Lockout Requirement

[mlp425]

I had a situation today where all of my "lock-out" locks were in use and I had one more three phase combination starter to lock out. At what point is a lock not needed?
If the disconnect handle is tagged and fuses are pulled? (doubt it)
If the disconnect handle is tagged, fuses are pulled, and T-leads disconnected?
How about disconnect handle is tagged, fuses are pulled and contactor coil wire disconnected?
Or none of the above.

 

[bphgravity]

Does your company / facility NOT have a LOTO policy?

 

[iwire]

If it is capable of being locked out it must be locked out.

The control of hazardous energy (lockout/tagout). - 1910.147

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)(5)(ii)(C)(1)
Lockout devices. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.

1910.147(c)(5)(ii)(C)(2)
Tagout devices. Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie.

 

[mlp425]

Yes, we do have a LOTO policy and have had the required training. I did go to the safety dept. for an additional lock but I was just wondering if there was any extreme measures to take if there were no locks available to safely disable this motor.

 

[bphgravity]

Perhaps you should update your management team about your situation today and see something gets written into your policy on how to handle this in the future...

 

[Cow]

Perhaps you should update your management team about your situation today and see something gets written into your policy on how to handle this in the future...

Seems like this could be remedied more simply by just buying more locks.

 

[LarryFine]

Seems like this could be remedied more simply by just buying more locks.

Oh, be serious! We can't end a thread like that!

 

[480sparky]

Oh, be serious! We can't end a thread like that!

OK... buy more locks than you will ever need......

Does that help?

 

[Cow]

Oh, be serious! We can't end a thread like that!

I know, I let the cat out of the bag too soon. The serious, practical answers aren't supposed to start until page 3, right?:smile:

 

[iwire]

I think maybe BPHs point might have been the training program needs improvement if it does not include training about what to do when they are out of looks.

Basically, stop work until locks become available.


It seems a manger could run out and buy some locks when they see the maintenance crew not working on the machine that needs work.

 

[pfalcon]

At what point is a lock not needed?

When you finish your work :grin:
or when there is an upstream lock.

If the disconnect handle is tagged and fuses are pulled? (doubt it)

This is called Tagout and can be used if per your company LOTO policy. Not considered to be as safe as Lockout since some helpful Jack-n-ape may decide the circuit *must* be powered up.

If the disconnect handle is tagged, fuses are pulled, and T-leads disconnected?
How about disconnect handle is tagged, fuses are pulled and contactor coil wire disconnected?

As the prior answer. Most Tagout policies don't require going so far. Again go and see your company LOTO; it is required to have the correct answer.

Or none of the above.

Your company policy may not permit Tagout per their LOTO policy

So in reality though peeps in the forum can help guide you to a reasonably safe conclusion on the LOTO issues they cannot really answer this question. Your company LOTO must be followed so you have to look it up there.

Otherwise when you run out of locks it becomes your boss' problem.

 

[billsnuff]

i issue each employee (2) LOTO locks. i also maintain a LOTO board in the shop with extra locks for just the situation you have. don't forget that each lock must identify it's owner and have one unique key...

 

[len149]

Dept. Lock and Lock Box

Dept. Lock and Lock Box

Save On Locks:
A lock out station with Department lock out supplies should be part of any companies LOTO policy. The additional locks at the station along with the lock box allows one to us companies Department locks for equipment, put the keys from these locks in a lock box and lock the keys with a personnal safety lock. This meets the intent that a personal lock is used for lock out.
Example:
Machine has 8 primary power sources and 4 electricans working on machine then 8 Dept locks are used to lock out the 8 primary sources the keys are placed in a lock box and the 4 electricians place their personal locks on the box.
8 + 4 = 24 Locks required
8 * 4 = 32 Locks required without lock box.

ECPL Facilitator

 

[iwire]

This is called Tagout and can be used if per your company LOTO policy. Not considered to be as safe as Lockout since some helpful Jack-n-ape may decide the circuit *must* be powered up.

Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

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.

 

[zog]

Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

Not true, if your company wants to they can use a tagout policy, very few do but I have seen them. Your quoted OSHA article says the opposite, it says if it cant be locked out you must have tagout procedures in your LOTO program, dosent say you cant use a tag system on something that can be locked out.

 

[zog]

Save On Locks:
A lock out station with Department lock out supplies should be part of any companies LOTO policy. The additional locks at the station along with the lock box allows one to us companies Department locks for equipment, put the keys from these locks in a lock box and lock the keys with a personnal safety lock. This meets the intent that a personal lock is used for lock out.
Example:
Machine has 8 primary power sources and 4 electricans working on machine then 8 Dept locks are used to lock out the 8 primary sources the keys are placed in a lock box and the 4 electricians place their personal locks on the box.
8 + 4 = 24 Locks required
8 * 4 = 32 Locks required without lock box.

ECPL Facilitator

8+4=12 last I checked

 

[mlp425]

Interesting... Allow me to add a little twist to this thread. Lets say I have three small conveyor motors controlled by seperate contactors being fed by a common disconnect, all motors are within sight of by the way. One of the conveyors needs to be serviced, however, production can and wants to continue running product with the two remaining conveyors. Is it not exceptable to remove the energy source by removing the t-leads and tagging them indicating the reason why they have been removed? Does this fall into the catagory of 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. ? I know it might be suggested that each motor should be fitted with a lockable disconnecting means, but most of the production machine come into our plant with one common lockable disconnect. It seems to get a little confusing when I try to put the NEC, NFPA 79 and OSHA together.

 

[zog]

Interesting... Allow me to add a little twist to this thread. Lets say I have three small conveyor motors controlled by seperate contactors being fed by a common disconnect, all motors are within sight of by the way. One of the conveyors needs to be serviced, however, production can and wants to continue running product with the two remaining conveyors. Is it not exceptable to remove the energy source by removing the t-leads and tagging them indicating the reason why they have been removed? Does this fall into the catagory of 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. ? I know it might be suggested that each motor should be fitted with a lockable disconnecting means, but most of the production machine come into our plant with one common lockable disconnect. It seems to get a little confusing when I try to put the NEC, NFPA 79 and OSHA together.

Hard to tell without seeing the system but that sounds OK As long as your written LOTO program reflects this . Not many companies EHS depts can justify or feel comfortable have a tagout system in place, nuclear plants and military facilities re the only places I have seen this allowed. You know, places that can make you dissapear for violating the LOTO policy.

 

[pfalcon]

Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

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)(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.

You should read the OSHA stuff farther. Tagout is permitted in place of lockout under specific conditions. I also did presume that the company LOTO policy was in compliance rather than presume incompetence on the part of the company.

 

[pfalcon]

Is it not exceptable to remove the energy source by removing the t-leads and tagging them indicating the reason why they have been removed? Does this fall into the catagory of 1910.147(c)(2)(i) ? I know it might be suggested that each motor should be fitted with a lockable disconnecting means, but most of the production machine come into our plant with one common lockable disconnect. It seems to get a little confusing when I try to put the NEC, NFPA 79 and OSHA together.

No this does not fall under 1910.147(c)(2)(i). When you removed the leads you have actually altered the functionality of the machine. Tagout takes place at the very same location and manner as Lockout except without the locks. You must use LOTO in order to safely remove the leads; then you need engineering approval to place the machine back in service under the new configuration. You also need engineering approval to work on the inactive sections of the machine based on analysis that hazardous motion and energy are not present. They are effectively approving a "new" machine.