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['Lockout/Tagout']
['Lockout/Tagout']
03/04/2024
Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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What do we do in a LOTO situation if the person who applied the lock is absent? Can I tell our managers to put away their bolt cutters?
What do we do in a LOTO situation if the person who applied the lock is absent?
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.
A 1995 OSHA letter of interpretation stated that the use of a master key is not an acceptable means for employer lock removal and that a bolt cutter (or equivalent means resulting in the destruction of the lock) must be used to remove the lock. The good news is that OSHA has rescinded this 1995 letter of interpretation, and your managers can now use procedures and training along with a master key to remove orphaned locks.
In a February 28, 2000 interpretation, OSHA now 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.
The use of a master key to remove a lockout device would be deemed equivalent only if it is performed under the employer’s direction and in accordance with the requirements in 1910.147(e)(3). Specific procedures and training, meeting the 1910.147(e)(3) exception, must be developed, documented, and incorporated into the organization’s energy control program. 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.
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