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Safety Info Posts - Lockout Tagout
Written by Bryan Haywood   
Friday, 22 April 2011 18:11

The employer must ensure that specific procedures are implemented during shift or personnel changes to provide a continuity of lockout or tagout protection throughout this transition period. This assurance usually involves action by the authorized or supervisory employee (Primary Authorized Employee) responsible for the coordination of affected workforces and the continuity of LOTO protection. See §§ 1910.147(c)(4)(ii)(C) and 1910.147(f)(4). The responsibility includes the orderly transfer of lockout or tagout device protection between employees on outgoing and incoming shifts to ensure that the machine or equipment is safe to work on.

Generally, the transfer of responsibility can be accomplished by the oncoming shift accepting control of the system involved prior to the release of control over the system by the off-going employees. The orderly transfer of personal LOTO devices between offgoing and on-coming employees must ensure that there is no gap in coverage between the off-going employee's removal of her LOTO device and the on-coming employee's attachment of his device. The performance-oriented nature of this provision allows employers to utilize a variety of methods that ensure the continuity of LOTO protection during shift or personnel change. The following procedures are examples of methods that would provide such employee protection:
A. All authorized employees leave their personal LOTO devices in place until the job is completed. The energy cannot be restored and the machine energized until all the employees have removed their personal LOTO devices;
B. The on-coming employee(s) apply their personal LOTO devices before the offgoing employee(s) remove their personal LOTO devices (as many facilities have over-lapping shift work);
C. Each on-coming employee starts LOTO from scratch, in accordance with §1910.147, by applying and releasing LOTO for the entire period of time that the employee services a machine. The machine is returned to operational status, with all the safeguards in place, so that the next employee may perform LOTO; and
D. The use of shift or personnel transfer devices, sometimes referred to as LOTO continuity devices.

For example, where the off-going employee removes his personal lockout or tagout device before the oncoming employee arrives, the procedure may allow for the departing employee to apply another interim LOTO continuity device (Shift Transfer Device) prior to the time the employee removes his device. This interim procedural step would indicate that the departing employee’s lockout or tagout device has been removed, but that the machine or equipment has not been re-energized. The on-coming employees would affix his personal LOTO device before removing the LOTO continuity device, and each oncoming employee would then verify that the system was still isolated.

The Job Lock, also known as the Operations Lock or Production Lock, is another common method used to ensure the continuity of energy isolation during multi-shift operations. This type of lock is the first lock placed on the energy isolating device(s) or lockbox, and it is the last lock removed when the job is completed. Each primary authorized employee from each shift controls the key to the job lock. Each authorized employee attaches her personal LOTO device to the group LOTO mechanism (with the Job Lock attached) while she performs work on the machine or equipment and removes the device when leaving for the day or when the job is completed. By using this Job Lock method, the security provisions of the energy control system are maintained across shift changes, and this procedure provides adequate assurance to the on-coming employee that the machine or equipment is safe to work on. See Chapter 4, Section IV for additional guidance.

In other words, LOTO continuity devices are devised for shift or personnel changes and they differ from personal LOTO devices because their application is intended to ensure the continuity of employee protection during shift and personnel changes – pursuant to §1910.147(f)(4). The hardware for these continuity devices must meet the prescribed specifications, contained in §1910.147(c)(5). However, in lieu of identifying the authorized employee who applied the LOTO continuity device, an employer may alternatively identify the party responsible (e.g., operations department; maintenance department) for the application and removal of the continuity device as these organizational groups may be responsible for the application and removal of the shift/personnel transfer devices.

In addition, the requirements contained in §§ 1910.147(c)(8), 1910.147(d)(4)(i), and 1910.147(e)(3) do not apply to LOTO devices used to ensure the continuity of employee protection for shift or personnel changes. In other words, the authorized employee who applies the continuity device (e.g., Shift Transfer Device, Job Lock) may or may not be the same authorized employee who removes the continuity device, as long as these actions are performed in accordance with the employer's established energy control procedure. For additional information, refer to Chapter 4, Section IV on the Job Lock (Type D) control measure.

Another element for assuring continuity of protection is the requirement that each oncoming employee verify that the machine or equipment has been effectively de-energized and isolated. When LOTO devices (personal and/or continuity devices) remain on energy isolation devices from a previous shift, all of the on-coming shift employees must verify for themselves the effective de-energization and isolation of the machinery or equipment.  On-coming employees may not depend on the actions of other employees or supervisors, particularly those who have left the workplace for the day, for assurance that it is safe to work on the machinery or equipment.

NOTE: OSHA has recognized the need for an alternative to the verification requirement where complex LOTO operations involve many employees and numerous energy isolating devices. This procedure is described in Chapter 4 of the LOTO CPL.

 
 

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