags and other hardware, and that devices are identified. A program works better when that hardware lives where the work happens. Typical setups include a lockout station at each pit or platform, and a shadowed board so a missing lock is obvious. Our 5S tool storage organization page covers the layout side. Related equipment includes collapsible pit handrails and locomotive work platforms.

Next steps

Start with an inventory of every machine and piece of equipment your crews service, then write each procedure and schedule the annual inspection. If you need blue flag equipment, see Blue Flag Safety Equipment for Railroads. Send the part numbers and quantities through /contact/ or call 800-377-2109, and we will quote it.