Can a businesses use tagout when lockout can be used on the energy isolation device?. Simply put, locks MUST be used when they can, UNLESS the employer can demonstrate that their tagout will PROVIDE FULL EMPLOYEE PROTECTION.
Here is the exact language from 29 CFR 1910.147:
1910.147(c)(2)(i) If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
1910.147(c)(2)(ii) If an energy isolating device is capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.
When we say that a “Tagout will provide full employee protection” OSHA uses the term “Tag-Plus-One” to explain that ONLY placing a tag on the energy isolation device is NOT acceptable and does not provide full employee protection. The 2008 LOTO Compliance Directive (CPL 02-00-147) states the following in regards to this requirement: (emphasis added by me)...
A key element in demonstrating that the tagout program provides equivalent protection to a lockout program is the standard's provision that the tagout program provide at least one additional safety measure. In other words, at least one added safety measure must be used in addition to tagging the energy isolation device to prevent unexpected re-energization. This independent, additional measure is designed to protect an employee from injury or death through the inadvertent activation of an energy isolating device associated with human error, inadvertent contact, the loss or detachment of a tag, or from any other limitation of tags. Such additional safety measures might include the:
1. Closure of a second in-line valve (e.g., double block and bleed);
2. Removal of a valve handle to minimize the possibility that machines or equipment might be inadvertently energized or started;
3. Removal of an additional isolating circuit element (e.g., fuse);
4. Opening of an extra disconnecting device (e.g., disconnecting switch; circuit breaker);
5. Opening and then racking out a circuit breaker;
6. Grounding of an electrical circuit, if the grounding practice would protect the employee if the tagged isolating device were operated; or
7. Locking, blocking, or barricading a controlling switch.
Any additional control measure ("Tags Plus") must be integrated into an energy control program through sound hazard-specific analyses on a case-by-case basis. For example, the blocking of a control switch as an additional measure to tagging an electrical disconnect may be an effective second layer of protection for preventing the mechanical activation of a machine, but this block may be an inadequate "Tags Plus" measure for the same machine's hydraulic or pneumatic hazardous energy sources.
Refer to page 3-37 of the CPL and beyond for more or contact me or your OSHA office for help. LOTO is a LIFE SAVING procedure when developed, implemented and managed properly.