It’s an internal OSHA term for when an employer chooses to use TagOut (TO) instead of LockOut (LO). The TO has to be “equally effective” as a LO; this “Tag Plus” must be demonstrated to show that the TO is equal to an LO.
1910.147(c)(2)(ii) If an energy isolating device is capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.
1910.147(c)(3)(ii) In demonstrating that a level of safety is achieved in the tagout program which is equivalent to the level of safety obtained by using a lockout program, the employer shall demonstrate full compliance with all tagout-related provisions of this standard together with such additional elements as are necessary to provide the equivalent safety available from the use of a lockout device. Additional means to be considered as part of the demonstration of full employee protection shall include the implementation of additional safety measures such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the likelihood of inadvertent energization.
If the employer uses tagout devices on lockable energy isolating devices, CSHOs need to carefully evaluate the Full employee protection (Tags Plus), §1910.147(c)(3), provisions to determine whether the tagout program provides an equivalent level of safety to a lockout program.
Lockout and Full Employee Protection [Tags Plus]
Lockout is a more effective means of ensuring the de-energization of equipment; it is the preferred method because lockout-based safety programs are less susceptible to human error, and tagout devices have inherent physical limitations. Therefore, if the energy isolating device is capable of being locked out, the standard requires lockout unless the employer can demonstrate that a tagout system will provide Full Employee Protection (“Tags Plus”) — i.e., a level of
protection that is equivalent to that provided by lockout. See 29 CFR §1910.147(c)(2)(ii). In order for the employer to demonstrate that a tagout program is as protective as a lockout program for a lockable piece of equipment or machine, that employer will need to show additional elements which bridge the gap between lockout and tagout. It is permissible for employers to implement a tagout program provided that all applicable full employee protection requirements
are met.
The term Full Employee Protection is set forth in §1910.147(c)(3), and it requires compliance with all tagout-related provisions of the standard, which includes attaching the tagout device at the same location that the lockout device would have been attached. Also, as explained in the preceding section on “Tagout,” inherent tagout program limitations necessitate the implementation of additional program and specification requirements when an employer opts to use a tagout program instead of a lockout program.
A key element in demonstrating that the tagout program provides equivalent protection to a lockout program is the standard’s provision that the tagout program provide at least one additional safety measure. In other words, at least one added safety measure must be used in addition to tagging the energy isolation device to prevent unexpected re-energization. This independent, additional measure is designed to protect an employee from injury or death through the inadvertent activation of an energy isolating device associated with human error, inadvertent contact, the loss or detachment of a tag, or any other limitation of tags. Such additional safety measures might include the following:
- Locking, blocking, or barricading a controlling switch.
- Closure of a second in-line valve (e.g., double block and bleed);
- Removal of a valve handle to minimize the possibility that machines or equipment might be inadvertently energized or started;
- Removal of an additional isolating circuit element (e.g., fuse);
- Opening of an extra disconnecting device (e.g., disconnecting switch; circuit breaker);
- Opening and then racking out a circuit breaker;
- Grounding of an electrical circuit, if the grounding practice would protect the employee if the tagged isolating device were operated; or
Any additional control measure (“Tags Plus”) must be integrated into an energy control program through sound hazard-specific analyses on a case-by-case basis. For example, the blocking of a control switch as an additional measure to tagging an electrical disconnect may be an effective second layer of protection for preventing the mechanical activation of a machine, but this block may be an inadequate “Tags Plus” measure for the same machine’s hydraulic or pneumatic hazardous energy sources.
These independent control measures, when effectively incorporated into the employer’s energy control program and enforced through regular supervision,
provide employees with an independent, redundant control measure. In short, this additional control measure provides the authorized employee using a tagout program with a “second layer of protection” in the event the tagout device for the primary isolating device is defeated.