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OSHA Lockout/Tagout Rules: Q & A

Topic: Safety Management

There is a gap between the value of worker safety and the culture of safety in many organizations. Closing the gap is a major concern for safety professionals and executive managers.

Q. Can a duplicate key for the purpose of lock removal under LOTO be held in a secure area with a procedure in place for access to the key and returning the key that does not jeopardize the employee's safety?

A. An OSHA Letter of Interpretation, dated February 28, 2000, which discusses the use of a master key and alternate procedures to remove a lockout device, states the following, which may be applicable to your situation:

Bolt cutters, or other device-destructive methods, are not the only permissible means by which to remove a lockout device, if the employer can demonstrate that the specific alternative procedure, which the employer follows prior to removing the device, provides a degree of safety that is equivalent to the removal of the device by the authorized employee who first affixed it.

The use of a master key to remove a lockout device would be deemed equivalent (to the removal of the lock by the person who applied it) only if it is performed under the employer's direction and in accordance with the requirements established in 1910.147(e)(3).

Obviously, the "one person, one lock, one key" practice is the preferred means and is accepted across industry lines, but it is not the only method to meet the language of the standard. However, prior to the use of the master key method, specific procedures and training, meeting the 1910.147(e)(3) exception, must be developed, documented, and incorporated into your energy control program.

Among the features essential to a compliant master key procedure is a reliable method to ensure that access to the master key will be carefully controlled by the employer such that only those persons authorized and trained to use the master key in accordance with the employer's program can gain access.

Q. How often do we have to inspect each piece of equipment for lockout/tagout?

OSHA requires an annual inspection of energy control procedures on each machine:

1910.147(c)(6)(i). The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.

1910.147(c)(6)(i)(A). The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.

1910.147(c)(6)(i)(B). The periodic inspection shall be conducted to correct any deviations or inadequacies identified.

1910.147(c)(6)(i)(C). Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.

1910.147(c)(6)(i)(D). Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.

1910.147(c)(6)(ii). The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.

Q. If my factory does not operate 24/7 and we are in the middle of a LOTO maintenance procedure that another crew will complete the next day, how do you pass off the keys/locks/tags etc. so the new crew is protected? Does the foreman have to bring in the master gold lock key and hand it to the new foreman?

A. According to the OSHA lockout/tagout rule section on shift changes (29 CFR 1910.147(f)(4)), it's up to the employer to develop procedures for shift changes to ensure continuity of protection for all employees. OSHA does not provide specific procedures for the changeover.

However, there should be a physical hand-off of keys/master key and documentation that such transfer took place. OSHA requires the employer to create procedures for accountability where an authorized person places the locks and then a different person removes them.