Whenever we talk about OSHA’s Lockout/Tagout (LOTO) standard, we almost always have to talk about its machine guarding and electrical standards. One crucial requirement in OSHA’s electrical standards, as it relates directly back to LOTO, is … (emphasis by me)
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1910.303(f)(1) Motors and appliances Each disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. or NFPA 70 110.22 Identification of Disconnecting Means (A) General Each disconnecting means shall be legibly marked to indicate its purpose unless located and arranged so the purpose is evident. In other than one- or two-family dwellings, the marking shall include the identification of the circuit source that supplies the disconnecting means. The marking shall be of sufficient durability to withstand the environment involved. |
I will go on record and say that EVERY ISOLATION DEVICE used to control hazardous energy MUST be identified by a UNIQUE IDENTIFIER.
Growing up in the chemical industry, this was a fundamental requirement for all assets, as PSM/RMP drove this from a P&ID and MI perspective. But when it came to writing machine/equipment-specific energy control procedures or completing a unique energy isolation control plan, having these unique identifiers attached to the isolation/relieving device ensured that personnel knew precisely which device to use.
I have written several times about incidents where workers locked out the incorrect breaker or electrical disconnect simply because they were NOT labeled and were in a different order than the equipment they were looking at. Or the incidents where a worker used the wrong pressure gauge to “verify a ZES.”
I firmly believe that all assets should be identified by a unique identifier, if for nothing else, for accounting/inventory reasons. Use these identifiers in our LOTO programs to help ensure that our employees use the correct devices to achieve a ZES.