Lock out/Tag out

[maryl]

I need an answer quickly! A Contractor & Subcontractor Safety Manual thatI just received contains a LOTO policy stating that their Maintenance Dept. will apply, and be responsibile for the removal of their lock and tag when one of our employees needs to work on de-energized equipment. I say "NO! NO! NO!" Can anyone give me a reference to NEC, NFPA 70E, or other, that specifically states that the person who is actually working on the equipment is the one with sole responsibility to perform the LOTO or at least apply their personal lock with the Maintenance Dept.'s.

OSHA uses the term "Authorized person".

[petersonra]

it is not unusual for the plant to apply a lock in such a situation. in most cases the individuals doing the work would also apply a lock.

if the number of people working on the locked out device makes that impractical, you can do something else.

this is not a NEC issue though.

[ October 28, 2005, 11:14 AM: Message edited by: petersonra ]

[don_resqcapt19]

Does it say that the worker cannot place his own lock in addition to the "owners" lock? In many industrial applications, the plant people must place the first lock to prevent problems with accidental shutdown of their processes, but the work must also place his personal lock.
Don

[bphgravity]

I believe the NFPA 70E (section 120) places the responsibility of the LOTO procedure to be established by the employer. I don't believe there is a specific requirement that only the person performing the work install and/or remove the device.

I also don't believe OSHA (1926.146) madates this either.

I definetly feel this is a good work practice and should be employed into the LOTO procedures, however, if the company has a documented and established procedure otherwise, I think it is compliant with minimum safety requirements.

[charlie b]

I would want the LOTO procedure to clearly state the actions that the maintenance department personnel must take, to verify the work is complete and the area is clear, before they are permitted to remove the tag. I would insert a step requiring the signature of the worker as a prerequisite for removing the tag.

[maryl]

Thanks for all your timely help. I will instruct our empolyees that they also need to attach their lock in addition to the customer's. It makes sence that the customer would want to be the ones to de-energize and LO seeing they know their machinery better than we would.

Again, thanks.

[don_resqcapt19]

From an OSHA letter ruling.
[quote]Question 2:

Does an on-site agency, such as an utility, have the right to restrict or limit the use of lockout/tagout procedures at their facility to only one procedure, specifically their own, when multiple contractors with individual procedures are involved?

Reply:

Lockout/Tagout procedures used by outside personnel (contractors, etc.) are covered by 1910.147(f)(2). This standard requires on-site employers and outside employers to inform each other of their respective lockout/tagout procedures. Furthermore, an on-site employer is required to ensure that his personnel understand and comply with restrictions and prohibitions of the outside employer's energy control procedures. Outside employers are not required to use on-site employer lockout/tagout procedures.[quote]

[petersonra]

however, if you choose not to follow thier policy they could decide to get another contractor.

it seems to me that we rely way too much on what some government rule says rather than just talking to each other and working out a solution that is acceptable to all concerned.

[don_resqcapt19]

Bob,
My point is that they can't stop you from putting your own lock on while you are working on the equipment, and if they wouldn't let me do that, they would be looking for another contractor, because I won't let any of my guys work without having their own lock on the equipment.
Don

[sparky_magoo]

I carry my own lock. I used it today at a sewage treatment facility. The city facility guys also put their own lock on. If they would have told me I can't put my oen lock on, I would have walked away. I'm sure my boss would have backed me up.