I think there is a difference between a lock out for mechanical work and one for electrical work. My comment was based on a lockout for electrical work. There is an OSHA letter interpretation that says the pilot light type devices, even the ones with multiple lamps are not suitable to prove de-energization for electrical work.
OK I got the impression that the thread was largely about non-electrical work. My apology.
Yes I received the same impression about "pilot light type devices, even the ones with multiple lamps are not suitable to prove de-energization for electrical work" after reading
this. By the way, the device described in this directive is different to DeadEasy. Included in this OSHA advice is that:
"The verification provision of paragraph (d)(6) of 29 CFR 1910.147 requires an affirmative step on the part of an authorized employee to determine if the hazardous energy is effectively isolated, and relying solely on the LED device would not satisfy this requirement. One effective method of compliance would be a deliberate attempt by an authorized employee to start up the equipment"
OK so pilot lights
and Try Start is OK, but so too is just Try Start. There is also mention in
Compliance Directive CPL 02-00-147 that:
"only through the use of a test instrument [by a "qualified employee" under 29 CFR Part 1910, Subpart S] or a deliberate attempt to start-up a machine that the authorized employee will be able to ascertain whether the steps taken to isolate hazardous energy"...."
The use of a test instrument is particularly applicable for verifying isolation and deenergization in the case of jammed equipment"
I would have thought that most motors and the loads they drive could possibly jam, not to mention other faults that may yield an incorrect Try Start result.
So it seems that on one hand OSHA says Try Start is OK, but on the other hand OSHA is aware of accuracy issues relating to Try Start and advocate a test instrument approach? Of course if you go down the track of only using the instrument approach, that in the case of MCCs and field equipment, then you might be exposed to isolating equipment at the MCC and working on incorrectly isolated (possibly energised) equipment in the field. Identifying the right field equipment is one area where a Try Start might have helped.
So could it be that OSHA's fall back position in the event of an accident is that they recommended both Live-Dead-Live check and Try Start for each isolation? Perhaps most businesses could not afford to do both and in that way, should there be an accident, OSHA is in the clear and the site owner is to blame?
So the big question is...
Should a site owner follow OSHA's recommendation of Live-Dead-Live check and Try Start[FONT=Tahoma, Verdana, Helvetica, sans-serif] to protect themselves from legal blame in the rare event of an accident [/FONT]or[FONT=Tahoma, Verdana, Helvetica, sans-serif] should the site owner consider less expensive approaches that similarly reduce the risk to near zero levels, such that no accident is likely to occur and therefore legal aspects are irrelevant.[/FONT]
I guess that's a judgement for each site owner to make.
I'd be happy to learn of any errors in the above as I really want to understand the topic.