OSHA answers more LOTO questions

  • If servicing and/or maintenance is not being performed, while employees are awaiting the parts necessary to complete the repairs, can the LOTO locks be removed and replaced with either “Continuity” locks or “Out of Service” locks?
  • Does this section of the compliance directive apply only to shift or personnel changes, or can it be applied to other scenarios (e.g., waiting for parts)?
  • Does the application of a LOTO lock in the above scenario qualify as servicing and maintenance?
  • Given the same scenario as above, if the equipment was still in place, but not in use, could a LOTO lock still be used?
  • Can a LOTO lock be used to prevent the energization of a circuit to an abandoned or removed piece of equipment and, if yes, how is this different than “out of service”?
  • Can a LOTO lock be used to prevent the energization of equipment that is waiting for parts and, if yes, why is this not considered “out of service”?
  • Is there any guidance on how long a LOTO lock can be left on a piece of equipment while waiting for the part?

Background: A company has three (3) different types of locks that you define as follows:

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