In the Final Rule, OSHA determined that lockout is a surer means of ensuring equipment is de-energized than tagout and is the preferred method. However, the Agency also recognized that tagout will nonetheless need to be used instead of lockout where the energy control device cannot accept a locking device. Where an energy control device has been designed to be “lockable”, the standard REQUIRES that lockout be used unless tagout can be shown to provide “full employee protection,” that is, protection equivalent to lockout. But what does OSHA consider to be “locakable”?
According to OSHAs Regulatory Impact Analysis, approximately 90% of all electrical energy isolating devices (disconnects) and about ??? of all energy control valves are currently capable of being locked out. The capability for lockout does not necessarily mean that the equipment has an actual hasp or other physical attachment point for a lock. For example, using chains can effectively enable the lockout of many types of valves, even if the valve does not have a specific locking point. For equipment of this type, OSHA believes that the lockout capability should be used to maximize the protection afforded by this standard.
A critical element of the standard is determining whether an energy-isolating device is “capable of being locked out.” In its most limited sense, a device would be considered to be “capable of being locked out” either :
- if it was designed with a hasp or other integral part to which or through which a lock could be affixed, or
- if it has a locking mechanism built into it.
However, OSHA’s use of the term for the purposes of the standard is somewhat broader, without being overly expansive. OSHA considers equipment to be capable of being locked out if the use of a locking mechanism will NOT require the employer to:
- DISMANTLE,
- REBUILD,
- REPLACE, OR
- ALTER
in a PERMANENT way, the energy control capability of the isolating device.
For example, although some valves and other energy-isolating devices are not designed with an integral means of being locked, they can be secured with chains, blocking braces, or wedges, which can then be locked. Because extensive equipment modification is unnecessary in this situation, OSHA views this type of lockout as both technologically and economically feasible.
However, a specific energy-isolating device is not considered as having the capability of being locked out if the device is installed within a cabinet, enclosure or cutout box containing several other energy-isolating devices or valves and the only means of preventing access to the energy-isolating device or valve is to lock the doors of the cabinet, enclosure or box. In this instance, tags MUST be used and attached to the specific energy isolating device and NOT SIMPLY to the cabinet or enclosure door or cover.
Source: LOTO Preamble