In the USA, our Occupational Safety and Health Administration (OSHA) has an exception to Lockout/Tagout (LOTO) for “cord and plug” equipment. The exception, 1910.147(a)(2)(iii)(A), states:
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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. (emphasis added by me) |
So a worker who has “EXCLUSIVE CONTROL” of the plug on a “cord and plug” piece of equipment AND the ONLY form of HAZARDOUS ENERGY is the electrical that passes through the cord and plug, which the employee has EXCLUSIVE CONTROL of does NOT have to apply a lock or tag to an isolation device. By the worker having EXCLUSIVE CONTROL of the plug to the SOLELY SOURCE of hazardous energy, the employee has the same level of safety as they would by applying a lockout device to an energy-isolating device. Sound simple enough????? Well… something as simple as this causes many serious issues and exposes many workers to unnecessary risks.
We have seen some really wild definitions of “exclusive control,” which turned out to be very far from what a rational safety professional would define as “exclusive control.” For example, we have seen policies that state only “line of site” is considered “exclusive control,” which leaves much to be desired! I do not know of many safety professionals who would agree that just because a worker can see the disconnect 150 feet away, the worker has “exclusive control”!
Over the years, I have attempted to define exclusive control as the “line of sight AND arms reach” of the energy isolation device. Combining distance and line of sight REQUIRES the worker to be in a position that would PREVENT another worker from activating the isolation device. A perfect example of needing both line of sight and distance is a worker using an isolation device just around the corner from the machine. He/she may be able to reach around the corner and touch the isolation device, BUT THEY CAN NOT SEE THE ISOLATION DEVICE; therefore, a LOCK IS REQUIRED. So even when the device is only a couple of feet away, the employee may NOT have exclusive control!
Well, our friends to the north, WorkSafe BC, have done a much more thorough job at defining exclusive control, and I suggest that we could all benefit from their definition, regardless of where you live and work.
WorkSafe BC states the following:
WorkSafeBC will accept that a worker has “exclusive and immediate control” of the energy isolating device if ALL of the following criteria have been met:
1) the machine or equipment has ONLY ONE set of operating controls,
2) the equipment is STOPPED,
3) ALL POTENTIAL sources of energy are reduced to a ZERO ENERGY STATE (ZES),
4) the energy isolating device remains in the FIELD OF VISION of the worker at ALL times while the task is being done and
5) the energy isolating device is located so ANY move by another worker to activate the control will be IMMEDIATELY OBVIOUS to the worker doing work on the machine or equipment.
Although they leave little room for interpretation on #5, a company would be well served to adopt this definition into their LOTO program.