This week OSHA issued citations to a steel mill involving Lockout/Tagout (LOTO) and the one citation that caught my eye revolved around a “group lockbox” situation. The citation reads
“On and before 6/18/2012, the employer did not ensure that authorized employees used a personal lockout device to lock the group lockout box. Each authorized employee had a universal key for opening the group lockout boxes throughout the XXXXXXXX roller bearing plant.”
OSHA issued the citation against 29 CFR 1910.147(f)(3)(ii)(D), which is the “Group Lockout” section and it requires…
Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.
Although the standard is not explicit in stating, LOTO is based on the premise that when you or I place our lockout device on the energy isolation device, or in this case, the group lock box, ONLY you can remove your lock, and ONLY I can remove my lock. When EACH Authorized worker has a “universal key,” this defeats the intent of LOTO and provides very little protection. When it comes to Personal LOTO locks, we MUST practice:
1 LOCK – 1 KEY
I will also dispute the idea of the “safety manager maintains a spare set of LOTO keys”. This practice is just asking for trouble! I know my confidence level would drop considerably if I knew a spare key to my personal LOTO lock was available. Folks, if a key to a LOTO lock is lost, a spare key should NOT be used to open the lock. The lock should be CUT OFF (using the lock removal procedure unless the worker is standing right there with their lock) so it can not be used again. We have seen on more than one occasion where a key is lost, and the spare is provided, and the worker continues to use the spare as his/her replacement key, only to have the original key found. Now, the worker does not have EXCLUSIVE CONTROL of their lockout device. I can hear the doubters now… “do you believe that someone would be so dumb/brazen to use the found key to unlock a LOTO lock?”. Sadly, YES, I do think improperly/poorly trained workers will do it, and I have seen it done before!
Click Here to see the actual Citation from OSHA regarding the “Universal Key” issue.