ARRGH!! LOTO Using red/white Tape!!

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brother

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Ok, I just got to vent!! just here recently we had another electrician get shocked/burned and rushed to the hospital last week! . And to top this off, Im argueing with an OLD timer saying that the special 'tape' (red white tag out) is NOT sufficient lock out tag out. He claims the 'Powers that be' SAYS its ACCEPTABLE so long as we all accept that 'practice.

Well Im having trouble finding it, but I remember reading somewhere that says that if you can put a lock on it, then LOCK IT OUT!! the only way tape, or tags is allowed by themselves is IF its IMPOSSIBLE to put on a lock. Well this situation is a breaker we CAN put on a lock, they are just not doing it.

Can someone help me on this issue where its found so I can show Him in BLACK AND WHITE whats ??? Thanks!!
 
brother said:
Ok, I just got to vent!! just here recently we had another electrician get shocked/burned and rushed to the hospital last week! . And to top this off, Im argueing with an OLD timer saying that the special 'tape' (red white tag out) is NOT sufficient lock out tag out. He claims the 'Powers that be' SAYS its ACCEPTABLE so long as we all accept that 'practice.

Well Im having trouble finding it, but I remember reading somewhere that says that if you can put a lock on it, then LOCK IT OUT!! the only way tape, or tags is allowed by themselves is IF its IMPOSSIBLE to put on a lock. Well this situation is a breaker we CAN put on a lock, they are just not doing it.

Can someone help me on this issue where its found so I can show Him in BLACK AND WHITE whats ??? Thanks!!
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Nope, because he is right. If the company wants to they can allow using a tag system in leiu of locks, but it has to be in thier written LOTO program. Your black and white answers lies in your companys LOTO written program.
 
zog said:
Nope, because he is right. If the company wants to they can allow using a tag system in leiu of locks, but it has to be in thier written LOTO program. Your black and white answers lies in your companys LOTO written program.
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Then what do you have to say about IWIRE'S comment here Post #3??

http://forums.mikeholt.com/showthread.php?t=107577&highlight=loto

Oh and by the way, I DID find our STATE and our company's policy amendments and I was right, you must put a lock on it unless its impossible to do so, this is the EXACT wording of the policy. and I also agree with iwire's comment on the federal level of osha.
 
zog said:
Nope, because he is right. If the company wants to they can allow using a tag system in leiu of locks, but it has to be in thier written LOTO program. Your black and white answers lies in your companys LOTO written program.
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IMO 1910.147(c)(2)(i) tells us it is not up to the company to do that unless the isolating device is not capable of being locked out.
 
iwire said:
IMO 1910.147(c)(2)(i) tells us it is not up to the company to do that unless the isolating device is not capable of being locked out.
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You have to read on after that statement.

(d)(2)(ii)The employer's energy control program under paragraph (d)(2) of this section shall meet the following requirements:

(d)(2)(ii)(A) If an energy isolating device is not capable of being locked out, the employer's
program shall use a tagout system.

(d)(2)(ii)(B)If an energy isolating device is capable of being locked out, the employer's program shall use lockout, unless the employer can demonstrate that the use of a tagout system will provide full employee protection as follows:

(d)(2)(ii)(B)(1)When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by the use of a lockout program.

(d)(2)(ii)(B)(2) In demonstrating that a level of safety is achieved in the tagout program
equivalent to the level of safety obtained by the use of 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 energizing.

Now this wont apply at many companies but I have seen it a few times, usually the case is justified because some processes have things that could be dangerous to the general public and tags can be removed quicker and by anyone in case of an emergency. Example:some times you need to work on that reactor coolant pump but if you loose coolingto the reactor it is getting turned on no matter what.
 
brother said:
Then what do you have to say about IWIRE'S comment here Post #3??

http://forums.mikeholt.com/showthread.php?t=107577&highlight=loto

Oh and by the way, I DID find our STATE and our company's policy amendments and I was right, you must put a lock on it unless its impossible to do so, this is the EXACT wording of the policy. and I also agree with iwire's comment on the federal level of osha.
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You sure had a different tone in your PM. Anyways, like I said it all depends on what your companies policy says in writing, looks like you found that out, I hop eyou filled in that other guy.

See my other response to iwires comment. It all depends on the company and types of work. Would an EC ever use a tagout program, I doubt it, wouldnt make sense. but for some plants it does and is allowed.
 
brother said:
Ok, I just got to vent!! just here recently we had another electrician get shocked/burned and rushed to the hospital last week! . And to top this off, Im argueing with an OLD timer saying that the special 'tape' (red white tag out) is NOT sufficient lock out tag out. He claims the 'Powers that be' SAYS its ACCEPTABLE so long as we all accept that 'practice.
Click to expand...

A tagout program's acceptability as depends on much more than having everyone "accept that practice". It requires identifying whether an energy control device is capable of being locked out or not, requires a company program, training, and inspections to start with.

A couple of answers are needed first:
1. How did the electrician get hurt?
2. Was the energy control device capable of being locked out? If yes, does your company choose to only use a tagout via a written procedure?

Here is some OSHA regs that have been partially covered by other replies:

1910.147(c)(1)
Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

1910.147(c)(2)
Lockout/tagout.

1910.147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.

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)(2)(iii)
After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.

1910.147(c)(3)
Full employee protection.

1910.147(c)(3)(i)
When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.

..1910.147(c)(3)(ii)

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.
 
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