In this last part of 2018, I have been on a LOTO crusade; I have been to 12 different facilities since August to help them understand LOTO. Some projects were complete new builds, some were to help with implementing Group LOTO, and a few were to training company safety professionals on the OSHA requirements so they can better understand the minimum requirements. But not just over these past several months, but instead over my entire career, I have seen the same situation managed differently and for me it is SIMPLE…
LOCKOUT is the REQUIREMENT, except when the isolation device will not accept a lock.
We can argue about Tagout vs. Lockout later, but for this article, I want to challenge a practice that I feel does NOT meet the minimum OSHA requirements.
So our policy/Practice is Lockout, except when the isolation device will not accept a lock – pretty standard practice in print, but in reality is where we drift. So follow me in my logic and let me know where you disagree, either from a compliance position and/or a safety position.
Here is the “exception” to LO:
(c) General
(1) Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source, and rendered inoperative.
(2) Lockout/tagout.
(i) If an energy isolating device is not capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
When an authorized employee uses a “tag” in lieu of a “lock” in this scenario, is it not meeting the definition of a “tagout”? Here is OSHA’s definition of “tagouot”:
Tagout. The placement of a tagout device on an energy isolating device, in accordance with an established procedure, to indicate that the energy isolating device and the equipment being controlled may not be operated until the tagout device is removed.
Remember the policy and practice at the facility is LOCKOUT whenever the device will take a lock, AND ONLY when the isolation device will not accept a lock is “tagout” allowed.
My questions:
- When the authorized employee uses a tagout tag instead of a lockout lock, is this a “tagout”?
- If you said “yes” to #1, then does your program/practice require “Tag+” to be implemented when a lock can not be used in order to comply with 1910.147(c)(3)(i)-(ii)?
- Bottom line is using a “tag” in lieu of a “lock” a “formal tagout” and does the written program, practices and training have to meet OSHA’s special requirements for “Tagout”, even though the use of a tag maybe once every five years and only on 1-2 isolation devices.
My position is that when a “tagout” is done, REGARDLESS of the reason (s), ALL of OSHA’s Tagout Requirements are REQUIRED. This means:
- the written program covers the use of tags, their limitations, and their means of acceptable attachment
- the training program for affected and authorized (and “other) personnel covers all the items in 1910.147(c)(7)(ii)
- Tag+ must be instituted in this scenario.
- Periodic Inspection program must cover both Authorized and Affected employees when this scenario is in play
My last challenge is…
The plant was built in 2009, and management and workers alike tell you that some of the equipment must be tagged out as there is no way to use a lock. Does this construction date raise a flag when coupled with the comments from management and authorized employees? Check out 1910.147(c)(2)(iii)… to me, this is crystal clear. A plant newly constructed in 2009 should NOT have isolation devices that will not take a lock – EVEN when the company bought “used equipment” for the new plant.
What say you?