OSHA’s Control of Hazardous Energy (lockout/tagout) standard has a paragraph called “Outside personnel (contractors, etc.)” and although it indicates that a contractor CAN use their own LOTO program within our facilities, I will attempt to convince you that it is MORE challenging than many may have considered. Here is what 1910.147 states about “Outside personnel (contractors, etc.)”…
1910.147(f)(2) Outside personnel (contractors, etc.).
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.
Although there are only two (2) simply stated requirements in the standard, it is the DIFFICULTY of implementing these two simple requirements. Let’s look at EACH requirement:
- 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.
So OSHA requires the facility to share their LOTO program details/requirements with EACH contractor. But this may prove to be more difficult than it sounds, especially if the contractor will be working in different units/departments and/or your facility has several hundred (or thousands) of employees working in these units/departments. Consider this…
Lockout locks must be identified by COLOR, SHAPE, or SIZE. Then ONLY those locks can be used for LOTO and they can NOT be used for any other purpose. We then MUST train ALL “affected employees” and “other employees” on how to identify these LOTO LOCKS and their prohibition against tampering with them.
Remember this:
1910.147(c)(7)(i)(C) All other employees whose work operations are or may be in an area where energy control procedures may be utilized, shall be instructed about the procedure, and about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out.
For example, lets say our facility LOTO locks are RED in color; we then train ALL personnel on site that could come across one of these red LOTO locks that this is how we identify our LOTO locks. This includes TRAINING CONTRACTORS on the color of the LOTO locks.
Now a contractor arrives on site and their LOTO program uses YELLOW locks. Keep in mind that we have NOT trained our employees to recognize YELLOW as a LOTO Lock color, so if we want to allow this contractor to use their YELLOW locks within the facility, then we MUST TRAIN all “affected employees” and “other employees” who could come across these YELLOW LOTO locks on how to identify these LOTO LOCKS and their prohibition against tampering with them.
Imagine if we had 20 plus contractors on site with their OWN LOTO programs and each one had a different means (color, shape or size) to identify their LOTO locks. This would become very confusing to all workers and this is EXACTLY what OSHA was trying to avoid with the SINGULARLY IDENTIFIED locks (1910.147(c)(5)(ii).
A contractor places his YELLOW LOTO lock on an electrical disconnect and along comes a facility employee (who has been trained that RED is the LOTO lock color) and sees the yellow lock on the disconnect. The facility employee was called to trouble shoot a machine that would NOT start after shift-change. The facility employee finds the yellow lock on the disconnect and on the lock there is a name which he does not recognize. His orders are to get the machine running for production. Since he does not recognize the yellow lock as a LOTO lock, what do we think he could do to get this machine running???
Simple Solution
In many plants, including ALL of my former facilties, we managed this situation by NEVER allowing contractors to place their LOTO locks out in the plant areas. The ONLY place a contractors’ lock would ever be placed is on a lockbox which is CLEARLY LABELED “LOCK BOX” and identified in the LOTO program and EVERYONE’s training. The contractors lock MUST also be accompanied with a specially specified Tagout Tag, which contains:
- their name,
- company name, and
- a 24-hr phone number
ALL energy isolations on facility equipment are completed by using facility LOTO locks (RED) and by facility authorized employees. LOTO’s involving authorized personnel, OTHER THAN facility authorizer personnel, will be done as a GROUP LOTO (1910.147(f)(3) with ALL authorized personnel conducting the servicing and/or maintenance will place their PERSONAL LOTO LOCK on the “lockbox”. The lockbox is then CONTROLLED by a facility supervisor (1910.147(f)(3)(ii)(A) so as to ensure no one who is NOT part of the LOTO can have access to the lockbox. Equipment that is NOT owned/operated by the facility (i.e. owned and operated by contractors) will be MOVED OFF-SITE to be worked on if LOTO is necessary.
By doing ALL LOTOs in this manner, we ensure that ALL on-site personnel who come across a LOTO lock in the field will be able to RECOGNIZE that lock as a LOTO LOCK and understand their prohibition against tampering with them. In other words, ALL LOTO locks used in the field will be the facility’s RED LOTO LOCKS and it is these locks that are included in the CONTRACTOR ORIENTATION and the facility “affected employee” and “other employees” LOTO training.
Allowing contractors to use their LOTO locks in the field will REQUIRE some extensive training for all other on-site personnel (facility personnel and all the other on-site contractor companies personnel). This becomes virtually impossible to manage and increases risks, but it is legal per 1910.147(f)(2).