NFPA 70E 2004 120.2(D)(3)(c)

[RETJW]

I have very serious concerns related to the present language in the NFPA 2004 70E Complex LOTO Procedure. I intend to address my concern with a proposal prior to the closing date of 11/25/05.

Here is my opinion and concern:

1. NFPA 70E 2004 Article 120.3(D)(3)(c) which states in part; ..."the person in charge shall be permitted to install locks/tags, or direct their installation, on behalf of other employees," is in direct and irreconcilable conflict with 1910.147(f)(3)(ii)(D) which states,
"Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained."
2. Some argue that NFPA 70E 120.3(D)(3)(b) addresses the issue by requiring the person described as "in charge," be qualified.
3. I contend that NFPA 70E 120.3(D)(3)(b) is nothing more than a halfhearted attempt to comply with 1910.147(f)(3)(ii)(A), 1910.147(f)(3)(ii)(B), and 1910.147(f)(3)(ii)(C).
4. What it so critically leaves out is the very strong "and" at the end of 1910.147(f)(3)(ii)(C) that puts the entire rule back in proper perspective with the very plain statement at the start of 1910.147(f)(3)(ii)(D). (See above)
5. Simply stated, one person cannot hang a lock and tag for another.

I do not want to see us go backwards and allow an "in charge" person, qualified or not, to hang locks and tags for another. One man, one lock, one key, one life still makes good sense.

What I hope we can generate is a national discussion that will provide some quality proposals to the 70E Technical Committee that will change the present rule. Any help will be appreciated, it does not matter to me whose proposal is accepted as long as the present rule gets changed. If you do decide to submit a proposal to the Technical Committee, you can download an NFPA Technical Committee Document Proposal Form at the NFPA site. Please keep the closing date in mind.
Thanks to all for any help. I have no doubt that this rule will eventually be changed to be in line with OSHA, what I feel we can not wait for is a "body count" first.

 

[petersonra]

Re: NFPA 70E 2004 120.2(D)(3)(c)

This just does not seem like a good idea. The whole purpose of people putting their own locks on the LO device is so they KNOW it is there.

And why would you even want to put a lock on for someone who is not there and thus not working on it anyway? When he gets there he can put his own lock on.

Although there are times it would be handy to be able to do this, it seems like something that ought to be very rare.

 

[daparro]

Re: NFPA 70E 2004 120.2(D)(3)(c)

I agree this is a bad precedent. The paragraph in question is actually located in 120.2(D)(3)(c). Why on earth when today's trends are toward more safety on jobs would a rule like this come out?

 

[tom baker]

Re: NFPA 70E 2004 120.2(D)(3)(c)

I thought that 70E was the defacto electrical safety standard, OSHA uses it as its easier to keep it up to date.

 

[zog]

Re: NFPA 70E 2004 120.2(D)(3)(c)

The person in charge the NFPA is refering to only applies when working under the complex LOTO procedure. When you have a crew of 30 Electricians working on substations throughout a plant on a job that requires 4 lockout points are you telling me it is practical to have 30 locks hanging on each of the 4 lockout points?

The intent of this rule is that the person in charge would (Following a job brief with all employees involved) hang a lock on each point, put the 4 keys in a lockbox and then all 30 employees would place a lock on the lockbox.

 

[daparro]

Re: NFPA 70E 2004 120.2(D)(3)(c)

I'm not so sure you have the intent right. I looked at the section again and then went to the Handbook on 70E. The Handbook has explanatory information that says:

"Additional employees often are assigned to an area to provide sufficient manpower to complete all necessary work tasks while the shutdown is under way. Contract or other temporary employees might be unfamiliar with the location of electrical circuits and disconnecting means. The person in charge is responsible for ensuring that no temporary employee is unnecessarily exposed to an electrical hazard.
A written plan must identify each step required to install lockout and tagout devices, including the following:
- The disconnecting means
- Who will install lockout/tagout devices
- How the absence of voltage will be verified
- How employees will be accounted for before, during, and after the work is complete.

The plan must be reviewed with or by all workers to establish clearly the authority of the person in charge."

The way I read this a lock would not be required from each hand if the written plan used another technique such as personally contacting each person. If they meant a lock was required they would have said so. I think each person should either put a lock on each device or in case of a large or complex job each person should be shown that each device is locked then put their lock on a box that contains the keys to the device locks.

 

[zog]

Re: NFPA 70E 2004 120.2(D)(3)(c)

"I think each person should either put a lock on each device or in case of a large or complex job each person should be shown that each device is locked then put their lock on a box that contains the keys to the device locks."

Exactly!

 

[coulter]

Re: NFPA 70E 2004 120.2(D)(3)(c)

Originally posted by zog:
"I think each person should either put a lock on each device or in case of a large or complex job each person should be shown that each device is locked then put their lock on a box that contains the keys to the device locks."

Exactly!

The outfit I work for has a pretty through Energy Isolation policy. An since we have our own personal Osha Inspector, I highly suspect it meets the law.

Under this policy, we can use a Designated Worker to represent the crew. It does not have to be a supervisor, and usually isn't, but the crew has to agree on who it is. In addition, anyone can opt out and put their personnal lock on the device or lock box. There is a bunch of paper work and procedure to insure everyone knows the status.

The policy states: "... all personnel performing work and services .. understand that they have the right to exclusive control over the energy isolation associated with their work."

I'm not making a statement about if it is right or wrong, just that it works well and aparently meets the law.

carl