Let’s set the record straight… “Line of sight” is HALF THE REQUIREMENT, and this term is NOT in any official language from OSHA, nor does OSHA recognize it!
We see this all the time…a LOTO procedure talks about cord and plug equipment not needing to be locked out if the worker is in the “line of sight” of the plug. Let’s look at the term “exclusive control.”
OSHA’s formal definition for “exclusive control” appeared in the 2008 LOTO CPL and states…
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Exclusive Control Under the exclusive control of the employee means that the authorized employee has the authority to and is continuously in a position to prevent (exclude) other individuals from re-energizing the machine or equipment during his servicing or maintenance activity. |
You will notice that the definition contains NO MENTION of “line of sight” type language but rather states the worker “is continuously in a position to prevent (exclude) other individuals from re-energizing the machine or equipment.”
This clarifies that the worker must be IN A POSITION to prevent someone from energizing the source.
Another VPP story…
I was dinged with a 90-day item in one of my VPP assessments as my LOTO program stated the worker had to be in “arms reach” but did not mention “in line of sight.” One of the OSHA CSHOs asked about a disconnect that is through an open doorway but on the other side of the wall. You could reach around the wall and touch the disconnect, but it was not within your line of sight, allowing someone to walk up and inadvertently energize the source without your knowledge. We quickly revised our LOTO procedure (and sent out alerts and retrained everyone within the week) to state the definition of “exclusive control” means
- “in line of sight, AND
- within arms reach at all times.”
A final thought on “exclusive control” is that the term means that only ONE WORKER HAS FULL/EXCLUSIVE CONTROL of the plug. This means that when this exception is exercised, ONLY ONE WORKER CAN BE DOING the servicing and maintenance. There is NO WAY TWO WORKERS can have “exclusive control” of the same plug simultaneously WITHOUT applying personal lockout locks! Do not fall for the argument that “Bob would never plug in the machine while he and Tom are working together.” If you think this would never happen, subscribe to my Incident Alerts for six months and count the incidents where a worker mistakenly energized a piece of equipment they thought their co-worker was no longer working on. Suppose two or more workers are working on this cord and plug equipment. In that case, ALL the workers exposed to the release of energy or injury from unexpected start-ups will need to apply their personal lockout lock onto a locking mechanism around the plug. The locking mechanism has to be on the PLUG and NOT over the outlet the plug is usually plugged into!!!! Click Here to see an example of a plug-isolation device.
Again…Line of sight is NOT an official term and does NOT translate into “exclusive control of an energy isolation device”!