Does your facility “Car Seal” or “Lock Open” Valves? Do NOT use your LOTO Locks!

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Details: Parent Category: Safety Info Posts; Category: Chemical Process Safety (PSM/RMP); Published: 18 March 2012

It is becoming more common to find facilities using or at least “experimenting” with some “car seal” program or, as some call it, the “Lock Open – Lock Closed” program. These are the programs where a valve has been identified as a safety critical valve and needs to either stay closed or open until certain procedures have been carried out. To ensure this, the facility will either place some seal on the valve or use a lock to keep it in a safe position.

I encourage every facility to have this type of car-seal program, as most facilities covered by a commercial insurance carrier are most likely already using some variation of this on their sprinkler risers.

Do you have locks on your sprinkler risers to prevent them from being closed?

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Comments

#2 Bryan 2012-03-18 23:46

Larry, I would never argue with an attorney of your experience and have no doubt you could get someone out of a citation for the scenario you described. But .147 is pretty clear to me... identify locks by color, shape, or size and then use ONLY those locks for LOTO and nothing else. As OSHA stated in the preamble, at 54 Federal Register 36671 (Sept. 1, 1989): "... the sight of a distinctive lock or tag will provide a constant message of the use that the device is being put to and the restrictions which this device is intended to convey. If lockout or tagout devices are used for other purposes they can lose their significance in the workplace. For the energy control procedure to be effective, these devices must have a single meaning to employees: 'Do not energize the equipment when such a device is affixed to it."
I have always taken LOTO to extremes as workers lives depend on it. But in my eyes using LOTO locks for carseal is a violation of .147 and weakens my LOTO program.

#1 Larry Halprin 2012-03-18 23:31

Bryan: You provide a tremendous service to the H&S community. In this case, even if you are correct, it represents compliance for the sake of compliance, not safety. First, no lock should be haphazardly cut off equipment. Second, the OSHA LOTO rule says that lockout devices and tagout devices "shall be singularly identified [and] standardized within the facility in at least one of the following criteria: Color; shape; or size." If one uses a lockout device, a tag is not required. If one uses a tagout device, a lock is not required. Therefore, one could make a persuasive argument that use of a lock (of the type used for LOTO) in combination with a significant white laminated tag for LOTO and use of a lock (of the type used for LOTO) in combination with a significant red tag for locking a sprinkler value would utilize a unique and standardized LOTO device (the combination of the lock and colored tag) and OSHA would look pretty silly issuing a citation under those circumstances.

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