Hi all,

We have several assembly bays in which we will typically switch to off and apply a general lock when the bay is not in use. However, I am wondering if that lock needs to comply with LOTO requirements? My service folks are telling me that since the switch is off for the reason of no equipment in the bay, it is considered to be "out of service" and therefore LOTO doesn't apply.

My concern is that several people have access to the key for the lock and that once new equipment is placed in the test bay and ready for assembly, LOTO is required. I'm thinking we need to place Out of Service tags on the locks and follow LOTO.

Any suggestions?

Thanks

I agree with your last statement above, but you didn't mention why the lockout would be needed with equipment in the bay. If, in fact, the locks protect personnel from the uncontrolled release of hazardous energy, then I agree with you - lockout is legally required. On the other hand, if there is no reasonable expectation that hazardous energy will be released, I don't think lockout is necessary. Sometimes, over-application of lockout weakens the program instead of strengthening it.

See OSHA 1910 subchapter O. Also we use locks instead of switches or bolts on MV gear to comply with NEC accessible rules over 600 volts but all locks are keyed to electrical department common key. Not LOTO either.

Paul/TWM22,

Thanks for the replies. I guess I am more concerned with the unexpected release of energy, as it pertains to the setting up of the equipment. Multiple people are involved in the set up and energizing of a bay and potential for accidental energizing of the incorrect bay could occur. I was thinking of the pad being LOTO so that potential would be eliminated. However, I have a few people that would probably argue with me that it isn't an OSHA requirement and therefore isn't needed.

Calling it LOTO is not a good idea. The hazard may exist in which case you have to protect against it. But if you expect multiple users and treat it under subchapter J/R/S LOTO then it becomes a complex lock out and much more cumbersome to implement. If you treat it as accessible to authorized personnel only or Subchapter O rules then essentially you can implement any rules as long as you are consistent. This is like an E-Stop...call it that and OSHA expects certain things that make compliance cumbersome; call it just stop or process stop then you can do whatever you want.

If I understand your question correctly you are shutting down the bay with switchgear that is turnning off a buss or a complete distribution point. Then connecting equipment that is not yet in production, and then doing setup work on that equipment from time to time.
I see it as two issues.
1- no activity and no work being done in the bay is an Out of service condition. the switchgear for the bay would be taged out of service and a non LOTO lock used.
2- as soon as the new equipment is being connected a LOTO lock and tag must be used. once the work is completed and a local disconnect is in place for the eqipment. The switch gear could go back to out of service and if work is being done on the new equipment a LOTO lock and tag would be used on the local disconnect.

Hello Junior
I anticipate from your comments above that there is just one lockout (energy-isolating device) location? From what you have described the initial lockout is really for equipment protection, in oppose to personal protection. The Bay is not being used however you do not want to have personnel being able to inadvertently turn the disconnecting means on resulting in possible injury, even though there appears to be no loads connected. However we now have a second part where equipment is being moved into the bay and being connected. My question is how many machines approximately?

Could we not try this? Anticipating that there is only one disconnecting means that shuts off the entire bay. No worries if there is more than one. This forthcoming information relates to CFR 1910-147 and what we refer to here in Canada as Group Lockout. You assign one authorized person (Primary Authorized Person) to conduct the initial lockout when the bay has no equipment. The Key for that lock would go into a lockout box, conveniently located in the facility. This lock would be referred to as a company or equipment lock. This Primary authorized person would then install their personal lock on the lockout box. The key remains in he possession of that person. As equipment is being installed in the bay, other Authorized Persons, once they have verified the initial lockout, or have walked the job, would then install a personal lock on the lockout box and retain their personal key

My apologies for the long winded message here. However could this work for you?

Best regards
Len Cicero
Ontario, Canada