emphasis added by me and professionally speaking, this LOI is just “crazy talk” and why OSHA LOTO minimums should be viewed as just that… the ABSOLUTE MINIMUM! In this LOI, OSHA has established that using a “zip-tie” in the manner in which you would apply a lockout lock to an electrical disconnect would meet the “tag-plus” requirement under a “tag-out” program! So basically, if you were to hang a Tagout tag with a zip tie and run the zip tie through the disconnect handle so that the handle is secured in the OPEN/OFF position, this would suffice in meeting the “additional means” requirement under the tagout provisions. So today class, we have learned from OSHA that a zip tie is equal to a lock – NOT!, NO WAY!, NEVER! I swear in Question #2 that OSHA is accepting the mere placing of a zip tie on the “closed electrical panel box after placing the control switch in the off position and performing verification” as an “additional means of demonstrating full employee protection under the standard”. So the zip-tie is merely hanging a tagout tag from the box/cover and is not even through the handle and this meets compliance?!?!?! But again, meeting OSHA minimum in a life-critical procedure is NEVER a good idea! Here’s the scenario and questions with OSHA’s response… you may want to sit down before reading further!
Scenario: Maintenance and servicing activities are required and the plant owner hires a contractor to perform the work using ONLY a tagout program, although the devices ARE CAPABLE of being locked out. The electrical disconnect (i.e. control switch) [SAFTENG comment – the disconnect is the ISOLATION DEVICE – NOT a control device] is placed in the OPEN/OFF position, verification is performed, and the panel is closed and secured with a plastic zip tie at the point where a lock would be used. This is all done by a plant representative. At this point, the plant considers the equipment safe for contractors to sign onto the plant’s clearance and to begin maintenance or servicing activities.