I am not trying to start another LOTO fight about Lockout vs Tagout, but for those who do work in the state of KY, it is important to know that KY-OSHA does NOT allow an employer to utilize TAGOUT when the device can accept a lock. This is different than what Federal OSHA allows. Federal OSHA allows Tagout in lieu of Lockout as long as the employer can demonstrate that the Tagout provides FULL employee protection equivalent to Lockout. In the 2008 LOTO CPL this was termed “Tag-Plus”.
Here is the language from 1910.147:
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1910.147(c)(2)(ii) If an energy isolating device is capable of being locked out, the employer’s energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section. … 1910.147(c)(3)(ii) In demonstrating that a level of safety is achieved in the tagout program which is equivalent to the level of safety obtained by using a lockout program, the employer shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization. |
But here is how KY-OSHA amended their standard: