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| What is the Lockout/Tagout Standard? |
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Lock-Out/Tag-Out, or "LOTO",
is the second most cited OSHA regulation violation. The primary applicable
regulations are OSHA §1910.147 Lock-Out/Tag-Out, §1910.269
for Electric Power Generation, Transmission and Distribution and §1910.268
for Telecommunications. These rules require that all energy sources
be turned off and either locked out or tagged out while performing
service or maintenance work. By protecting the worker from accidental
release of energy (electrical shock, mechanical action, heat, etc.),
these rules are saving hundreds of lives yearly.
Although tags are generally used in conjunction with a lock (preferred
by OSHA), many utilities still use tags alone. When the company trains
and tracks religiously and effectively, this mode works safely. In
writing the OSHA 1910.147 rules, the tags versus locks issue was debated
extensively. Ultimately, OSHA chose lock-out as the preferred and
safer way to ensure that equipment remain de-energized. Still, when
an energy isolating device was not capable of being locked out, they
also allowed “tag alone” use. Furthermore when the employer
can "demonstrate that the tagout program will provide a level
of safety equivalent to that obtained by using a lockout program"
[1910.147 (a)(3)(c)(3)]tags alone are also acceptable. This “flexibility”
may not improve safety. Many users and regulators acknowledge that
tags are much easier and faster to use. Thus, tags are more likely
to be implemented than a “locks-only” program. Indeed,
some field circumstances make locks impractical and perhaps more dangerous
than a tag. Nonetheless, in developing your own LOTO program, we recommend
you honestly assess your training effectiveness, your written procedures
and your workforce's capabilities and come down firmly on the side
of safety. |
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