What Reg. 851 Applies To
Regulation 851 applies to industrial establishments under the OHSA, defined broadly to include manufacturing, processing, warehousing, and similar industrial settings. It does not apply to workplaces covered by sector-specific regulations:
- Construction projects (O. Reg. 213/91)
- Mines and mining plants (Reg. 854)
- Health care and residential facilities (O. Reg. 67/93)
- Farming operations (which generally fall under federal jurisdiction or specific agricultural regulations)
For most Ontario industrial workplaces, including manufacturing facilities, food and beverage processing plants, machine shops, and tool and die operations, Reg. 851 is the governing regulation for LOTO requirements.
How Reg. 851 Differs From Modern LOTO Standards
Reg. 851 was originally written before modern hazardous energy control standards became established. Its LOTO-relevant sections use different terminology and structure than CSA Z460:20:
- The regulation does not use the term "energy control procedure"
- It addresses LOTO requirements across multiple separate sections rather than in a single integrated framework
- It focuses on specific hazards (electrical, motion, energy release) rather than a unified hazardous energy concept
- It does not require annual audits or machine-specific written procedures with the specificity CSA Z460:20 requires
Most Ontario industrial employers who build LOTO programs to CSA Z460:20 are exceeding the bare regulatory requirements. The CSA standard fills in the operational details that Reg. 851 leaves to employer discretion.
For details on the Canadian standard, see CSA Z460:20 Explained.
Section 42: Lockout of Electrical Equipment
Section 42 addresses lockout for electrical equipment. The section requires that before any work is performed on or near electrical equipment that has been disconnected from its power source, the disconnecting means must be locked out using a lock or tagged out, and the equipment must be tested to verify that the power has been removed.
This section establishes the foundational electrical lockout requirement in Ontario industrial regulation. Compliance requires:
- A locking device on the disconnecting means
- Testing to verify isolation before work begins
- Tagging or signage identifying the lockout
In practice, employers should also follow CSA Z460:20 requirements for energy control procedures, which provide more detailed guidance on electrical isolation.
Section 75: Motion Stopped and Movement Blocked
Section 75 addresses moving equipment hazards. The section requires that before any work is performed on a machine that has parts that move, are capable of moving, or could move, the machine's motion must be stopped, and the moving parts must be blocked or secured to prevent inadvertent motion.
This section is particularly relevant for:
- Machines with raised loads that could fall under gravity
- Equipment with stored mechanical energy (springs, accumulators)
- Conveyor systems with parts that could move from gravity or residual drive
- Pneumatic or hydraulic systems with stored pressure
Compliance requires both stopping the motion (de-energization) and physically blocking the parts (such as pinning a raised platform or chocking a wheel).
Section 76: Locking Out to Prevent Starting
Section 76 is the core LOTO requirement in Reg. 851. It requires that:
- A machine, equipment, or process must not be operated unless any safety device or guard is in place and functioning
- When work is being performed, the equipment must be locked out to prevent any person from starting it
This is the section most directly aligned with modern LOTO concepts. Compliance requires:
- Identification of all start mechanisms
- Lockout devices on all start mechanisms
- Verification that the lockout is effective
Section 76 should be read together with Section 42 (electrical lockout) and Section 75 (motion stopped). Most modern programs cover all three under a unified hazardous energy control approach following CSA Z460:20.
Section 78: Energy Release for Drums, Containers, and Pipelines
Section 78 addresses stored energy in vessels and piping. The section requires that drums, containers, and pipelines must have energy released to atmosphere or otherwise rendered safe before any work is performed that could expose workers to that energy.
Relevant for:
- Pressurized chemical lines
- Steam systems
- Compressed gas systems
- Any pressurized fluid system
Compliance involves bleeding off pressure, draining fluids, purging contents, and verifying zero-energy state before work begins. CSA Z460:20 provides more detailed guidance on these procedures.
Section 119.13: Lockout for Confined Space Entry
Section 119.13 specifically addresses LOTO requirements when entering a confined space. The section requires that before any worker enters a confined space, all equipment, processes, or piping that could introduce hazards into the space must be locked out.
This section connects Reg. 851 (LOTO) to O. Reg. 632/05 (Confined Spaces). When workers enter a confined space, both regulations apply simultaneously. The lockout requirements under Section 119.13 are part of the broader confined space hazard control plan required under O. Reg. 632/05.
For more on confined space requirements, see Ontario Regulation 632/05 Explained.
Other Relevant Sections
Several other sections of Reg. 851 contain LOTO-relevant requirements depending on the specific equipment and operations:
- Section 50: Prevent supply of material to hoppers and silos (relevant for material handling equipment)
- Sections addressing specific machinery types (presses, conveyors, etc.) often include LOTO-related requirements
A comprehensive LOTO program built to CSA Z460:20 covers all of these requirements within a unified framework.
Penalties Under Reg. 851
Contravention of Reg. 851 is an offence under the OHSA. Maximum penalties are the same as for other OHSA contraventions:
- Up to $25,000 or imprisonment for up to 12 months, or both, for an individual
- Up to $500,000 per corporation per offence
In addition, Section 25(2)(h) of the OHSA's general duty clause applies. Employers are required to take every precaution reasonable in the circumstances for worker protection. Reg. 851 compliance does not automatically satisfy Section 25(2)(h): the general duty clause may require more.
For more on due diligence, see OHSA Section 25(2)(h) and Due Diligence Explained.
Common Mistakes Ontario Employers Make
In CCL's practice, the most common Reg. 851 LOTO compliance gaps include:
- LOTO programs that meet only the bare regulatory requirements without addressing the full scope of CSA Z460:20
- Failure to address Section 75 (motion stopped) requirements separately from Section 76 (locking out)
- Energy release procedures (Section 78) that are inconsistent or incomplete for stored energy systems
- Confined space programs that don't explicitly cross-reference Section 119.13 LOTO requirements
- Generic procedures that don't address machine-specific hazards
- No verification step (testing) after isolation
- Outside contractor coordination missing
How CCL Health & Safety Helps
CCL Health & Safety builds LOTO programs that satisfy Reg. 851 and conform to CSA Z460:20. We develop machine-specific energy control procedures, structure verification and audit programs, integrate LOTO with confined space requirements where they overlap, and produce documentation that holds up to MLITSD inspection.
For more on our LOTO program development services, see Lockout/Tagout Program Development.
Read the Source
Read the full text of Ontario Regulation 851: ontario.ca/laws/regulation/900851.