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OSHA’s lockout/tagout standard requires a documented procedure to be followed when an employer needs to remove a lock in the absence of the authorized employee who applied the lock.
In a February 28, 2000 letter of interpretation, OSHA states that 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.
A compliant master key procedure needs to include a reliable method to ensure that access to the master key will be carefully controlled by the employer. Safety is ensured through effective procedures that respect the sanctity of another employee’s lockout or tagout device.