Cord-and-Plug Lockout/Tagout (LOTO) Exception
The Problem
Lockout/Tagout (LOTO) procedures are designed to protect workers from hazardous energy during maintenance or servicing of equipment. However, an exception applies to cord-and-plug connected equipment. Misunderstanding this exception can result in serious injury or even death—especially when residual energy isn’t fully neutralised or when the plug is not under exclusive control. Today, we’ll clarify the conditions under which this exception applies and how to ensure safety on site.
Identify the Hazards
Residual Energy:
- Equipment such as compressors or machinery with capacitors may retain energy after being unplugged.
- Electrical energy stored in capacitors or backup systems can still pose a risk.
Loss of Plug Control:
- If the plug is not under the direct control of the person doing the work, it could be accidentally reconnected.
Multiple Workers Involved:
- If several people are servicing the equipment, and communication fails, re-energising the equipment too early can lead to serious harm.
Safety Practices and Preventative Measures
1. Ensure Complete De-Energisation:
- Unplugging must eliminate all hazardous energy sources.
- Example: Compressors may still hold pressure in tanks or lines, or electrical equipment may retain charge in capacitors.
- Always test to confirm residual energy has been released before starting work.
2. Maintain Exclusive Control of the Plug:
- The plug must remain:
- Within arm’s reach.
- In the worker’s direct line of sight.
- Under their exclusive control at all times.
- Within arm’s reach.
- If more than one person is working on the equipment, this exception does not apply. Each worker must apply their own lock.
3. Default to Lockout If Unsure:
- If you’re uncertain about energy release or control of the plug, always use a full lockout procedure.
- When in doubt—lock it out.
Real-Life Case or Scenario
On one site, a worker servicing a machine relied on the cord-and-plug exception. Unbeknownst to them, capacitors within the unit still held charge. While the machine was unplugged, they suffered a serious electric shock due to residual energy. This incident could have been avoided by verifying full de-energisation before commencing work.
Employee Responsibilities
- Confirm all energy (including stored energy) is discharged before beginning work.
- Keep plugs under exclusive personal control during servicing.
- If plug control is not possible, apply full lockout/tagout.
- Report unclear or unsafe procedures to your supervisor.
Employer Responsibilities
- Train workers on when the cord-and-plug exception applies and how to use it safely.
- Provide access to appropriate testing tools and personal lockout equipment.
- Encourage safe decisions and promote a “when in doubt, lock it out” culture.
Discussion & Questions
- “What challenges have you encountered when applying the cord-and-plug exception?”
- “Has anyone had to switch from cord control to full lockout? What prompted the decision?”
Commitment/Action Plan
Let’s commit to using the cord-and-plug exception only when all conditions are clearly met. Take the time to verify that all energy has been fully neutralised and that the plug is always within your control.
Wrap-Up
The cord-and-plug exception can simplify low-risk work, but safety must never be compromised. If in doubt, lock it out. Understanding the conditions and applying safe practices will protect you and your team. Thank you for making safety your priority.
Standards Overview
Under WorkSafe New Zealand’s Health and Safety at Work (General Risk and Workplace Management) Regulations, PCBUs must ensure the control of hazardous energy during servicing and maintenance.
Cord-and-plug exceptions are only valid when:
- The equipment is fully de-energised by unplugging, and
- The plug remains under the exclusive control of the person performing the task.
Disclaimer
These toolbox talks are provided for informational and educational purposes only and are not a substitute for professional legal, health and safety, or regulatory advice.
The content reflects recognised best practices and general industry standards as at the date of publication. However, it may not be applicable to all workplace environments or specific operational contexts.
It is the responsibility of the Person Conducting a Business or Undertaking (PCBU), as well as officers, workers, and other duty holders under the Health and Safety at Work Act 2015 (HSWA), to ensure compliance with all relevant laws, regulations, and WorkSafe New Zealand guidance.
The authors, presenters, and distributors of this toolbox talk disclaim all liability for any loss, damage, or injury arising from the use or reliance on the information provided. Users should seek advice from a suitably qualified health and safety professional or legal advisor for guidance tailored to their specific circumstances.
Always follow your organisation’s policies, procedures, and safe work practices to manage risks and maintain a safe and healthy workplace.
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