So this week my good friend “Jim” and I were talking about an “accepted practice” that has grown into an “industry practice” and how OSHA has definitely drawn the line on the “cord and plug” LOTO practice such that it does NOT include valves. This “practice” involves the concept of defining “exclusive control of an energy isolating device(s)” without the aid of a Lockout(s) or Tagout device(s). Last year, OSHA issued a letter (LOI) to a petrochemical company that asked the following two (2) questions: (I paraphrased the questions – see the full LOI at the end of this post for actual wording)
- Can I close a valve that goes to a pressure gauge and NOT lockout or tagout the isolation valve, since the valve is right next to the gauge that I will be changing?
- Can I close the inlet and outlet valve to a filter housing (or strainer), drain/vent the housing, all with valves right at the filter housing (e.g. arm’s reach) and change/clean the filter/strainer and not apply lockout or tagout devices to the isolation valves?
I will tell you upfront, I have lived this practice with BOTH of these exact scenarios and almost all of the companies I worked for allowed these tasks WITHOUT LOTO under some VERY STRICT and DEFINED circumstances. In fact, two of these facilities were VPP facilities and in one review this was looked at VERY HARD by the VPP assessors. We had Risk Assessments, written procedures, and VERY DEFINED TASKS where we allowed a SINGLE worker to do tasks (even LINE OPENING/EQUIPMENT OPENING task) without applying lockout devices to their isolation valve(s). We defined “exclusive control” as being