As the debate continues about using "clamshells" as a lockout device, our behind the scenes discussions continue regarding OSHA's use of the term "Substantial". The discussion was so good I asked if I could summarize and post it to keep the discussions going. So once again, here is OSHA's definition of a "Lockout device":

A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.

Most of us view a "lockout lock" as the lockout device and it is certainly a big part of it; however, if we take a step back and look at a lockout we see that many lockouts are using devices/equipment to actually hold the energy isolation device in the "safe" position. At least that is the case in the process industry where we use "shark leader" (e.g. cable) and chains to wrap around valves in order to "lock them out". The point was made when the question was asked:

Would we allow operators to use dental floss or kite string around the valve(s) and then hang a lock on the floss or string?

That is so far outside what most would find acceptable I had never even look at the cables and chains as being a weak point in the energy isolation. So this safety professional was educating us on establishing strength limitations, much like OSHA has done with attaching a tag to an energy isolation device (i.e. the 50-pound breaking strength requirement). And quite frankly, I could not agree more with her position on the matter. Not that I have ever seen anyone use dental floss or kite string in an energy isolation arrangement, I am of the cloth that if we do not define what can be used and what is prohibited, we will one day find where the human has done it and will be shocked at our dismay.

So we should look at ALL components of the energy isolation and ensure that the ENTIRE "lockout device" is substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.

 
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