1910.147 says the following regarding contractors performing LOTO inside our facilities:
1910.147(f)(2)(i)
Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures.
1910.147(f)(2)(ii)
The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program.
Seems simple enough???
First… this “inform each other of their respective lockout or tagout procedures” is a safety-trap!!
Most contractors are NOT authorized under the host site’s LOTO program. Heck, the contractors may not even be familiar with the types and magnitude of energies involved or the energy isolation devices to be used. Even with machine-specific procedures in place, a contractor most likely will not know the location of the energy isolation devices. BOTTOM LINE… it is our hazard. Therefore, it is our responsibility to perform the LOTO.
Second… imagine a facility with a centralized maintenance team (a team that travels from one unit/department to another). In this facility, contractors are allowed to LO equipment using a lock that is colored yellow. The site does not use Yellow in their program, so employees are NOT trained to identify yellow locks as LO locks. So this “informing” requirement can stretch far and wide and if not done well, places a lot of workers at serious risk.
To eliminate these risks, it is just simpler and safer to have authorized personnel lockout the equipment, place the keys in a lockbox and have each contractor place a personal lock on said lockbox.