Clarification on Group LOTO requirements

Seriously, in the year 2021/2022, we still have these questions asked of OSHA about a standard that has been in place since the mid-1980s.

Scenario 1:

Three (3) authorized employees are working on a pump.

Each energy source is de-energized and locked out by an employee in plant operations.

Then, the plant operations employee places the keys for each lockout device in a group lockbox in the plant control room.

Next, the supervisor verifies that the equipment is in a zero energy state and places his/her personal lock on the lockbox in the control room.

The three authorized employees then perform the pump replacement under the protection of the crew supervisor’s lock and do NOT use their personal locks.

 

Oh HELL NO!  SAFTENG’s official answer; OSHA was much more diplomatic in their response, but it too was a NO!

 

Scenario 2:

It is the same description of work as stated above, but this time, the Supervisor uses a “satellite lockbox” in which he places his personal lock’s key inside, and then each of the workers places their personal LO lock onto the satellite lockbox.

Now, by using the satellite lockbox, each of the three workers doing the work EACH has EXCLUSIVE CONTROL of the isolation devices protecting them.

Here is the OSHA response:

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