Lockout tagout

[Sparketta]

The real scoop on LOTO

The real scoop on LOTO

I have to speak up here, because LOTO is a subject I know extremely well. Some of the posters here are on the right track, but some of you are not quite getting it.

For the most part OSHA requires that locks be removed by the authorized employee who installed them. The problems brought up here due to locks left on and having to be removed by someone else or cut off should not have happened. It is not the intent of the standard to be cutting off locks left and right due to convenience issues, as is discussed in OSHA's LOTO Preamble, which states:

"In paragraph (e)(3) of this Final Rule, OSHA is requiring that as a general rule, the authorized employee who affixes a lockout or tagout device is the only one allowed to remove it. OSHA believes that each employee must have the assurance that the device is in his/her control, and that it will not be removed by anyone else except in an emergency situation. The entire energy control program in this standard depends upon each employee recognizing and respecting another employee's lockout or tagout device. The servicing employee relies upon the fact that he/she applied the device, and assumes that it will remain on the equipment while he/she is exposed to the hazards of the servicing operation.

OSHA can envision very few instances which would justify one employee's removal of another's lockout or tagout device. However, in a true emergency, and not merely because the employee is not available, the employer may be able to demonstrate a need to remove an employee's lockout or tagout device. An exception to paragraph (e)(3) of the final rule is being provided to allow for such situations, and is discussed further below. OSHA emphasizes that removal of a personal lockout or tagout device by another person may not be based on convenience or simple unavailability of the employee. If a lockout or tagout device is attached, it is assumed that the employee who attached that device is engaged in servicing the equipment on which the device is in use, and that person is exposed to the hazards of reenergization. Therefore, as a general matter, the protection of that employee requires that he/she have complete control over his/her lockout or tagout device. Some modification of the general rule is warranted in the case of transfer of authority between shifts as discussed in paragraph (f)(4) below, and to a limited extent in group lockout or tagout, as discussed in paragraph (f)(3) below, both of which involve coordination of activities between servicing employees.

Under the exception to paragraph (e)(3), the employer may direct the removal of a lockout or tagout device by another employee only if the energy control program incorporates specific procedures and training for that purpose, and only where the employer can demonstrate that the alternative procedure will provide equivalent safety to having the employee remove his/her own device. The procedure must include, at a minimum, the following items: First, verification that the authorized employee is not at the facility; second, making all reasonable efforts to contact that employee to inform him/her that his/her device has been removed; and third, ensuring that employee knows of that device removal before he/she resumes work at the facility. These steps are necessary to ensure that the employee who is protected by the device is not exposed to energy hazards either at the time of its removal or afterwards."

Not removing the locks of other employees should not be an issue, either, if LOTO is performed properly. Per OSHA, Lockout/tagout applies to the servicing/maintenance or equipment or machinery, and the standard dictates that the locks and tags are only to be used for that purpose. At the end of the shift, or if the job is paused to order parts, or whatever, the LOTO should come off and go with the worker to whatever the next job he or she works on that requires it.

When the equipment is left in an unsafe condition as in some of the cases mentioned here, there is another OSHA standard that covers it. The standard on accident prevention signs and tags, 1910.145, states:

1910.145(f)(5)

"Danger tags. Danger tags shall be used in major hazard situations where an immediate hazard presents a threat of death or serious injury to employees. Danger tags shall be used only in these situations.

1910.145(f)(6)

Caution tags. Caution tags shall be used in minor hazard situations where a non-immediate or potential hazard or unsafe practice presents a lesser threat of employee injury. Caution tags shall be used only in these situations."

So, when there is a break in maintenance, LOTO should be removed, and if the equipment is left in a condition that would make it hazardous to the general public (not just dangerous to someone working on it, remember, any one working on it would have to LOTO it anyway), a Caution or Danger (non-LOTO) tag shall be applied. In the case that there is no personnel hazard but the equipment could be damaged if it were to be energized, a configuration type informational tag (non-OSHA regulated) can be used. For extra protection, any of these tags can be applied with what the ANSI LOTO standard refers to as a "service lock" which all members of a particular work crew have a key or the combination to. This allows for the configuration to be maintained, safely, and when work is to resume, the worker removes the service lock, applies his or her LOTO and verifies ZES before starting work. The ANSI standard goes into more detail on this than OSHA's standard does, even going as far as prescribing removal of the LOTO whenever the authorized employee must leave the building for any reason.

So, why is it so important to remove LOTO when you are no longer working on the equipment? Why not just leave it locked out and be extra safe?

It is OSHA's belief that the practice of leaving equipment locked out while it is not being worked on desensitizes employees to the meaning of the distinctive lock and tag. When this happens, and especially when the workers are already violating the standard by readily removing each others locks whether with a master key or by cutting them off, the entire meaning of LOTO is diluted and you have a recipe for disaster.

Where does OSHA spell this out in the LOTO standard, 1910.147?

That is the big problem; they don't; you have to read between the lines. Under 29 CFR 1910.147(c)(5)(ii), lockout/tagout devices ". . . shall not be used for other purposes; . . ." Additionally, 29 CFR 1910.147(a)(1)(i) states: "This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees."

It would be hard to argue that the lock that was left on after the authorized employee has left for the day is being used to protect him during maintenance when no maintenance is occurring and he is at home sleeping.

I have seen OSHA inspectors write citations for LOTO locks and tags left in place when there is a break in maintenance.

As OSHA states in the LOTO Preamble, the provision to allow someone other that the authorized employee to remove the lockout/tagout is only for emergencies:

"This provision was intended to cover situations such as those that might arise from the sudden sickness or injury of an employee, key loss, or other emergency conditions."

If LOTO is removed when the authorized employee stops working on the equipment, these kinds of emergencies would be the only time there would be a need to remove someone else's LOTO.

Sorry to be so wordy.

 

[iwire]

Last week I was working on a machine, it took the better part of 5 days to do what I had to do, the equipment was not safe to run at the end of my shift each day, should I be removing my lock while I am gone?

I am left very confused, in electrical construction LOTO may be on for months for certain feeders.

 

[Sparketta]

Last week I was working on a machine, it took the better part of 5 days to do what I had to do, the equipment was not safe to run at the end of my shift each day, should I be removing my lock while I am gone?

I am left very confused, in electrical construction LOTO may be on for months for certain feeders.

Yes, per the LOTO standard for General Industry, you should be removing your personal lock when you leave, and replacing it with a configuration "Do not Use" type tag if the only danger is to the equipment if it were to be energized, or a "Danger" or "Caution" tag if it would pose a hazard to people in the area if the equipment were to be powered. Additionally you could attach a "service" or "shop" lock (non-LOTO lock that the whole crew has keys to) for extra protection, if you feel it to be necessary.

Construction has its own LOTO standard with slightly different rules under 29 CFR Part 1926, rather than the one for General Industry under part 1910, so the rules for construction LOTO may be different.

Keep in mind that if it is a group LOTO situation, the rules are slightly different. The Primary Authorized Employee would place locks at each isolation point and place the keys to those locks in a lockbox which he would secured with an "operations lock." The operations lock would secure the box between shifts when workers were switching out or overnight if it was a single shift operation. For a multi-shift job, the Primary Authorized Employee on each shift would have a key to the operations lock so that when all work was complete, the locks on the isolation points could be removed. Your personal lock (and the personal locks of any other employees working on the equipment) would be placed on the lockbox while you were working on it (so that the box cannot be opened until the personal locks of all workers are removed), and removed when you finished for the day or moved to another task. The locks securing the isolation points can remain in place for the duration of the maintenance, while shifts of workers come and go.

 

[electricalperson]

i use my LOTO gear all the time. i will NEVER remove a lock if im leaving the job. i feel that removing a lock just because you are leaving is an unsafe practice. i personally feel that the person who put the lock on is the only one who should remove it regardless if they leave the job or not. they are only a nextel beep away if they need to be called back to remove the lock. if you want to see me turn red and scream cut one of my locks off.

 

[jim dungar]

Last week I was working on a machine, it took the better part of 5 days to do what I had to do, the equipment was not safe to run at the end of my shift each day, should I be removing my lock while I am gone?

I am left very confused, in electrical construction LOTO may be on for months for certain feeders.

Most of the industries in this area add their own "equipment" lock and tag to the LOTO cluster. All workers must properly apply their own LOTO locks while they are on site, these personal locks must be removed when the employee leaves the site (unless a lock box is being employed) at the end of a shift. The company supplied "equipment" lock (under control of the project manager) stays attached until the equipment is ready to be returned to service.

 

[FNCnca]

Current company proceedure is to remove our lock at the end of the shift and to place a danger tag in its place. A danger tag is as good as a lock, only authorized persons shall remove the tag.
Removing a tag, without following proper proceedure, is subject to termination.
Removing another persons lock, without following proper proceedure, is subject to immediate termination, and has been done here.
Not locking out as required is subject, to immediate termination, and has been done here.
No excuse is considered good enough.
If you leave your lock in place when you leave, and it has to be removed, it is easier to call you back in (our prefered method) than to do all the paperwork required, to cut the lock.
All companies should be this stringent, and with rising insurance rates, they soon will be.
All workers should want to do this anyway, after all it is your life we are talking about.

 

[Safety869]

mdschunk

mdschunk

At our facility and according to our Lock-out Proceedure, at the end of a shift and the work is not completed a 'shift lock' will be applied by the supervisor. All employee locks will be removed at the end of the shift. If a lock is left on past the shift, the supervisor has to prove to us, by punch out documentation, phone call or complete walk thru of the equipment locked out, that proves that the employee has left the building.

 

[iwire]

Well I appreciate the replies but for now at the facility I am working at I will leave my lock on as long as I feel the equipment is unsafe. The only way that will change is if they change their policy and have someone else install a lock before I remove mine.

There is no way I could in good conscience pull off my lock at the end of the day with the machine in a state of disassembly. (Without someone else placing a lock on, and that would not happen)

As it happens my work there is mostly the addition of machine guarding systems so I talk to the 'safety committee' often, I will bring what I have learned here to their attention and see how they feel about it.

 

[Pierre C Belarge]

Well I appreciate the replies but for now at the facility I am working at I will leave my lock on as long as I feel the equipment is unsafe. The only way that will change is if they change their policy and have someone else install a lock before I remove mine.

There is no way I could in good conscience pull off my lock at the end of the day with the machine in a state of disassembly. (Without someone else placing a lock on, and that would not happen)

As it happens my work there is mostly the addition of machine guarding systems so I talk to the 'safety committee' often, I will bring what I have learned here to their attention and see how they feel about it.

What about disconnecting the conductors that supply the equipment? Disconnect them at the circuit breaker, and safe them off.

 

[frenchelectrican]

What about disconnecting the conductors that supply the equipment? Disconnect them at the circuit breaker, and safe them off.

not always be a safe methold because sometime you need the power to feed the aux equment if not related driect to that equiment.

I will give you a quick example what i useally do with primemover power plants with diesel and Natrual gas units what i useally do is LOTO generator breaker first then LOTO or remove fuel control valve connection next the engine starter i remove one or two cable depending on the set up and also the fuel supply valve LOTO them as well.
that way it will never start up at all

for other LOTO produceres for LV useage [ under 600 v ] lock out breaker or remove the fuse but MV and HV little diffrent the same rules applided to the LV but additon to the earth wire to the phase conductors to ground them good.

some place will have the Kirk Key system follow their producers as need to addtion to your LOTO producers

Merci, Marc

 

[Sparketta]

Well I appreciate the replies but for now at the facility I am working at I will leave my lock on as long as I feel the equipment is unsafe. The only way that will change is if they change their policy and have someone else install a lock before I remove mine.

There is no way I could in good conscience pull off my lock at the end of the day with the machine in a state of disassembly. (Without someone else placing a lock on, and that would not happen)

As it happens my work there is mostly the addition of machine guarding systems so I talk to the 'safety committee' often, I will bring what I have learned here to their attention and see how they feel about it.

I don't blame you- you have to follow whatever rules are in place where you are working. Removing your LOTO lock doesn't have to leave things in a dangerous condition, though, and it shouldn't- you simply put a non-LOTO padlock on with a non-LOTO Danger tag; everything will be fine, and you won't have diluted the singular meaning of LOTO that OSHA is so concerned with.

I hope that you are at least verifying that your lock is still in place at the beginning of each shift, if you are not removing it. Where I work, we used to leave the LOTO in place for the duration of the job as well. It worked out okay mostly, but one time there was a real problem in that a different contractor on second shift removed, replaced, and reenergized the entire circuit breaker box that held an employee's LOTO on one of the breakers inside. When the authorized employee in question went to resume work on the job, he was very lucky in that he was not hurt- his tool bag contacted the exposed 480v first, but it could have been a lot worse.

 

[quogueelectric]

Osha 1926

Osha 1926

I just took the osha course sat and it is my understanding that there is only a tagout procedure not a LOCKOUT procedure in place now. As a side note I just had the pleasure of working in a large powerplant and the loto procedure is followed very seriously. you violate this procedure you are fired immediately no joke there is a paper trail for lockout and a paper trail for release. You cut a lock you go to jail that simple. Violation of federal laws and forget about the job you used to have. There is a shift supervisor who is in charge of all loto activitiy and he is very serious about removing any locks it means his job every day all day NO EXCUSES and this is the way it should be treated. GO BIG BLUE!!!

 

[j.saraceni]

j.saraceni

j.saraceni

The purpose of the lock and tag is to protect the person to whom the lock is assigned. This lock and tag protect your life. If upon completion of your task or a shift change or end of the day you must remove your lock and tag as you are not working on this. If for some reason you leave a lock attached after you are gone a commitee should be formed to look over the situation and together form an opinion to either let the lock remain or remove the lock. If the person who the lock is assigned can be reached only he or she can remove the lock. Once your tag is removed and there exists a condition that equipment or persons can be harmed if operated, a yellow " caution tag " should be affixed describing the details of the condition and at this point only authorized qualified individuals should be allowed to proceed with work on this equipment after they have affixed their own lock and tag. Some companies allow a transition locking system which will not allow the equipment to operate. This transition lock is not personal protection and the removal should only be performed by authorized individuals. But never remove a red lock and tag.....

 

[jatrottpe]

Another component of the LOTO is the TRY. In our industry where you have a&b motors and other electrical devices for redundancy and reliability, you would be surprised by the number of times an A motor is locked out when the work is being done on the B motor.

 

[redbluff]

Another LOTO subject but none the less serious. We designed a set of three VFD's (600HP ABB units) with one spare (per the client which is a very dangerous situation) which the client wanted to be "available" by selection which required a thorough interlock and lock out sequence since the spare is spliced and fed to each motor through contactors on selection and permissives (one common spare for three drives). The spare has a "lock out" keyed" selector switch for "available and "lock out" which in the lock out position will keep the spare from energizing the isolation contactor which connects the spare drive to a selected disabled drive. The control of the isolation contactor is basically by the keyed lockout switch. The engineer absolutely demands that the contacts operating the isolation contactor be normally closed and not normally open for fail safe operation which sends chills down my spine and I refused to do so. After 37 years of maintenance electrical work and being a master electrician I've seen it all and cannot be convinced to set up a lock out device to run if it fails. I'm in engineering now and am instructed to do so and I can't. Am I right or wrong?

 

[macdonald41]

I recently completed a course on "work protection" in Ontario . It's more geared toward hydroelectric utilities , but it can be adapted by any company. The basic idea is to sign on when you begin your shift and install your lockouts.At the end of your shift, sign off and remove your lockouts. If the equipment still needs to be locked out, install a company standard padlock.The next shift does the same.

The day my supervisor gets the key to my lockout will be over my dead body.

 

[zog]

Another LOTO subject but none the less serious. We designed a set of three VFD's (600HP ABB units) with one spare (per the client which is a very dangerous situation) which the client wanted to be "available" by selection which required a thorough interlock and lock out sequence since the spare is spliced and fed to each motor through contactors on selection and permissives (one common spare for three drives). The spare has a "lock out" keyed" selector switch for "available and "lock out" which in the lock out position will keep the spare from energizing the isolation contactor which connects the spare drive to a selected disabled drive. The control of the isolation contactor is basically by the keyed lockout switch. The engineer absolutely demands that the contacts operating the isolation contactor be normally closed and not normally open for fail safe operation which sends chills down my spine and I refused to do so. After 37 years of maintenance electrical work and being a master electrician I've seen it all and cannot be convinced to set up a lock out device to run if it fails. I'm in engineering now and am instructed to do so and I can't. Am I right or wrong?

The system you are describing does not meet the OSAH requirements for a lock out device, thats more of a lock out relay (86 Device per IEEE), I always hated the name lock out relay, it tends to lead to confusion.

 

[safetyva]

Why to try

Why to try

Another component of the LOTO is the TRY. In our industry where you have a&b motors and other electrical devices for redundancy and reliability, you would be surprised by the number of times an A motor is locked out when the work is being done on the B motor.

I once examined a commercial flatwork ironer where an employee had been injured as a result of unexpected start-up during repair. The maintenance director meticulously demonstrated his "very thorough" lockout procedure they'd been using at the time of the injury. When he was done, I asked him to try the start button and verify lockout. The ironer gave a big shake then spun up to full working speed. I do have to say he looked astounded.

 

[Safety869]

I used to work for an outfit that supplied every field employee with a LOTO kit. And they were pretty strict about requiring their use.

Problem was, many of us bounced from one job to another. So one day we would put a lock on, and never see the job again. We ended up cutting tons of them off because the guy who put it on yesterday isn't here today.

Management finally started charging the guys for them until we explained the problem to them. They then replaced all the padlocks with ones that are all keyed alike.

I think you will find that OSHA will say that someone else having a key to your lock, is giving up the security of that lock and you will be fined. It is not written per se but that is what they told me. At the end of our shifts a shift lock will be installed and will not be taken off till the oncoming shift installs theirs and are updated to the process of fixing the problem with what ever you are working on. If someone leaves their lock on and goes home, we have to contact them or prove that they are no longer in the building.

 

[tomP]

Following is the part of our lock out standard for when a shift ends without work being completed.

4.3.1.3. Department Locks: A group of numbered locks should be designated as departmental safety locks and should be assigned to using departments. The departmental locks are used as follows:
4.3.1.3.1. Major work that will not be completed during the shift in which it was started shall have a departmental lock applied to the main disconnect and other energy sources. This shall not take the place of the individual employee's lock. The purpose of a departmental lock is to avoid unauthorized use of equipment prior to completion of all work.