The state of NC has its own OSHA Plan (e.g., State Plan), but they use the Federal OSHA standards as their enforcement tools. As like most state plans, their website is a buffet of safety materials that are free for the taking. In fact, I used some of their materials when I was a safety manager in industry years ago. But recently I was truly let down by NC-OSHA! I was doing a PSM/RMP audit at a facility and we were reviewing their energy control program (e.g. LOTO) and I took issue with the fact that the facility had not identified their Lockout Locks by either a COLOR, SHAPE, or SIZE as required by 1910.147(c)(5)(ii)(B). They were using a hodge-podge of locks of all different shapes, sizes, and colors and had merely used a label maker to label each Lockout lock with the words “Lockout Lock”. The labels were yellow with black font. Granted, interviews indicated that everyone could identify the facility Lockout Locks, but this was because each lock had the words “Lockout Lock” on it. I did find some workers using the same brand, size, and color locks on some jobs AND THEY DID NOT HAVE THE YELLOW LABELS on them so I wrote a finding against their program/practice and referenced 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; and additionally, in the case of tagout devices, print and format shall be standardized.
Only to have this sent to me today in rebuttal of my finding… (hard to argue the site did anything wrong when they have this supporting documentation from NC-OSHA)