Document Type: Procedure

Level: Level 2
Code / Rev: PRD14936/0
Official Language: English
Effective Date: 01/Jan/2015

This document as well as the information or data contained herein are the exclusive property of Tenaris S.A. and of its affiliated companies and as such
must be considered confidential. This document or any information and/or data contained herein shall not be copied, reproduced, disclosed, distributed
or otherwise used to and/or by third parties for any purpose without the express, prior and written consent of Tenaris. Such prohibited actions will be
prosecuted to the fullest extent of the law. ALL RIGHTS RESERVED.

Control of Hazardous Energy (LOTO)

1 Objective

This procedure establishes the minimum requirements for the control of energy during
any activity performed on machines and equipment, whenever energies and/or
movements could cause injury to personnel or cause damage to property.

2 Scope

This procedure applies to all Tenaris Sites except where local stricter laws or
regulations prevail.
This procedure covers all activities performed on machines and equipment when:
• own personnel or contractors are required to remove or bypass a guard or other
safety device, or
• own personnel or contractors are required to place any part of their body into an
area on an operating machine or piece of equipment or where an associated danger
zone exists during a machine operating cycle.

3 Out of Scope

Other activities on machines and equipment which do not expose personnel and
contractors to relevant risks or properties to damages, are not covered by this
procedure.
For example:
• minor tool changes and adjustments, and other minor service activities, which take
place during normal production operations, which are routine, repetitive, and
integral to the use of the equipment for production, provided that the activity is
covered by a proper risk analysis and performed using measures which provide
effective protection;

WRITER REVIEWER (S) APPROVER

BIANCHI Emilio HSE MULLER Stefano HSE

TAVERNA Roberto HSE Tenaris, BREMBILLA Giovanni HSE
Tenaris Tenaris

Important Note (for document printed from Tenaris Workplace)

This printed document might already be invalid unless the copy shows evidence of being controlled.
If the copy is not controlled and you are not systematically alerted of changes, please check the latest applicable version posted in Tenaris Workplace before implementation.
If you are not authorized to access Tenaris Workplace, please mail to: IDM Reviewer(s).
Tenaris

• routine work on cord and plug connected electrical equipment which is under
constant surveillance by the person performing the work and controlled by simply
unplugging the equipment. Whenever possible it is strongly recommended to apply
the physical lock-out of cut-energy devices.

4 Main Responsibilities

The Site Manager is responsible to comply with this procedure providing the needed
resources and leadership.
Area Leader and Maintenance Manager are responsible for:
• determining which persons from Operations, Maintenance, Contractors, etc. (here
referred to as the “LOTO Leaders”) are authorized to perform a lock-out or tag-
out on machines and equipment;
• maintain an up-to-date list of the LOTO Leaders.
Area Leader and Maintenance Manager with the support of the HSE Site Manager are
responsible for:
• issuing a local LOTO and Work Permit procedure according to this procedure and
applicable regulations;
• determining which activities are within the scope of the local LOTO and Work
Permit procedure;
• ensuring that:
- LOTO Leaders receive proper initial and refresher training courses;
- all other employees and contractors required to perform activities on machines
and equipment (here referred to as “Operating people”) receive proper
awareness training.
Maintenance Manager is responsible for drafting the equipment-specific LOTO work
instructions.
LOTO Leader is responsible for:
• applying the local LOTO and Work Permit procedure and the equipment-specific
LOTO work instructions;
• giving evidence that the machines and/or equipment have been properly locked out
or tagged out.
Operating people are responsible for:
• informing the LOTO Leader and the Area Leader about the task they are in charge
of;
• waiting for their authorization before starting any activity;
• informing the LOTO Leader once their task is completed.

Control of Hazardous Energy (LOTO) 2/9

Tenaris

5 General Rules

5.1 Lock-out and Tag-out systems

Lock-out shall be always preferred to tag-out as a safety practice.
If a machine or equipment is incapable of being locked out or in those Sites where a
local lock-out procedure is not in place, a tag-out system shall be used provided that the
tag-out system guarantee a safety level comparable to the lock-out one.

5.2 Physical locks on new and modified machines and equipment

Every cut-energy element on new machines and equipment shall allow to place a
physical lock so that it can be secured in the off position.
In the case of replacement or major repair, renovation or modification, existing
machines and equipment shall be equipped with lockable cut-energy elements.

5.3 Lock-out and Tag-out rules

To avoid accidental or inadvertent operation, machines or equipment shall be:
• stopped and isolated from all potentially hazardous energy sources (electrical,
hydraulic, pneumatic, chemical, thermal, or others);
• discharged of any residual energy;
• locked out or tagged out.
Lock-out or tag-out shall also apply when working on or near exposed, energized
electrical circuits or parts.
Locks and tags shall only be removed by the persons who has in charge them. No other
employee shall attempt to:
• remove the locks and/or tags from the cut-energy elements;
• operate any switch, valve, or other energy isolating device which is locked out or
tagged out.
Whenever possible, the use of tools such as vibration monitors, heat guns, laser rulers,
etc. must be considered to perform activities without entering an operating area.

5.4 Lock-out materials

Locks shall be singularly identified by a serial number or a permanent mean of
identification and not be used for other purposes. Four categories of locks have been
defined:
• an individual personal lock, permitting a single person to lockout and service a
machine or equipment. It shall indicate the identity of the employee applying the
lock;
• a machine specific lock to be placed and locked on the cut-energy elements by the
LOTO Leader. This machine specific lock must indicate the reference of the
machine or equipment to be locked out;
• a multiple lock out device, receiving the key of the machine specific lock, and
permitting multiple persons to place their locks;
• a temporary lock, permitting the LOTO Leader going off duty to retrieve his/her
personal lock leaving the machine or equipment locked for the coming LOTO
Leader.

Control of Hazardous Energy (LOTO) 3/9

Tenaris

Each lock must be recorded in a database which identifies who or what machine or
department the lock was issued to so it can be used as a supplementary means of
identifying the owner of the lock.

5.5 Tag-out materials

A tag-out system shall be used when a machine or equipment is incapable of being
locked out or until a local lock-out procedure is in place.
Tags shall read:
“DANGER, DO NOT OPERATE, DO NOT REMOVE THIS TAG !”
and include the name of the LOTO Leader who released it and the date and time the
tag was applied.
• Tag-out materials, including their means of attachment, shall be substantial enough to
prevent inadvertent or accidental removal. In order to be effective, tags must be legible
and clear to all employees and contractors who may be in the area.

5.6 Physical locks on defective or abandoned machines and/or equipment

Physical lock-out of cut-energy devices must be applied to the equipment, machinery,
processes, etc. that are deemed to be defective or abandoned and may be intentionally,
remotely, or accidentally operated.

6 Procedural Steps

6.1 Local LOTO work instructions

Every machine or equipment whose unexpected energizing or start-up could cause
injury to personnel or cause property damage, must have a LOTO work instruction.
To draft each equipment-specific LOTO work instruction, an initial survey must be
conducted:
• to identify type and severity of risks originating from all the hazardous energy
sources, considering that more than one may be present on the same machine;
• to locate and identify all cut-energy elements in order to be certain which energy
isolation switch, valve, or other cut-energy element applies to the machine or
equipment to be locked out or tagged out.
The equipment-specific LOTO work instruction shall identify the proper shutting
down sequence, how to locate, disconnect and isolate the energy sources, how to verify
that the energy is properly isolated, and the steps for restoring the energy to the
machine or equipment.

6.2 Informing the LOTO Leader

In order to start the activity, Operating people shall inform the LOTO Leader and the
Area Leader about the tasks they are in charge of and then wait that the machines
and/or equipment have been properly locked out or tagged out before starting the
activity.

Control of Hazardous Energy (LOTO) 4/9

Tenaris

6.3 Lock-out or Tag-out of Machines and Equipment

The LOTO Leaders must:
• review the LOTO and Work Permit procedure and equipment-specific LOTO
work instructions;
• notify all employees and contractors that a lock-out or tag-out system is to be used
and the reason for it, prior to application of controls;
• shut down the operating machine or equipment by the normal stopping procedure
(e.g., push the stop button, open the toggle switch, close the valve, etc.);
• physically locate and operate the energy isolation switch, valve, or other energy
isolating device so that the equipment is isolated from its energy sources;
• lockout or tagout the cut-energy elements with the assigned locks or tags.
• release any stored or residual energy (such as that in capacitors, springs, rotating
flywheels, hydraulic systems, and air, gas, steam or water pressure) using methods
such as grounding, repositioning, blocking, or bleeding down (high voltage
electrical systems shall be locked out or tagged out and grounded by certified and
designated maintenance personnel only);
• ensure that the equipment is disconnected from the energy sources and return the
operating controls to the safe, neutral, or off position;
• in the case of a tag-out, perform, whenever possible, additional safety measures
such as:
- the removal of an isolating circuit element;
- the blocking of a controlling switch;
- the opening of an extra disconnecting device;
- the removal of a valve handle;
• when the equipment must be maintained in an energized position due to specific
activities to be performed, put in place or activate the mechanical block specific to
the machine.

6.4 Verifying Isolation

The LOTO Leader must:
• verify that all the energies are released by adequate tools such as metering electrical
equipment, gauges on hydraulic or pneumatic lines, inspection windows on
electrical disconnects, etc.;
• make certain that the machine or equipment is effectively isolated by turning it on
or by testing it prior to beginning the activity and once all Operating people are in
a safe position.

6.5 Start of activities

Once verified the isolation of the machine or equipment, the LOTO Leader shall
inform the Area Leader (or other person having required the activity) that the LOTO
procedure have been completed, and activities may start at his/her discretion in
compliance with the local LOTO and Work Permit procedure.

Control of Hazardous Energy (LOTO) 5/9

Tenaris

6.6 Individual personal locks

Once authorized by the Area Leader (or other person having required the activity), all
Operating people involved, shall place, where applicable, their personal lock on the
energy-cut element or on the multiple lock-out device in compliance with the
equipment-specific LOTO work instruction.

6.7 Contractors
When contractors are involved, the Area Leader (or other person having required the
activity) and the third-party supervisor shall inform each other of their respective
LOTO procedures. If applicable, contractors shall use their personal lock and tags
identifying their names as well as their company.

6.8 Completion of the activities

Once the activities are completed, the Operating people must:
• check the machine or equipment and the immediate area to ensure that
nonessential items have been removed and that the machine or equipment
components are operationally intact;
• check the work area to ensure that all personnel have left the affected area;
• remove all personal locks;
• advise LOTO Leader that the tasks are completed and machines or equipment may
be restored to service.

6.9 Restoring machines or equipment to service

The LOTO Leader must:
• verify the documentation and information provided by Operating people to ensure
that service can be restored;
• be sure that all personnel has left;
• remove the tag or lock;
• re-energize the machine or equipment according to the equipment-specific LOTO
work instruction ensuring that each step does not interact or interfere with the
following one;
• test the machine or equipment to assure proper and safe operation;
• notify the Area Leader that the activity is completed and the machine or equipment
is ready to be returned to service.

7 Exceptional Steps

7.1 Changing the LOTO Leader

In the case of a different LOTO Leader will intervene to restore the machine or
equipment to service:
• the leaving LOTO Leader will retrieve his/her lock and the coming one will place
his/her own one; or
• being the second LOTO Leader absent at that moment, the leaving LOTO Leader
will retrieve his/her lock and place the temporary one. Once arrived, the coming
LOTO Leader will retrieve the temporary lock and place his/her own one.

Control of Hazardous Energy (LOTO) 6/9

Tenaris

7.2 Testing, troubleshooting, or positioning of machines, equipment or components

In situations where lock or tags must be temporarily removed from the cut-energy
device in order to energize the machine or equipment to test, troubleshoot or position
the equipment or its components, the following sequence shall be followed by the
LOTO Leader:
• verify that machines or equipment have been cleared of all tools and materials;
• remove Operating people from the machine or equipment area;
• ask Operating people to remove their personal locks;
• remove the machine specific lock or the tag from the cut-energy devices;
• energize and proceed with testing, troubleshooting or positioning:
- identifying the energized area using isolation tape or physical boundary
indicators to prevent inadvertent access to or contact with the energized
equipment by unauthorized personnel;
- ensuring that Operating people entering the energized area are aware of the
hazards and the precautions to be taken to maintain a safe distance from the
energized area.
Once the testing or troubleshooting is completed, the LOTO Leader shall:
• check that controls have been returned to the neutral or off position, if modified or
activated during the task and/or the test;
• apply the equipment-specific LOTO work instructions to de-energize all systems
and continue the activities on machines and equipment.

7.3 Personal Locks removal

Anytime that a person has failed to remove his/her personal lock and is not
immediately available, the on site management shall attempt to locate and contact the
employee. If feasible, once contacted, the employee must personally remove his/her
lock.
If the employee is unavailable, the Maintenance Manager and the Area Leader shall
inspect the equipment or machine to evaluate its condition and the potential energy
hazards. Once the condition is cleared, the lock may be removed and activities can
proceed or the equipment or machine be restarted.
The Area Leader shall complete a HSE observation in the TSE System (or on paper) to
record the non-conformity, detailing the steps taken to ensure the equipment was
inspected and deemed safe to energize. The employee who has forgotten to remove
his/her lock will be notified by his/her supervisor before resuming work at the site.

8 Training

Specific training shall be provided for LOTO Leaders on lock-out or tag-out. The
training shall at least include recognition of applicable hazardous energy sources, the
type and magnitude of the energy available in the workplace, the methods and means
necessary to cut and control energy, and the knowledge and skills required for the safe
application and removal of the energy controls.
Operating people must receive an awareness training that includes:
• LOTO and Work Permit procedure;
• equipment-specific LOTO work instructions;

Control of Hazardous Energy (LOTO) 7/9

Tenaris

• avoid removing locks and tags;

• avoid restarting or reenergizing machines or equipment which are locked out or
tagged out.
In those Sites where only the tag-out procedure is applied, awareness training shall
include special emphasis on the correct use and limitations of tags and the prohibition
to remove, bypass or ignore them when attached to energy-isolating devices.
Retraining shall be provided for LOTO Leaders and Operating people whenever:
• there are changes in their job assignments, machines, equipment or processes or in
the energy control procedures.
• incidents, or inspections show this is necessary.
Annual refresher training shall also be planned for all LOTO Leaders and Operating
people.

9 Periodic Inspections

At least annually, Area Leaders and Maintenance Managers with the support of the
HSE Site Manager shall conduct an inspection of the:
• LOTO and Work Permit procedure;
• equipment-specific LOTO work instructions;
• LOTO Leaders’ list
to ensure that procedures are being followed and to identify and correct any deviations.
The inspection shall be conducted using an inspection checklist recorded in the TSE
System (or on paper).

10 Records

The following records shall be maintained:

• Employee training, retraining and annual refresher training;
• LOTO and Work Permit procedure;
• equipment-specific LOTO work instructions;inspections.

Control of Hazardous Energy (LOTO) 8/9

Tenaris

11 Definitions and Abbreviations

The "Glossary" is the source for general definitions and abbreviations. The following
ones are specific of the present procedure.
LOTO Leader: a person who locks out and/or tags out machines or equipment
Operating people: employees and contractors required to perform activities on
machines or equipment.
Cut-Energy element (or device): a mechanical device that physically prevents the
transmission or release of energy, including but 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 ungrounded supply conductors, and in addition, no pole can
be operated independently;
• a line valve;
• a block or blank.
and any similar device used to block or isolate energy.
Push-buttons, selector switches, and other types of control circuit devices are not cut-
energy elements.

12 Reference Documents

• U.S. Occupational Safety and Health Administration (OSHA) Regulation 29 CFR

1910.147

Control of Hazardous Energy (LOTO) 9/9