LOTO, “Clam Shells”, OSHA, and “substantial”

To follow up on the post from yesterday regarding the use of these “lockout devices”, I was reminded by many of you in the same camp as me, that these devices are also highly questionable when we look at their ability to meet the “substantial“ requirement.  These safety pros all agreed that the use of these devices, and in fact any plastic lockout device, comes under great scrutiny at their companies.  They were quick to agree that these plastic clam shells would never be permitted, although several of them did say that metal ones may pass their test, but would still not allow these lockout devices to be used.  Unfortunately, I am not at liberty to call out company names, but these are major employers around the globe. 

1910.147(c)(5)(ii)(C) Substantial –

1910.147(c)(5)(ii)(C)(1) Lockout devices. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.

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