Have you ever seen/heard of this LOTO practice before?

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Details: Parent Category: Safety Info Posts; Category: Lockout Tagout; Published: 01 September 2012

LO vs TO Last year, we came across a very interesting LOTO practice that we completely disagreed with, but we were the only ones in the room who were not in agreement, so I think we may need to be "calibrated" in our LOTO expectations! I am not saying I will ever agree with this practice at a facility I am managing, but we were at a VPP site, and the safety professionals were truly world-class in many aspects of safety and health, so I thought maybe it was just me getting old and set in my ways.

The practice involved using a specially colored, self-locking, non-reusable nylon tie wrap (the color and design of these nylon tie wraps were specified in their written program) and a LOTO-prescribed tag to secure an isolation device in the safe position. Now, I will give credit here; the practice was to "secure" the isolation device in the "safe position." But when I read and observed the practice, this was a "tagout" and not a "lockout."

The facility viewed this practice as a "lockout" since the nylon tie wrap(s) were the locking type and were being used to "secure" the isolation device in the "safe" position. No lock is used, only the specially colored nylon tie wraps and their prescribed LOTO tag. Here is more...

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Comments

#5 Mark Warnow 2012-09-20 16:17

Quoting Bryan:

THANKS Walt! Do you know why OSHA archived the 2004 LOI you referenced?

I would like to know why as well. I'm not saying I agree with the method; however, I'm also not ruling out the idea that there may be circumstances where it might make sense.

#4 Steve Martin 2012-09-20 01:04

I thought OSHA stated the lockout device is "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." My point is the nylon cable ties requires no key or combination used to lock or unlock the device. A pocket knife is suffice, thus is not proper LOTO.

#3 Araceli Andrews 2012-09-14 13:48

Yes, I have seen this type of LOTO practiced; not uncommon among power plants and Naval ships. Historically, equipment not designed for the application of locks were "grandfathered-in" and tagged-out so long as frequent audits were completed and documented. Thank you...

-1 #2 Bryan 2012-09-03 20:57

THANKS Walt! Do you know why OSHA archived the 2004 LOI you referenced?

+1 #1 Walt Siegfried 2012-09-03 03:20

The nylon tie question has been addressed in OSHA’s December 7, 2004 letter. Specifically, the Agency reference the 1910.147(c)(5)(i) provision stating that: “Nylon cable ties are generally removable through the use of common cutting tools (e.g., pocket knives, side cutters, or scissors) or by releasing the pawl mechanism with a device such as screwdriver; neither of which constitutes an "unusual technique," as required by the standard.” Unfortunately, the LOTO standard has no LO device strength specification – i.e., similar to the tagout attachment 50 pound provision. Rather, OSHA relies on a generic statement that the type of lockout device must be substantial enough to prevent its removal “without the use of excessive force or unusual techniques.” In terms of effectiveness, a taut, substantial nylon tie may actually reduce the chance of hazardous fluid leakage because it can be drawn tighter (reducing valve throttle hazards) than a lock and chain device assembly.

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