The state of NC has its own OSHA Plan (e.g., State Plan), but they use the Federal OSHA standards as their enforcement tools. As like most state plans, their website is a buffet of safety materials that are free for the taking. In fact, I used some of their materials when I was a safety manager in industry years ago. But recently I was truly let down by NC-OSHA! I was doing a PSM/RMP audit at a facility and we were reviewing their energy control program (e.g. LOTO) and I took issue with the fact that the facility had not identified their Lockout Locks by either a COLOR, SHAPE, or SIZE as required by 1910.147(c)(5)(ii)(B). They were using a hodge-podge of locks of all different shapes, sizes, and colors and had merely used a label maker to label each Lockout lock with the words “Lockout Lock”. The labels were yellow with black font. Granted, interviews indicated that everyone could identify the facility Lockout Locks, but this was because each lock had the words “Lockout Lock” on it. I did find some workers using the same brand, size, and color locks on some jobs AND THEY DID NOT HAVE THE YELLOW LABELS on them so I wrote a finding against their program/practice and referenced 1910.147(c)(5)(ii)(B)…
Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized.
Only to have this sent to me today in rebuttal of my finding… (hard to argue the site did anything wrong when they have this supporting documentation from NC-OSHA)
Now granted, the locks shown below both have a BLUE BAND around them and are silver in color. If the program identifies the Lockout Locks as “silver with a blue band,” and these are the ONLY locks used for Lockout, AND I find none of these locks on toolboxes and lockers in the facility, then I’d say they are compliant. Even the fact that the locks are different sizes is not an issue as long as the written program, and the training identify lockout locks as “silver with a blue band”.
But just looking at the picture, it seems that NC-OSHA’s LOTO Training presentation indicates that a “yellow label” with the letters “LOTO” on it being placed on a lock makes it a Lockout Lock. They even reference 1910.147(c)(5) on the slide. After explaining and using federal compliance documents (CPL and Preamble) and having them read some of my LOTO articles explaining the means to identify lockout locks SINGULARLY, I won my position. But we should not be having these debates in 2017.
NOTE: I did download the entire presentation from NC-OSHA Website just to be sure we were not missing something in their delivery. I have been set up before with only half the story so I wanted to be sure of what I was seeing. In fact NC-OSHA’s presentation does in fact state that the lockout locks must be SINGULARLY identified; however, it makes no mention of the COLOR, SHAPE, or SIZE requirement. It could be that NC-OSHA does not enforce the COLOR, SHAPE, or SIZE requirement in (c)(5)(ii)(B), I have reached out to them to see.
