As the debate continues about using “clamshells” as a lockout device, our behind-the-scenes discussions continue regarding OSHA’s use of the term “Substantial”. The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA’s definition of a “Lockout device”:
A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.
Most of us view a “lockout lock” as the lockout device and it is certainly a big part of it; however, if we take a step back and look at a lockout we see that many lockouts are using devices/equipment to actually hold the energy isolation device in the “safe” position. At least that is the case in the process industry where we use “shark leader” (e.g. cable) and chains to wrap around valves in order to “lock them out”. The point was made when the question was asked:
Would we allow operators to use dental floss or kite string around the valve(s) and then hang a lock on the floss or string?