Clearing up a couple of LOTO myths

Over the last several years the SAFTENG team has been seeing some interesting concepts when it comes to Lockout/Tagout applications and methods.  I want to air these out and get some dialogue started so that everyone can understand the errors of these myths…

1) LOTO does not apply to electrical energy under 50 volts.  WRONG!  I know where this one started, and it is the WRONG application.  It came from the electrical standards, where 50 volts and lower are exempted from some of the electrical safety requirements.  However, 50 volts is NOT a zero energy state, and ALWAYS REMEMBER, it is not the volts that kill – it only takes milliamps to kill.  ZERO ENERGY STATE is ZERO – not 50 volts or less.

Comments from the LOTO Zen Master – Dennis Collins, regarding my #1 above.  

To discuss lockout/tagout from an OSHA enforcement standpoint, you have first to recognize that:

1. Lockout requirements are contained in two separate regulations: 1910.147 and 1910.333
2. The coverage for each of the standards is entirely separate and distinct.
3. 1910.333 Electrical Safety Related Work Practices (ESRWP) covers servicing of electrical equipment.
4. The hazard that we are protecting against under ESRWP is electrical in nature, such as shock and electrocution.
5. 1910.147 Control of Hazardous Energy/LOTO covers servicing of machines and equipment.
6. 1910.147 covers all hazards from all energy sources with the exception of hazards associated with servicing electrical conductors.

In other words, you can NEVER have a violation of 1910.147 where the hazard to which employees are exposed is electrocution. Electrocution hazards will always be covered by 1910.333. 1910.147 will protect employees from hazards associated with all other energy sources (pneumatic, hydraulic, etc.). 1910.147 will also cover the isolation and lockout of electrical energy, but only for purposes of addressing non-electrical hazards (such as mechanical hazards) that may be created by that electrical energy.

With respect to the 50-volt plateau as a lockout consideration:

1. Under 1910.147, voltage is irrelevant. The hazards that you are protecting against are not electrical. If a potential hazard exists due to failure to isolate an electrical source, then a violation exists whether above or below 50 volts.
2. Under 1910.333 (ESRWP), the 50-volt level is a consideration but not an absolute lockout/no lockout limit. 1910.333(a)(1) does indicate that live electrical parts operating at less than 50 volts need not be deenergized, however, it further states “if there will be no increased exposure to electrical burns or to explosion due to electric arcs.” Therefore, there is no requirement to isolate and lock out equipment for electrocution potential purposes, but there may be a need to do so for other hazards. As an example, contact of a metal object (like a ring) with electrical equipment at 40+ volts could cause a burn. The hazard associated with the failure to isolate a potential source of sparking in a classified hazardous location should be apparent.

2) LOTO does not apply to compressed air as long as it is under 30 psi.  

WRONG!  This myth originated in 1910.242, requiring that compressed cleaning air be regulated down to 30 psi.  Again, 30 psi can be LETHAL in many situations, and it is undoubtedly not a ZERO ENERGY STATE.

3) Using LOTO locks/tags to prevent an operator from opening/closing a valve that may overflow a vessel is OK.  

This one is seen quite often, but it cuts deep to the core of LOTO and is a clear violation of 1910.147(c)(5)(ii)… 

Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes.  

Using LOTO locks and/or tags to control production or quality needs is prohibited.  OSHA is concerned that these uses will only detract from the significance of the LOTO locks and lessen their respect.

4) Two or more authorized employees can maintain EXCLUSIVE CONTROL of a plug at the same time.  

IMPOSSIBLE.  The exception that OSHA allows is found in 1910.147(A)(iii)(2)(A) and permits an authorized employee to forgo using a Lockout lock or tag as long as he/she can maintain exclusive control of the plug while doing their servicing and maintenance.

This standard does not apply to the following:    Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.

The “misapplication” of this exception is just poorly understood.  Essentially, OSHA is NOT providing us an “exception” to LOTO, but rather, OSHA is merely admitting that if I have the plug to the machine/equipment in my pocket or under my foot, I have EXCLUSIVE CONTROL.  One problem is when the machine is so large that the cord is too short for the worker to maintain it in their EXCLUSIVE CONTROL at ALL TIMES while working – thus, the plug MUST BE LOCKED OUT.  

Another common issue is when we come across two more workers claiming to have EXCLUSIVE CONTROL of the same plug without either of them using a Lockout lock.  Let’s be clear here: if I have the plug in MY POCKET, then I have EXCLUSIVE CONTROL of the plug, and NO ONE ELSE can make that claim!  So, bottom line, this “exception” applies to a lone authorized employee ONLY, and if multiple workers need to perform servicing and maintenance on the machine/equipment, a lockout device will need to be applied to the plug, and EACH AUTHORIZED EMPLOYEE will place a personal LO lock on the lockout device to achieve EXCLUSIVE CONTROL.

5) A “periodic inspection” is the same regardless of the isolation methods (LO vs. TO).  

WRONG!  OSHA makes a CLEAR and DISTINCT difference in the requirements for periodic inspections when conducted on a Lockout vs. a Tagout.  Here are the differences:

If an “authorized inspector” is doing an inspection and the isolation involves a tagout on an energy isolation device, then that inspection MUST INCLUDE a review with the AFFECTED EMPLOYEE; an inspection done on an isolation that is ALL LOCKOUT need only involve the AUTHORIZED EMPLOYEE(S).

Does anyone have any others they’d like to add to this list?  Any questions or challenges to my five?