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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

From an OSHA letter ruling.

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.

 

[petersonra]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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]

Re: Lock out/Tag out

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.

 

[petersonra]

Re: Lock out/Tag out

Originally posted by 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

i agree that the way the osha rule is written they cannot stop you from putting your own lock on the equipment. i did not mean to imply they could or should do so.

my point was more along the lines of rather than relying on some government agency regulation, why not just talk to them and see what they mean. they may mean for you to put your own lock on but just don't say so in their own procedure. if i were to write a lo-to procedure for my company I would not include any instructions at all for outside contractors. they have to have their own policy.

 

[celtic]

Re: Lock out/Tag out

Originally posted by don_resqcapt19:

Outside employers are not required to use on-site employer lockout/tagout procedures.

I would add my OWN lock...and offer one of these gizmos if they don't have one:

If they cannot comply with MY LOTO policy, I cannot and WILL NOT perform the task.

 

[celtic]

Re: Lock out/Tag out

Duplicate

[ October 28, 2005, 05:15 PM: Message edited by: celtic ]

 

[don_resqcapt19]

Re: Lock out/Tag out

Bob,

if i were to write a lo-to procedure for my company I would not include any instructions at all for outside contractors. they have to have their own policy.

It is much easier for you if you include the contractors in your policy. If you don't, then you have to train your people as to the methods that the contractor is using.
Don

 

[realolman]

Re: Lock out/Tag out

There is more involved than electricity also. You are supposed to identify and document all potential sources of energy. I would expect the plant guys to know that better than contractors, and OEM people to know that better than plant guys.

I think the multiple lock gizmo pictured in an earlier post is appropriate. If I'm working on it, and I want my lock on it, my lock goes on it. When I'm done it comes off. If you're not done, your lock is still there.

Part of lock out is informing operators and whoever else would be affected, about your lock out. It wouldn't kill people to talk to each other

 

[pierre]

Re: Lock out/Tag out

For those who may be interested or are just ahead of the curve, here are two very good sites for info and FREEEEEEEE stuff that will really help.


http://www.osha-slc.gov/SLTC/electrical/index.html


www.cdc.gov/niosh/02-123pd.html

[ October 29, 2005, 09:13 AM: Message edited by: pierre ]

 

[bphgravity]

Re: Lock out/Tag out

The NFPA 70E has a couple of sample LOTO procedures (simple and complex) in Annex G. These can be viewed online for free if you don't have a hard copy. www.NFPA.org

 

[wiremonkey78]

Re: Lock out/Tag out

At our plant. The employer has a supervisor,usually the one who bid the job being preformed. Talk with the leadership of the contractor. About the peramiters of the clearance to be set-up. He then must place a lock and sign onto the clearance first. Then the contractor my place a lock or locks.

 

[tkb]

Re: Lock out/Tag out

I have worked in plants that also have their own LOTO policies.

The owner or whoever is responsble, locks out the disconnect and other systems with their locks and the multi hole LOTO devices.

All trades that work on the machines also have to put their own lock on the same device.

When you are done then you take off your lock. If there is only the owners lock left then the machine is ready to be turned back on.

I don't see a problem with the owner having the responsibility of controling the LOTO program.
You still have to put your own lock on regardless.

 

[wtucker]

Re: Lock out/Tag out

Well, there's always OSHA, General Industry Standards:

Title 29, Code of Federal Regulations, Part 1910.147(c)(8)

"Energy isolation. Lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance."

Couldn't get much simpler than that.