OSHA provides the requirements for the control of hazardous energy in 29CFR.1910.147. The general requirements [1910.147(c)] are extensive. Let’s look at the requirements that pertain to protective materials and hardware [1910.147(c)(5)].
There are only two types of such items to be concerned about:
- Devices used for isolating, securing, or blocking machines from energy sources.
- Lockout and tagout devices.
The bulk of this subsection covers the second. But there are some things you need to know about the first. Examples are locks, tags, chains, wedges, adapter pins, and self-locking fasteners. From this list, you get the idea these are not about keeping the electrical circuit open but about disabling the machine from:
- Operating (e.g., lock on operator panel or keyed ignition switch in car).
- Moving (e.g., punch press blocks or wheel chocks for car).
- Or in some other way producing an energy hazard (kinetic, heat, chemical, etc.) to the maintenance person(s) inspecting or maintaining it.
Lockout and tagout devices must meet two lists of requirements. The first list in 1910.147(c)(5) is in paragraph form and the second is enumerated. Let’s combine those:
Lockout and tagout devices must be:
- Singularly identified. This is so they are not confused with anything else. For example, only red colored locks can be used at plant X for lockout/tagout and that color is banned for all other locks.
- The only devices used for controlling energy.
- Used for no other purpose.
- Durable. OSHA provides some verbiage, the crux of which is these things have to withstand the environment in which they are used.
- Standardized. At a given facility, they need to have a consistent look. Even if they are all just the same color, that will satisfy OSHA.
- Substantial. The lockout devices must be stout enough to prevent removal without excessive force or the use of things like bolt cutters. Tags, and their means of attachment, need to be such that inadvertent or accidental removal is prevented.
- Identifiable. The lockout and tagout devices must indicate the identity of the employee applying those devices.
Any electrical distributor in the commercial/industrial market will carry at least one line of these devices. All of the design work is already done for you, all you need to do is pick a lock style and a tag style for your facility.
Think of the tags as consumables. Min/max them so that you never run low, much less out. You will replenish these much more often than you will replenish or expand your inventory of locks. That is an easy solution for the tags. For the locks, things are trickier because one set of locks is not interchangeable with another. Joe’s key should not open Mike’s lock; that would defeat the purpose of Mike’s having hung a lock in the first place.
The simplest solution is also the most economical: overbuy on locks so that nobody ever comes up short. If it costs you $18 each for six locks keyed alike when you “need only four,” that’s $36. If you have 20 maintenance people, that’s $720. If you have a machine producing $450,000 an hour of revenue and it has to sit for two hours while someone gets five lockout locks keyed alike for Jim and another five for Brad, that $720 is a rounding error.
