We continue to see businesses using many methods to identify their lockout locks, many of which are NOT acceptable to OSHA. 1910.147(c)(5)(ii)(B) states:
Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: color; shape; or size…
Most businesses use color, and we can have multiple colors in our program; as long as these colors are spelled out in the written program AND communicated in training (including contractor training). OSHA wants ZERO confusion when a worker/contractor walks through the plant and comes across a lockout lock to know that this is a lockout lock.
We also have to identify who placed the lock there (1910.147(c)(5)(ii)(D).
We can do this through a tag or by using a permit system and a stamped or engraved lock with a trackable number back to the permit (OSHA calls this a “Master Tag”). Using items like model numbers or brand names CAN be part of your description, but the description MUST be included with either color, shape, or size. Also, don’t forget that once we have identified a color, shape, or size of lock to be used for LOTO, ONLY these locks can be used for LOTO and NOTHING else.
Be very careful playing games with the “shade of color.” When we say red is a LOTO lock color, be careful to allow other shades of red to be used. I often find red as a listed color in the LOTO program, and on each sprinkler riser, a red lock is used to secure the valves in the open position.
The facility knows this is not part of LOTO but used red on all their fire protection devices without thinking about the LOTO issue. OSHA issued one LOI on this matter in 2002, and it is useful if you are having trouble identifying your LOTO locks.
Click Here to see the LOI.
If you have LOTO questions, send them to me, and I will give you my best answer and provide supporting documentation from OSHA or ANSI.