Lockout/Tagout (LOTO)

What the law actually requires in Australia and New Zealand

No Australian law is called "lockout tagout". What the law requires is that a PCBU manages the risks of plant, and two model WHS Regulations carry most of that weight. Regulation 210, Operational controls, requires that operator controls are "able to be locked into the 'off' position to enable the disconnection of all motive power". Regulation 213 covers maintenance and inspection of plant.

The method sits in section 4.5, "Isolating energy sources", of Safe Work Australia's model Code of Practice, Managing the risks of plant in the workplace (December 2023). That section is the national reference. NSW adopts it as SW03838, and SafeWork NSW's own isolation factsheet cites clause 210 of the Work Health and Safety Regulation 2017 (NSW) as the source of the duty.

Victoria is not a model WHS state. Its duty sits under the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017, and WorkSafe Victoria publishes its own eight-step isolation procedure that reaches the same place by a different legal route. In New Zealand, WorkSafe NZ publishes machine lockout guidance and directs businesses to the joint AS/NZS 4024 Safety of Machinery series.

This page is general information, not legal advice. Electrical isolation, confined spaces and construction sites each add requirements of their own, so confirm the detail with your state or territory regulator.

Sources: Safe Work Australia: Managing the risks of plant in the workplace, Code of Practice (December 2023) · SafeWork NSW: Isolation of plant, lock-out / tag-out · WorkSafe Victoria: isolate, de-energise, lockout and tagout plant · WorkSafe New Zealand: keeping workers safe with machine lockouts

The eight-step lock-out process

Safe Work Australia's model Code calls the lock-out process "the most effective isolation procedure" and sets out eight steps. WorkSafe Victoria publishes the same sequence. The order matters: each step exists because the one before it can leave energy in the machine.

Step eight is the one worth reading twice, because the Code is explicit about what it does not prove. Failure to reactivate the plant "may mean the main power has been isolated. However, it does not guarantee all stored energies have dissipated." A machine that will not start can still hold pressure in a hydraulic line, a raised attachment on a worn cylinder, or a charged capacitor bank. Releasing those is a separate act, not a by-product of the test.

Sources: Safe Work Australia: Managing the risks of plant in the workplace, section 4.5 · WorkSafe Victoria: isolate, de-energise, lockout and tagout plant

The ten energy sources the Code lists

Most isolation failures are not a failure to lock out. They are a failure to notice a second source. The model Code lists ten, and three of them (solar panels, gravity and radiation) have no switch to throw.

Sources: Safe Work Australia: Managing the risks of plant in the workplace, section 4.5 · SafeWork NSW: Isolation of plant, lock-out / tag-out

Danger tags, out-of-service tags, and who may remove a lock

A tag is not an isolation device. The model Code is unambiguous: "A tag should not be used on its own as an isolation device; only a lock is effective in isolating the energy source." Tags carry information to other people. The lock is what makes the plant safe.

The two tag types do different jobs. A personal danger tag says a named worker is working on this plant. SafeWork NSW requires it to be durable and securely fixed, to state the warning including any specific hazard, to be dated and signed by the worker or workers carrying out the work, and to be attached prominently at each isolation point. An out-of-service or caution tag says the plant itself is defective or unfit for use, states the nature of the defect, and is removed by a competent person only after the defect is rectified.

Removal is the step with the clearest rule and the most breaches. Safe Work Australia: "Tags and locks should only be removed by the person who applied them or by the supervisor after consultation with the signatory of the tag." WorkSafe Victoria: "Only the person whose name is written on a personal danger tag should remove the tag." WorkSafe NZ: "Each lock should be removed only by the person who attached it following the correct removal sequence." Where that person cannot return, the Code requires removal under a management-approved procedure rather than a judgement call on the day.

Keys follow the same logic. Each worker involved in the maintenance, cleaning or repair should have a lock, tag and key for each isolation point, and there should be no duplicate key for any lock except a master key kept secure and used only in an emergency. Where several energy sources must be isolated to shut the plant down safely, the single key to each lock-out device should be held by the same person. Where more than one worker is on the plant, each attaches their own padlock to a hasp, or the keys go into a box that each worker locks separately.

Sources: Safe Work Australia: Managing the risks of plant in the workplace, section 4.5 · SafeWork NSW: Isolation of plant, lock-out / tag-out · WorkSafe Victoria: isolate, de-energise, lockout and tagout plant · WorkSafe New Zealand: keeping workers safe with machine lockouts

The AS/NZS standards regulators name

Australian and New Zealand regulators point to the same joint standards series rather than to OSHA 29 CFR 1910.147, which is the United States rule and does not apply here. These are the parts named in the guidance above.

Sources: SafeWork NSW: Isolation of plant, lock-out / tag-out · WorkSafe New Zealand: keeping workers safe with machine lockouts