We continue to see businesses using tagout when locks can be used and they dispute us when we attempt to explain to them that locks MUST be used when they can, UNLESS the employer can show that their tags are EQUALLY effective as a lock. OSHA REQUIRES Tag-Plus-One when using a tag in these situations.
The recent CPL for LOTO states:
A key element in demonstrating that the tagout program provides equivalent protection to a lockout program is the standard’s provision that the tagout program provide at least one additional safety measure. In other words, at least one added safety measure must be used in addition to tagging the energy isolation device to prevent unexpected re-energization. This independent, additional measure is designed to protect an employee from injury or death through the inadvertent activation of an energy isolating device associated with human error, inadvertent contact, the loss or detachment of a tag, or from any other limitation of tags. Such additional safety measures might include the:
1. Closure of a second in-line valve (e.g., double block and bleed);
2. Removal of a valve handle to minimize the possibility that machines or equipment might be inadvertently energized or started;
3. Removal of an additional isolating circuit element (e.g., fuse);
4. Opening of an extra disconnecting device (e.g., disconnecting switch; circuit breaker);
5. Opening and then racking out a circuit breaker;
6. Grounding of an electrical circuit, if the grounding practice would protect the employee if the tagged isolating device were operated; or
7. Locking, blocking, or barricading a controlling switch.
Any additional control measure (“Tags Plus”) must be integrated into an energy control program through sound hazard-specific analyses on a case-by-case basis. For example, the blocking of a control switch as an additional measure to tagging an electrical disconnect may be an effective second layer of protection for preventing the mechanical activation of a machine, but this block may be an inadequate “Tags Plus” measure for the same machine’s hydraulic or pneumatic hazardous energy sources. Refer to page 3-37 and beyond for more or contact me or your OSHA office for help. LOTO is a LIFE SAVING procedure when developed, implemented and managed properly.