LOTO locks can be keyed alike. For example, equipment/field locks can all be keyed to a SINGLE key; however, personal/individual locks MUST BE individually keyed (e.g., 1 key – 1 lock). Before starting work ask yourself this simple but very important question: Do I have EXCLUSIVE/SOLE control of each and every isolation device protecting ME?
This is the fundamental premise of energy control (i.e., LOTO)! In other words, there is no way anyone could energize any of the energy sources while I am working because I have EXCLUSIVE CONTROL of every single isolation device protecting me.
We worked a Shutdown/Turnaround last year and we came across a “flip-flop” in the facility’s practice of “group lockout”. Someone, somewhere, somehow got it in their head that it was safe, compliant, perfectly acceptable to have “individual locks” with multiple keys. In other words, we came across dozens of group lockouts with multiple workers in the “group”, each having their own personal key to the single lock on the lockbox, while they’re working. Their argument was that “keyed alike locks” are allowed in group lockout.
Do you see their flip-flop? Let me explain…
Typically, group lockout is used when there are dozens of isolation points and many workers who will be working on the equipment. Rather than making each authorized worker place his/her personal LOTO lock on each isolation device, the equipment owner will apply LO locks on the isolation devices and place the key(s) into a lockbox, and then each authorized worker will place their personal lock on this lockbox to CONTROL the key(s) to the locks that secure the isolation devices in the safe position.
These LO locks that are used on the isolation devices can be individually keyed, OR they can all be keyed to a single key. Either way is ACCEPTABLE; we will either be placing a single key into the lockbox or dozens of keys in our scenario.
A lot of companies have learned that when a worker has dozens of locks and dozens of keys to these locks and they have to align each key with each lock (even with the keys and locks are labeled), this takes a lot of time. So they have gone to field locks that are in series, and all the locks in that series are KEYED ALIKE with just a single key.
Some companies have not gone to this KEYED ALIKE practice for their field locks, and hence, when they go and apply the locks to the isolation devices, each lock is INDIVIDUALLY KEYED. So when they are done with the field portion of their LOTO they will have dozens of keys they have to keep track of and then ensure they all make them into the lockbox. Where the hassle really comes is when the LOTO is being removed and the personnel has to find the correct key for each lock. Heck, some companies have not even taken the time to label their keys so they can be matched up to the locks. Yep, the worker will stand on the ladder with the dozens of keys and begin trying each key in the lock until he/she finds the key that works. They then move to the next LO lock and begin trying each key all over again. That is CRAZY and this is how LOTO gets its bad reputation amongst authorized employees and management alike.
But having a single lock on a lockbox for ten workers, each worker having their own personal key to this single lock, is NOT acceptable! Regarding PERSONAL/INDIVIDUAL LO locks, each one MUST BE individually keyed!
So yes, the field/equipment locks used in Group LOTO can be “keyed alike”; however, those workers on the job MUST have EXCLUSIVE CONTROL over each of those isolation devices protecting them, and this is done with INDIVIDUALLY KEYED locks AND the key(s) to the individual lock(s) are in the POCKET of the worker(s) doing the work.