It is becoming more common to find facilities using or at least “experimenting” with some “car seal” program or, as some call it, the “Lock Open – Lock Closed” program. These are the programs where a valve has been identified as a safety critical valve and needs to either stay closed or open until certain procedures have been carried out. To ensure this, the facility will either place some seal on the valve or use a lock to keep it in a safe position.
I encourage every facility to have this type of car-seal program, as most facilities covered by a commercial insurance carrier are most likely already using some variation of this on their sprinkler risers.
Do you have locks on your sprinkler risers to prevent them from being closed?
The problem with these programs is that the facility often uses lockout locks to lock its sprinklers and other critical valves in their safe positions. When we explain that using LOTO locks is NOT allowed for these purposes, we get some pretty weird looks and sometimes a few choice words to follow! But let me explain why using LOTO locks in a “car seal” or “Lock Open – Locked Closed” program is not compliant and should NOT be allowed.
First, let’s examine what OSHA says about our LOTO locks. OSHA has been pretty clear over the years that each facility must identify its LOTO locks by color, shape, or size. Most facilities choose to use color as their method to identify a lock as a LOTO lock. But OSHA also states that once we have identified a LOTO lock (by either color, shape, or size), ONLY that lock can be used for LOTO, AND that lock can NOT be used for anything else but LOTO! Here are the parts of the OSHA standards covering these requirements:
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; …
1910.147(c)(5)(ii)(B) Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; …
OSHA has also issued a letter of interpretation stating the following about using LOTO locks on equipment that is not actually being worked on (2006 – 10/11/2006 – Use of LOTO device on equipment placed in “out of service” status not related to servicing or maintenance). Here is the meat of that LOI:
Question:When equipment is placed in an “out of service” status for business or production purposes (e.g., poor efficiency, recycled, sold, etc.) and not related to servicing or maintenance, is the use of lockout/tagout devices for this purpose a violation of 29 CFR 1910.147(c)(5)(ii)?
Reply:Yes. As you have stated in your letter, applying lockout/tagout devices to equipment that was placed out of service for business or production reasons would not “. . .preserve the integrity of the Lockout/Tagout program.” The preamble to the final rule states, at 54 Federal Register36671 (Sept. 1, 1989):“. . . the sight of a distinctive lock or tag will provide a constant message of the use that the device is being put to and the restrictions which this device is intended to convey. If lockout or tagout devices are used for other purposes they can lose their significance in the workplace. For the energy control procedure to be effective, these devices must have a single meaning to employees: “Do not energize the equipment when such a device is affixed to it.”
Locks used in a “Car Seal” or “Lock Open – Lock Closed” program is NOT considered “servicing/maintenance”; in fact, the main purpose of a “car seal” program is to ensure these valves are not accidentally deviated from their safe position for maintenance without meeting some stringent requirements first. Of course, we can use these valves as energy isolating valves and place a LOTO lock on them when needed; we can NOT use a LOTO lock on them while they are NOT being used for controlling energy during servicing and maintenance.
So as you can see, using our LOTO locks to Lock Open or Closed valves for purposes other than LOTO (e.g., service and maintenance) will be a violation of OSHA’s Control of Hazardous Energy standard. Our LOTO locks must be sacred within the facility and strictly reserved for controlling hazardous energy during servicing and maintenance. Allowing them to be used for anything else will only reduce their significance.
I suggest using plastic tie wraps (rated for UV exposures) that are color-coded, along with a color-coded tag that looks NOTHING like any tag used in the LOTO program. Using these plastic pull-ties and different tags will ensure OSHA compliance and maintain the integrity of our LOTO program. But if your insurance company requires your sprinkler risers to be locked OPEN, then you will want to consider using one program for all your valves, and thus you will be forced to use locks. In this case, pick some odd color that is clearly different from your LOTO lock(s) color (some facilities will use multiple colors in their LOTO program).
I have used pink locks before, and they worked perfectly. They really stood out, and it was easy to train all personnel, including contractors, about my LOTO and car seal locks.
Remember, LOTO locks are NOT general-duty safety locks! We may need a lock for safety reasons (such as our sprinklers and car seal program), but that is NOT to be confused with a LOTO lock. We MUST keep our LOTO locks sacred and prevent confusion from creeping into the program.