My LOTO was cut off today.....

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Fulthrotl said:
in no particular order:

there was a tag, and a padlock with my cellphone number on it.
i'm the only electrician there. it was a brady LOTO lock.
no, a transfer lock was not used when i was offsite.
i don't know who i'd transfer it to. i suppose one of the voices
in my head, but which one?


was it a OSHA compliant LOTO procedure? it seems not, based on the
informed folks here.

the lock was there for a simple reason. unauthorized removal could
put you in mortal danger.

you could get shocked, as well.
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Seemed reasonable to me. If I put that tag and lock on there it better not be cut unless I'm dead and buried.
 
don_resqcapt19 said:
OSHA does not permit a "lockout" lock to remain on the equipment if the person that placed the lock is not on site. You can put some other type of lock if the equipment is not is not is a safe condition, but a "lockout" lock is intended to only be in place when you are actually working on the equipment. Lockout policies for the plants in my area require what the call a "transfer" lock when the equipment is not is a safe condition to be energized but no one is actively working on it. When work starts the next day the transfer lock is replaced with a lockout lock.
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Really.....never heard of that rule. A tag is just as restrictive as a padlock. Neither can be removed or overridden without authorization. My understanding having worked electric and water utilities for decades is that if a L/O tag and or L/O padlock are installed, it takes the person signed onto the tagout log to remove it. If that person is unavailable, another authorized person (usually a supervisor) can remove the L/O if he's sure it's OK and is willing to assume responsibility. Most times, that's not a popular position to be in. But expecting tagouts to be swapped around each time a shift changes or a weekend comes along sounds a bit extreme. Never seen it done.
 
meternerd said:
Really.....never heard of that rule. A tag is just as restrictive as a padlock. Neither can be removed or overridden without authorization. My understanding having worked electric and water utilities for decades is that if a L/O tag and or L/O padlock are installed, it takes the person signed onto the tagout log to remove it. If that person is unavailable, another authorized person (usually a supervisor) can remove the L/O if he's sure it's OK and is willing to assume responsibility. Most times, that's not a popular position to be in. But expecting tagouts to be swapped around each time a shift changes or a weekend comes along sounds a bit extreme. Never seen it done.
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IIRC, Don's description is how it was done at the one industrial facility I worked in. But it was a Fortune 500 company, so maybe that explains it.
 
gadfly56 said:
IIRC, Don's description is how it was done at the one industrial facility I worked in. But it was a Fortune 500 company, so maybe that explains it.
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I guess that the idea was that many people had a key to the same transfer lock or set of transfer locks, so that next shift to come in and work on the machinery could remove the transfer lock on their own and then attach a uniquely keyed LOTO lock belonging to a member of that team?
Saves having to do a person to person hand-off if there was an idle shift in between.
 
don_resqcapt19 said:
OSHA does not permit a "lockout" lock to remain on the equipment if the person that placed the lock is not on site. You can put some other type of lock if the equipment is not is not is a safe condition, but a "lockout" lock is intended to only be in place when you are actually working on the equipment. Lockout policies for the plants in my area require what the call a "transfer" lock when the equipment is not is a safe condition to be energized but no one is actively working on it. When work starts the next day the transfer lock is replaced with a lockout lock.
Click to expand...

For a left field view, Don's (OSHA's) approach is similar to what's done in my neck of the woods. Your personal lock protects you only hence its name. If you are not on site then your lock is not applied to onsite equipment. A Danger Tag or Out of Service Tag is applied to equipment depending on the state of the equipment while you are off site. Covers housing energised, in service equipment can only be opened using a key or tool. I see the cover is normally held on with screws and there is signage in place. If the cover was put on correctly this would normally be sufficient. In special cases during pre-commissioning activities of a site, an additional information tag warning that the equipment maybe energised is applied. This tag is removed following handover from the pre-commissioning team to the commissioning team.
 
wtucker said:
The LOTO lock must be removed when the employee is no longer in danger. Then, an "out-of-service" lock should be applied.
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What is the actual difference, really, between a LOTO lock, a transfer lock, and an "out of service" lock? Is it the physical lock? The marking on the lock (maybe)? A sign? The intent of the person applying it? In industrial settings it might be all of those, but in this case, where there is only one electrician and he says the setup is unsafe to operate? I don't think there is a difference at all. ("Hmm, I have to leave the site; I'll remove this lock, which has my name/phone on it, and put on this other lock, which has my name/phone on it. Oh, and change the sign from unsafe-to-operate to out-of-service.")

And even if this was a transfer lock or similar, I'd say it's still incumbent to the millwrights to call and check what they can do.

Come to think of it, the only time I've seen a LOTO lock being cut off was by the electrician who put it on and then dropped the key down a floor drain. He was the only one working on the job and we needed the panel re-energized (his work was complete).
 
ptonsparky said:
Good Golly Molly...someone cut a padlock off...and we are worried about the semantics of a LOTO vs OOS.
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This is the point. It is not semantics. LOTO serves a very specific function and should not be be reduced in importance by using them to keep people out of places you don't want them.

My LOTO is to protect me.

Every company should have a policy for lock installation and removal above and beyond LOTO.
I have seen equipment with padlocks on them that were over twenty years old. No current employee even worked with the person whose name was on those locks.
 
Jim dungar said:
This is the point. It is not semantics. LOTO serves a very specific function and should not be be reduced in importance by using them to keep people out of places you don't want them.

My LOTO is to protect me.
Every company should have a policy for lock installation and removal above and beyond LOTO.
I have seen equipment with padlocks on them that were over twenty years old. No current employee even worked with the person whose name was on those locks.
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OK. Point taken.

Someone still had a severe case of HUA syndrome.
 
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jim dungar said:
This is the point. It is not semantics. LOTO serves a very specific function and should not be be reduced in importance by using them to keep people out of places you don't want them.

My LOTO is to protect me.

Every company should have a policy for lock installation and removal above and beyond LOTO.
I have seen equipment with padlocks on them that were over twenty years old. No current employee even worked with the person whose name was on those locks.
Click to expand...

But at same time this is not a LOTO application. Had it been a switch with a lock to prevent operating the switch we have a LOTO situation.

Here all we had is a lock preventing access to inside the enclosure - but was not preventing anything from operating.

Qualified people? As in only one electrician on the site? LOTO applies to more then just electrical workers, as well as to more then just locking out electrical energy.

OP maybe has a reason to be PO'ed, but his lock was not a part of LOTO, it was just a lock to prevent access like the lock on his job box if he has one there.
 
I agree with others that this situation was not a LOTO, however, other statements here have me wondering. I am in construction. I just did a building as follow:

  • 5 stories.
  • one main switchboard
  • each floor had a distribution panel and all circuits on the floor were fed from it.
  • The roof had its own distribution panel residing on the 5th floor.

We place LOTO on each floor's breaker in the main switchboard with the supervisor's name on it. All breakers in every downline panel were off, but that was just me directing them for caution sake anticipating that someone can always be stupid and violate the protocol. LOTO was only removed after the floor was 100% done and energizing for test and troubleshooting was necessary. At that time LOTO was turned over to be the individual's responsibility on a day by day hour by hour basis. These floors weren't "Out of service" The were being "serviced" in accordance with the OSHA definition.

So, please tell me if you are saying our procedure wasn't correct, and if you say I couldn't leave my tags on the switchboards, overnight, then cite the actually OSHA standard that requires otherwise please.
 
Perhaps the main mistake in people's minds, other than lock-cutting, was calling it a LOTO lock in the first place..... Change that and most of the this becomes interesting but irrelevant. If fullthrotl had called it an out-of-service lock would we be having the same discussion? I don't think so.
 
zbang said:
Perhaps the main mistake in people's minds, other than lock-cutting, was calling it a LOTO lock in the first place..... Change that and most of the this becomes interesting but irrelevant. If fullthrotl had called it an out-of-service lock would we be having the same discussion? I don't think so.
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But it wasn't an out of service lock either. It took me a bit to come to a conclusion, but There was no purpose in putting a lock on that junction box except to add a level of safety. Since it was not out of service, an out of service tag would not have been appropriate. Any more than lock out tag out.
 
Strathead said:
I agree with others that this situation was not a LOTO, however, other statements here have me wondering. I am in construction. I just did a building as follow:

  • 5 stories.
  • one main switchboard
  • each floor had a distribution panel and all circuits on the floor were fed from it.
  • The roof had its own distribution panel residing on the 5th floor.

We place LOTO on each floor's breaker in the main switchboard with the supervisor's name on it. All breakers in every downline panel were off, but that was just me directing them for caution sake anticipating that someone can always be stupid and violate the protocol. LOTO was only removed after the floor was 100% done and energizing for test and troubleshooting was necessary. At that time LOTO was turned over to be the individual's responsibility on a day by day hour by hour basis. These floors weren't "Out of service" The were being "serviced" in accordance with the OSHA definition.

So, please tell me if you are saying our procedure wasn't correct, and if you say I couldn't leave my tags on the switchboards, overnight, then cite the actually OSHA standard that requires otherwise please.
Click to expand...

They make a LOTO device that allows multiple locks to be placed on it for lockout. You could leave one "master" lockout as the supervisor, pending turn over for the floor, but each electrical worker on each floor has to add their own personal lock to that floor's lockout device. If they change the floor they are working on, they have to take their lock off the master for that floor and put it on the one for the floor they are going to.
 
gadfly56 said:
They make a LOTO device that allows multiple locks to be placed on it for lockout. You could leave one "master" lockout as the supervisor, pending turn over for the floor, but each electrical worker on each floor has to add their own personal lock to that floor's lockout device. If they change the floor they are working on, they have to take their lock off the master for that floor and put it on the one for the floor they are going to.
Click to expand...

If that is true it is just another example of the unsurprising ridiculousness of our government. Perhaps we should put locks on every panel in every new construction we work on, even when the utility isn't hooked up yet, because you never know, someone may sneak in and turn it on.
 
Strathead said:
If that is true it is just another example of the unsurprising ridiculousness of our government. Perhaps we should put locks on every panel in every new construction we work on, even when the utility isn't hooked up yet, because you never know, someone may sneak in and turn it on.
Click to expand...
Why is having your personal lock on the power source that could energize the equipment ridiculous? That is the whole purpose of lockout...to help keep the person who placed the lock safe. Every person working on the equipment is required to have his or her own lock on the energy source.

Loto is always an individual responsibility, it is never the responsibility of someone else.
 
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