I am not sure of the situation that is actually taking place here, but I can state that the locking device was installed on this control switch for the sole means to apply a lock.  Whether they intended it to be a LOTO Lock (vs. some other type of lock) is unknown, but it appears a LOTO lock is provided and being used (although the key is still in the lock).  This is not an uncommon practice, i.e. to re-engineer a lockable device over a button on a control panel for the sole purpose of making "LOTO simple" - unfortunately, it makes it INCORRECT and UNSAFE.

control switch with key in LOTO lock

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