| Lockout/Tagout: OSHA’s View |
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Lock-Out/Tag-Out, or
"LOTO", is the second most cited OSHA regulation violation.
The primary applicable regulations are OSHA §1910.147 Lock-Out/Tag-Out,
§1910.269 for Electric Power Generation, Transmission and Distribution
and §1910.268 for Telecommunications. These rules require that
all energy sources be turned off and either locked out or tagged out
while performing service or maintenance work. By protecting the worker
from accidental release of energy (electrical shock, mechanical action,
heat, etc.), these rules are saving hundreds of lives yearly.
Although tags are generally used in conjunction with a lock (preferred
by OSHA), many utilities still use tags alone. When the company trains
and tracks religiously and effectively, this mode works safely. In
writing the OSHA 1910.147 rules, the tags versus locks issue was debated
extensively. Ultimately, OSHA chose lock-out as the preferred and
safer way to ensure that equipment remain de-energized. Still, when
an energy isolating device was not capable of being locked out, they
also allowed “tag alone” use. Furthermore—when the
employer can "demonstrate that the tagout program will provide
a level of safety equivalent to that obtained by using a lockout program"
[1910.147 (a)(3)(c)(3)]—tags alone are also acceptable. This
“flexibility” may not improve safety. Many users and regulators
acknowledge that tags are much easier and faster to use. Thus, tags
are more likely to be implemented than a “locks-only”
program. Indeed, some field circumstances make locks impractical—and
perhaps more dangerous than a tag. Nonetheless, in developing your
own LOTO program, we recommend you honestly assess your training effectiveness,
your written procedures and your workforce’s capabilities—and
come down firmly on the side of safety. |
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