Group LockBox System

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TVH

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Under a Group Lock Box System where should the lockbox be located? Some at my work site say it should be located in view of the energy isolating device. Others say it should be located in the office of the Electrical Competent person. Others say it does not matter where it is located.

Concern being that under a LOTO protocol person(s) who have locks and tags attached to energy isolating devices need to physically check their locks and tags before commencing work to ensure that conditions have not changed. If the lockbox is located remote from the energy isolating device then their could be tempetation to not physically check the energy isolating device.

Comments appreciated.
 
TVH said:
Under a Group Lock Box System where should the lockbox be located? Some at my work site say it should be located in view of the energy isolating device. Others say it should be located in the office of the Electrical Competent person. Others say it does not matter where it is located.

Concern being that under a LOTO protocol person(s) who have locks and tags attached to energy isolating devices need to physically check their locks and tags before commencing work to ensure that conditions have not changed. If the lockbox is located remote from the energy isolating device then their could be tempetation to not physically check the energy isolating device.

Comments appreciated.
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I've seen it multiple ways. At one facility a supervisor was in charge of placing locks on equipment and keys in lockbox, which was then left in a designated spot (operators pulpit) for employees to hang their locks. Have also had to have box at machine center so that it was easily visible to people working on equipment.

"In view of" may not be possible if energy sources are in different locations i.e. MCC room and pneumatic valve at machine
 
TVH said:
Concern being that under a LOTO protocol person(s) who have locks and tags attached to energy isolating devices need to physically check their locks and tags before commencing work to ensure that conditions have not changed. If the lockbox is located remote from the energy isolating device then their could be temptation to not physically check the energy isolating device.
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What do you mean by "Person(s) who have lock and tags attached"? You put your lock on when you begin work on the equipment, take it off when you're done. Conditions cannot have changed while your lock was on.

(1910.147(f)(3)(ii)(D) "Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.")

See also, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24005

And, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25538
 
wtucker said:
What do you mean by "Person(s) who have lock and tags attached"? You put your lock on when you begin work on the equipment, take it off when you're done. Conditions cannot have changed while your lock was on.

(1910.147(f)(3)(ii)(D) "Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.")

See also, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24005

And, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25538
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In my many years experience in heavy construction I have seen/investigated may LOTO violations/incidents especially during the commissioning phase. Several of these involved LOCK BOX systems: I have seen situations where someone has walked off with lock boxes and never found (unknown reason). Locks applied to wrong lock boxes where multiple boxes are in use. Locks on energy isolaton devices in the MCC that have been cut off. Tampering of tags at MCC. Spare keys or master keys in use voiding protection. This is what I mean by changing conditions.

As opposed to permanent facilities, construction offers many situations where LOTO can be compromised expecially during commissioning of downstream equipment by multiple crafts.

In Construction I personally favor locks and tags be positionned by the authorized craftsman directely on the energy isolating device at the MCC and under a Work Permit System. Authorized craftsman responsible to physically verify his lock and tag before commencing work. You cannot physically check LOTO positioning on the isolating device under a lock box system where the lock box is located away from the vicinity of the MCC Energy isolating device. A lock box system can lead to confusion and confusion has no place in an energy isolating system.

My orginal question is where should a lock box be located? Box should also be secured into position.
 
TVH said:
Under a Group Lock Box System where should the lockbox be located? Some at my work site say it should be located in view of the energy isolating device. Others say it should be located in the office of the Electrical Competent person. Others say it does not matter where it is located.

Concern being that under a LOTO protocol person(s) who have locks and tags attached to energy isolating devices need to physically check their locks and tags before commencing work to ensure that conditions have not changed. If the lockbox is located remote from the energy isolating device then their could be tempetation to not physically check the energy isolating device.

Comments appreciated.
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For a single project of equipment and 3-10 guys on it right there is fine. 100-200 people and 10 different lock boxes a office with a dude who knows what every box is for is better.
 
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