Why so many try to make such a simple safety process so difficult has puzzled me for years! Even in Group LOTO, each employee is protected by the LOTO MUST have EXCLUSIVE CONTROL of the devices protecting them. It is that simple. This organization should be embarrassed for asking these questions, especially when their scenarios involve only three (3) authorized employees.
Scenario 1:
Three (3) authorized employees are replacing a pump.
First, each energy source is de-energized and locked out by an employee in plant operations.
Then, the plant operations employee places the keys for each lockout device in a group lockbox in the plant control room.
Next, the supervisor verifies that the equipment is in a zero energy state and places his/her personal lock on the lockbox in the control room.
The three (3) authorized employees then perform the pump replacement under the protection of the crew supervisor’s lock and do NOT use their personal lockout locks.
Is scenario 1 in compliance with 29 CFR § 1910.147(f)(3) if the supervisor kept a written log of the three authorized employees and ensured that all were accounted for and clear of the equipment after the work was completed prior to the removal of his/her personal lock?