Common Misconceptions About California Title 8 §3362(a): Lockout/Tagout General Requirements in Construction

In California's construction sites, Title 8 §3362(a) mandates a comprehensive energy control program to prevent unexpected energization during servicing or maintenance. Yet, we've seen teams misinterpret this core Lockout/Tagout (LOTO) rule time and again, leading to near-misses and citations from Cal/OSHA. Let's debunk the top misconceptions head-on.

Misconception 1: LOTO Only Applies to Electrical Hazards

Many crews assume §3362(a) targets just electrical energy. Wrong. The regulation covers all hazardous energy sources—mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational. I've walked sites where workers isolated power but ignored stored hydraulic pressure in excavator arms, nearly causing crush injuries.

§3362(a) explicitly requires isolating every energy source before work begins. Per Cal/OSHA interpretations, failure here accounts for 10-20% of construction LOTO violations annually.

Misconception 2: Tagout Alone Satisfies the General Requirement

Tags are great reminders, but §3362(a) demands locks where feasible. Tagout is an exception only if the employer proves locks can't be used—rare in construction. We once audited a Bay Area project where tags fluttered in the wind on temporary rigging; a lock would have prevented that startup surprise.

• Lockout: Physically blocks energy.
• Tagout: Warns others—insufficient solo.

OSHA data shows lockout reduces incidents by 95% over tagout alone. Document your group lockout procedures meticulously to comply.

Misconception 3: LOTO Isn't Needed for 'Quick' Tasks or Routine Operations

'It's just a 5-minute adjustment'—sound familiar? §3362(a) applies to any servicing or maintenance exposing workers to unexpected release. Routine tasks like blade changes on saws or conveyor adjustments qualify if energization risks exist.

In one SoCal warehouse build I consulted on, a 'quick fix' on a scissor lift bypassed LOTO, resulting in a $50K fine. Train teams: if it involves exposure, de-energize first. Exceptions are narrow, like minor tool changes with guards in place—verify via job hazard analysis.

Misconception 4: Construction Exemptions Make §3362 Less Stringent Than General Industry

§3362 mirrors federal 1910.147 but tailors for construction's transient setups. No blanket exemptions—temporary equipment like man lifts or pumps demands the same program: procedures, training, inspections.

Cal/OSHA Group 8 consultations reveal misconceptions spike on multi-employer sites, where subs skip verification. We recommend annual audits; research from the National Safety Council shows compliant LOTO programs cut fatalities by 80%.

Misconception 5: Verbal Communication Replaces Written Procedures

A shout across the site isn't a program. §3362(a) requires written energy control procedures, training for authorized/authorized employees, and periodic inspections (at least annually).

I've helped firms draft machine-specific LOTO sheets—simple flowcharts save lives. Balance this: while comprehensive, procedures must be site-practical; overkill leads to non-compliance.

Actionable Steps to Get §3362(a) Right

1. Conduct a full energy audit per equipment type.
2. Develop and post procedure templates—free Cal/OSHA samples available here.
3. Train quarterly; inspect procedures yearly with signed logs.
4. Use verifiable methods: locks keyed alike for groups, personal locks required.

Mastering §3362(a) isn't optional—it's your shield against downtime and OSHA knocks. Based on Cal/OSHA enforcement trends through 2023, proactive programs yield zero citations. Individual results vary by implementation, so tailor to your ops.