In this Letter of Interpretation (LOI), OSHA answers several common questions related to the practice of Group Lockout, such as:
- Does OSHA require all authorized employees who place their locks on the group lockbox to verify that the energy source was deenergized before performing servicing and maintenance work?
- How could a change of condition(s) (e.g., where the lock at the motor control center was tampered with, cut off, or otherwise any abnormal situation that could cause a concern to worker(s) doing work on the field equipment) be identified if all authorized employees do not verify that all energy sources were deenergized?
- Does the group lockbox have to be located in the same facility as the main energy isolation device?
- Does OSHA require group lockboxes to be securely mounted at a designated location (e.g., on the wall) in general industry facilities or construction sites?
Simple and easy answers are:
- NO,
- Depends,
- NO,
- See answer to #3
Here is OSHA’s explanations: (Note I have added some text inside [ ] to clarify this
Scenario:
A group lockbox is positioned in an area remote from the main electrical energy isolation device.
The energy isolation device is located in the motor control center.
An authorized employee isolates and locks out the main energy isolation device in the motor control center.
That employee places the key to [lock placed on] the de-energized isolation device inside a group lockbox and places their lock and tag on the group lockbox and retains the key [to their personal LO lock].
Other authorized employees, who are also part of the work, place their locks and tags on the lockbox and retain their [personal LO lock] keys.
NOTE: some emphasis is by me and some links have been added for ease of access to referenced documents/sources
Question 1: Does OSHA require all authorized employees who place their locks on the group lockbox to verify that the energy source was deenergized before performing servicing and maintenance work?
Response: NO
When a primary authorized employee verifies isolation, all other authorized employees may, BUT ARE NOT REQUIRED TO, verify energy isolation during group lockout.
In accordance with OSHA’s Compliance Directive 02-00-147:
When a primary authorized employee verifies isolation, all of the authorized employees participating in the group LOTO must be informed of their right also to verify the effectiveness of the lockout measures and must be allowed to personally verify that hazardous energy sources have been effectively isolated, if they so choose. An authorized employee who opts to verify the effectiveness of the isolation measures must perform this verification after affixing his personal lockout or tagout device to the lock box and before performing servicing/maintenance activities.
Question 2: How could a change of condition(s) (e.g., where the lock at the motor control center was tampered with, cut off, or otherwise any abnormal situation that could cause a concern to worker(s) doing work on the field equipment) be identified if all authorized employees do not verify that all energy sources were deenergized?
Response: Intentional tampering with a lockout or tagout device is not a known or predictable hazard and is not covered by the OSHA control of hazardous energy regulation. However, employers are required to use specific procedures to ensure continuity of hazardous energy control, including provision for orderly transfer of lockout or tagout devices between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.
Question 3: Does the group lockbox have to be located in the same facility as the main energy isolation device?
Response: NO
OSHA does NOT require the group lockbox to be located in the same facility or secured at a designated location.
Employers must develop and use a procedure that affords employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device.
OSHA’s Compliance Directive 02-00-147 provides examples of various procedures that can be utilized during group lockout/tagout, including the use of master lockbox/tagbox and the use of satellite lockbox/tagbox.
Question 4: Does OSHA require group lockboxes to be securely mounted at a designated location (e.g., on the wall) in general industry facilities or on construction sites?
Response: See the response to question # 3 above.
CLICK HERE for the LOI