LOTO padlock

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peez

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Are there any code violations (OSHA, NFPA70E) for using an ordinary padlock instead of using lockout padlock? The only intention is for cost cutting.

Looking forward for your comments
 
There are certain requirements not only for padlocks but for an entire LOTO program. If you are asking this question, it is likely that your facility does not have a written lockout tagout program. Please refer to OSHA 1910.147 for details on a LOTO program.

To specifically answer your question, a regular padlock cannot be used for LOTO. There are specific requirements for a LOTO lock contained in 1910.147(c).
 
I don't see anything that says you can't use a standard lock for lockout. It just requires that it be readily identifiable as a lockout lock. In many cases this is accomplished by the use of a standard lock of a specific color.
 
don_resqcapt19 said:
I don't see anything that says you can't use a standard lock for lockout. It just requires that it be readily identifiable as a lockout lock. In many cases this is accomplished by the use of a standard lock of a specific color.
Click to expand...

i would think that the location of a lock would readily identify it as a LOTO lock.

after all, nobody is padlocking that disconnect to prevent theft, are they?
the person APPLYING the lock needs to be readily identifiable.

we'd find locks on equipment at DWP that had been applied 15 years before,
by someone who'd since retired. :huh:

those brady tags really are durable..... :p
 
peez said:
Are there any code violations (OSHA, NFPA70E) for using an ordinary padlock instead of using lockout padlock? The only intention is for cost cutting.
Click to expand...

It may help answer your question if you tell us what codes are applicable to you in the Philippines, and in your industry. I would not have expected OSHA or NFPA to apply, but it will still depend on what you are doing.
 
wbdvt said:
There are certain requirements not only for padlocks but for an entire LOTO program. If you are asking this question, it is likely that your facility does not have a written lockout tagout program. Please refer to OSHA 1910.147 for details on a LOTO program.

To specifically answer your question, a regular padlock cannot be used for LOTO. There are specific requirements for a LOTO lock contained in 1910.147(c).
Click to expand...

My warm thanks for giving me the reference. However as stated in OSHA 1910.147

1910.147(c)(5)(ii)(B)
Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized.

There are no specification for the padlock to be used, and additionally, its function is still the same. Please see attached photo for referenceLOTO.jpg​
 
don_resqcapt19 said:
I don't see anything that says you can't use a standard lock for lockout. It just requires that it be readily identifiable as a lockout lock. In many cases this is accomplished by the use of a standard lock of a specific color.
Click to expand...

Yes, that's my point. However, are there any chances that I'll be issued with non compliance report?
 
MAC702 said:
It may help answer your question if you tell us what codes are applicable to you in the Philippines, and in your industry. I would not have expected OSHA or NFPA to apply, but it will still depend on what you are doing.
Click to expand...

HI. MAC

OSHA and NFPA are applicable here in the Philippines
 
LOTO Locks

LOTO Locks

Per the regulation

Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized.

Locks used for lockout must be readily identifiable. We use a standard padlock with red electrical tape around the body to identify it for use for lockout tagout.
The goal is to ensure that everyone (affected and authorized personnel)in the area can identify that lock as a lockout lock even if the tag were removed.
Additionally, a lockout lock cannot be used to tag equipment 'Out of Service'. Locks used for lockout are expected to be removed at the end of the shift by the worker that placed it there. If equipment is being taken permanently out of service, put a non-lockout lock on it and a message on it saying 'This equipment is out of service as of [insert date].

With respect to "If you are asking this question, it is likely that your facility does not have a written lockout tagout program". Give the guy a break. at least he's asking the question.

MikeCJ
 
Only watchout I see

Only watchout I see

It says somewhere that all locks need to be keyed differently. We had to order them because we had 300 people with locks.

Don't let cost over rule safety.
 
just the cowboy said:
It says somewhere that all locks need to be keyed differently. We had to order them because we had 300 people with locks.

Don't let cost over rule safety.
Click to expand...

Oddly enough I have seen safety catalogs carry products that offer a master key option which sounds like the worst idea ever. The one place I worked at that I had to have my own, the safety director would personally hand them out and he'd break the spare key, as they always came with two.
 
gadfly56 said:
Oddly enough I have seen safety catalogs carry products that offer a master key option which sounds like the worst idea ever. The one place I worked at that I had to have my own, the safety director would personally hand them out and he'd break the spare key, as they always came with two.
Click to expand...
If the master key(s) were kept under strict managerial, procedural and physical, control and only use where otherwise the lock would be cut off, I can see the value.
Note that master keyed is very distinct from keyed alike, as 99+% of the time the individual key would be used.
 
GoldDigger said:
If the master key(s) were kept under strict managerial, procedural and physical, control and only use where otherwise the lock would be cut off, I can see the value.
Note that master keyed is very distinct from keyed alike, as 99+% of the time the individual key would be used.
Click to expand...

That, of course, is the nub of the issue. All you need is someone in production to get a hold of one and it's chaos. No C.O.N.T.R.O.L.
 
Let's move forward. Given this scenario, if we standardize this standard padlock then we fabricate (let's say red sticker with lockout sign attached to the standard padlock), should we say that I am already an OSH compliant?

Standard padlock only cost u $5 while using lockout padlock will cost you $36
 
peez said:
Let's move forward. Given this scenario, if we standardize this standard padlock then we fabricate (let's say red sticker with lockout sign attached to the standard padlock), should we say that I am already an OSH compliant?

Standard padlock only cost u $5 while using lockout padlock will cost you $36
Click to expand...

I suppose that could work, as long as you can ensure all the locks are keyed different.
 
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