WARNING! This variance applies ONLY to Nucor Steel Connecticut Incorporated at its Wallingford, CT facility and the SPECIFIC TASK listed. It can NOT be adopted by anyone else or any other workplace (NOT even another Nucor facility) in any fashion whatsoever.
This information is being shared for INFORMATIONAL PURPOSES ONLY as OSHA allows the use of a “Trapped Key Safety System” instead of traditional LOTO practices. I am sharing this so that anyone interested in using this type of system in lieu of LOTO can see the process one must go through to get the VERY SPECIFIC variance and the extras that OSHA requires under the variance. If it were me, I would have merely moved the energy isolation device (EID) from the Motor Control Room (MCR) to a location near the rolls so that traditional energy isolation methods could be utilized. This seems to be a lot of work for a single LOTO task with a much cheaper and easier solution. But here is the variance…