OSHA answers several questions related to “Group LOTO” practices

In this Letter of Interpretation (LOI), OSHA answers several common questions related to the practice of Group Lockout, such as:

  1. Does OSHA require all authorized employees who place their locks on the group lockbox to verify that the energy source was deenergized before performing servicing and maintenance work?
  2. How could a change of condition(s) (e.g., where the lock at the motor control center was tampered with, cut off, or otherwise any abnormal situation that could cause a concern to worker(s) doing work on the field equipment) be identified if all authorized employees do not verify that all energy sources were deenergized?
  3. Does the group lockbox have to be located in the same facility as the main energy isolation device?
  4. Does OSHA require group lockboxes to be securely mounted at a designated location (e.g., on the wall) in general industry facilities or construction sites?

Simple and easy answers are:

  1. NO,
  2. Depends,
  3. NO,
  4. See answer to #3

Here is OSHA’s explanations:  (Note I have added some text inside [ ] to clarify this

Scenario:

A group lockbox is positioned in an area remote from the main electrical energy isolation device.

The energy isolation device is located in the motor control center.

An authorized employee isolates and locks out the main energy isolation device in the motor control center.

That employee places the key to [lock placed on] the de-energized isolation device inside a group lockbox and places their lock and tag on the group lockbox and retains the key [to their personal LO lock].

Other authorized employees, who are also part of the work, place their locks and tags on the lockbox and retain their [personal LO lock] keys.

 

NOTE: some emphasis is by me and some links have been added for ease of access to referenced documents/sources

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