5 Common Misconceptions About OSHA 1910.147 Lockout/Tagout in Airports

Airports buzz with energy—literally. From baggage conveyors to ground power units, hazardous energy sources lurk everywhere under OSHA 1910.147, the Control of Hazardous Energy standard, aka Lockout/Tagout (LOTO). Yet, in my years consulting for airport ops teams, I've fielded the same myths that trip up compliance. Let's debunk them with airport-specific clarity, straight from the standard.

Misconception 1: LOTO Only Applies to Electrical Hazards

Think LOTO is just for flipping breakers on runway lighting? Wrong. OSHA 1910.147 covers all hazardous energy: electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational. In airports, this hits baggage handling systems (pneumatics), aircraft tugs (stored mechanical energy), and even jet bridge hydraulics.

I've walked facilities where teams skipped LOTO on a conveyor because 'it's not electric.' One unexpected startup later, fingers crushed. The standard mandates energy control for any servicing/maintenance that exposes workers to injury—period. Check 1910.147(c)(1) for the full scope.

Misconception 2: Tags Are Enough—Locks Aren't Always Needed

Slap on a tag, call it safe? Not in OSHA's book. Tagout is a temporary fix only if locks aren't feasible, and even then, it must match lockout effectiveness per 1910.147(c)(3). Airports love tags for quick fixes on shared equipment like people movers, but without locks, you're courting violations.

We once audited a major hub: tags fluttered everywhere on fuel carts, no locks in sight. FAA might overlap for flightline, but OSHA citations rolled in anyway. Pro tip: Document why tagout-only, train everyone, and inspect tags every shift.

Misconception 3: Low-Power Equipment Gets a Pass

'That cart's too small to hurt anyone.' Famous last words. OSHA doesn't care about horsepower—1910.147 applies if uncontrolled release can cause injury. Airport examples? Golf carts with batteries, small pumps on de-icing rigs, or even manual baggage carts with potential pinch points.

• Gravitational energy from elevated platforms.
• Residual pressure in airline ground carts.
• Spring-loaded doors on service vehicles.

Quantify it: If it moves unexpectedly during service, LOTO it. OSHA's interpretation letters confirm this—no size exemption.

Misconception 4: FAA Rules Trump OSHA LOTO in Aviation

Aviation's FAA domain, right? Partially true, but OSHA 1910.147 stands firm for ground ops and maintenance not purely flight-critical. Airports aren't exempt; 29 CFR 1910 covers general industry, including terminals and ramps.

I've advised ops where FAA Part 145 repair stations assumed blanket immunity—OSHA disagreed during a surprise audit, fining for un-LOTO'd engine stands. Harmonize: Use joint procedures. Reference OSHA's 2004 letter to airlines clarifying overlap.

Misconception 5: Annual Training Boxes OSHA's Requirement

One-and-done training? Nope. 1910.147(c)(7) demands retraining on changes, incidents, or audits showing gaps—at least annually for most programs. Airports' 24/7 shifts and contractor flux amplify this.

Picture this: A night-shift mechanic, untrained on new conveyor LOTO, bypasses it. Injury follows, audit reveals expired certs. We recommend quarterly refreshers plus procedure-specific drills. Track via digital platforms for proof—OSHA loves records.

These myths don't just risk fines (up to $15,625 per violation, willful higher); they endanger lives amid airport chaos. Audit your LOTO program against 1910.147's elements: procedures, devices, training, inspections. For deeper dives, OSHA's free eTool or NFPA 70E crosstabs help. Ground those misconceptions—your team's safety depends on it.