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 Post subject: LOTO Procedure
PostPosted: Tue Feb 26, 2013 1:38 pm 

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NFPA 70E allows for single energy sources (simple LOTO) not to have a written LOTO instructions. OSHA 29CFR1910.333(b) does not. Anyone having to address this issue?


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PostPosted: Thu Feb 28, 2013 7:00 pm 
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1910.333(b)(2)(i) states: "The employer shall maintain a written copy of the procedures outlined in paragraph (b)(2) and shall make it available for inspection by employees and by the Assistant Secretary of Labor and his or her authorized representatives.
Note: The written procedures may be in the form of a copy of paragraph (b) of this section."

Sounds pretty simple to me. The employer must have a procedure. It doesn't have to be specific work instructions for every lock. In fact it doesn't have to be anything at all but a copy of the relevant section of OSHA regulations. It has to be made AVAILABLE. As in if you come ask me, I can show you OSHA 1910.333(b) on the Internet. You could also simply refer to 70E. This is NOT the same as having a detailed written procedure for every single lockout point.

70E, 120.2(D)(1) states that "Simple lockout/tagout plans shall not be required to be written for each application." Section 120.2(B)(3) states that "A plan shall be developed on the basis of the existing electric equipment and system and shall use up-to-date diagrammatic drawing representations." Sure sounds like a written requirement to me, for EVERY LOTO. The major difference is that complex lockouts require "a written plan of execution that identifies the person in charge" in section 120.2(D)(2)(8)(b).

All that 120.2(D)(1) is saying is to clarify that you can have a generic, written procedure for all simple lockouts. You can't do this for complex lockouts because the documentation must identify the person in charge. It is still possible to have a generic, written procedure covering all complex lockouts that includes a form that identifies the person in charge. It's just much more difficult to write one. We have one where I work at. It is around 15 pages long, triple that if you count some of the special cases (electrical, confined space, various crane/material handling scenarios). In the nuclear industry it gets so bad that they have an entire department of "permit writers" at each plant that specialize in doing nothing more than writing LOTO procedures.


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PostPosted: Mon Mar 04, 2013 4:45 am 
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OSHA is the enforceable code. As PaulEng stated, it's pretty simple to meet OSHA's requirement for simple LOTO.


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PostPosted: Mon Mar 04, 2013 6:16 am 

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OSHA requires written LOTO procedures with the following exceptions for single source of energy systems.

[url='http://arcflashforum.brainfiller.com/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0147&src_anchor_name=1910.147(c)(4)(i)']1910.147(c)(4)(i)[/url]
[INDENT]Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.

Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.[/INDENT]


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PostPosted: Tue Mar 05, 2013 11:40 am 
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Thanks for these clarifications, that is helpful to me --

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PostPosted: Tue Mar 05, 2013 7:06 pm 
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BISAM wrote:
OSHA requires written LOTO procedures with the following exceptions for single source of energy systems.

[url='http://arcflashforum.brainfiller.com/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0147&src_anchor_name=1910.147(c)(4)(i)']1910.147(c)(4)(i)[/url]
[INDENT=1]Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.[/INDENT]
[INDENT=1]Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.[/INDENT]


.147 is for nonelectrical lockouts. It clearly states this. All electrical work falls under .269(d) or .269(n) or .333 ot 1926.4xx or 56 or 57 CFR. There may be more but absolutely never .147.


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PostPosted: Wed Mar 06, 2013 1:54 pm 
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PaulEngr wrote:
.147 is for nonelectrical lockouts. It clearly states this. All electrical work falls under .269(d) or .269(n) or .333 ot 1926.4xx or 56 or 57 CFR. There may be more but absolutely never .147.


I would not agree with that. 1910.147 does very much so cover electrical lockouts. It covers hazardous energy controls of which electrical energy is one. The 1910.269 you referenced only applies to electric utility systems. 1910.333 is selection of work practices and the 1926 is for construction industries.
In fact there is this definition in 1910.147, "Energy source. Any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy." Seems to me electrical lockouts are included in 1910.147.

You state that 1910.147 clearly states that it is for nonelectrical lockouts. Could you provide the section in 1910.147 where that is stated?

Thank you.

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PostPosted: Thu Mar 07, 2013 6:41 pm 
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Since its in the very first section I don't know why you managed to find any other part.

1910.147(a)(1)(ii) This standard does not cover the following:
1910.147(a)(1)(ii)(C) Installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering; 1910.147(a)(1)(ii)(D) Exposure to electrical hazards from work on, near, or with conductors or equipment in electric-utilization installations, which is covered by subpart S of this part; and...

I'll give you credit for not being the first to totally disregard the scope of the regulation. Also be aware that construction (which is pretty broadly defined) is also descoped entirely from 1910.


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PostPosted: Fri Mar 08, 2013 4:56 am 
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PaulEngr - I did not see anywhere in the posts that this discussion was specific to working in facilities under the jurisdiction of electric utilities. Then .147 would not apply but .269 would. You made a general statement that .147 does not apply to LOTO for electrical equipment which is incorrect.

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PostPosted: Fri Mar 08, 2013 4:52 pm 
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Actually the original question was 1910.333, not 1910.269. Since my facility has a substantial cogen, 45 miles of overhead line, and a mine, I'm in the midst of drafting new policies that covet .269, .147, .333, 1926.4xx, and MSHA..Needless to say there are more similarities than differences, but I constantly have to deal with misunderstandings about the differences. The strangest one is that all requires locks EXCEPT 1926 (construction) that mandates tags but not locks.


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PostPosted: Mon Mar 11, 2013 7:31 am 

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1910.333(b)(2)
"Lockout and Tagging." While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph. The requirements shall be followed in the order in which they are presented (i.e., paragraph (b)(2)(i) first, then paragraph (b)(2)(ii), etc.).
Note 1: As used in this section, fixed equipment refers to equipment fastened in place or connected by permanent wiring methods.
Note 2: Lockout and tagging procedures that comply with paragraphs (c) through (f) of 1910.147 will also be deemed to comply with paragraph (b)(2) of this section provided that:
[1] The procedures address the electrical safety hazards covered by this Subpart; and
[2] The procedures also incorporate the requirements of paragraphs (b)(2)(iii)(D) and (b)(2)(iv)(B) of this section.


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PostPosted: Mon Mar 11, 2013 7:02 pm 
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The major purpose of note 2 is to deal with what is known as "complex" lockouts in 70E terms. Note that qualified personnel are required to do every step except physically putting a lock on (with lock boxes instead of directly applying individual locks to equipment) and shutting down equipment. Qualified personnel must do the hazard assessment, the 'try', test for absence of voltage, and any grounding. If it were not for note 2 then you might not interpret the regulation as allowing one group lockout box. .147 has similar provisions.


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 Post subject: Re: LOTO Procedure
PostPosted: Wed Nov 26, 2014 6:00 am 
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Martech wrote:
Lockout tagout or LOTO refers to specific practices and procedures to safeguard employees from the unexpected energization or startup of machinery and equipment, or the release of hazardous energy during service or maintenance activities. This procedure establishes the minimum requirements for lockout of energy sources that could cause injury to personnel.Lockout procedure is provided to assist employers in developing. Lockout tagout procedure purpose. is to prevent injury from the unexpected energizing, startup or release of stored energy that could cause injury.


Why are you resurrecting old threads just to add a textbook definition that isn't really relevant to the discussion?


Note: Deleted Martech posting quoted as it was not relevant and provided no value to discussion.


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 Post subject: Re: LOTO Procedure
PostPosted: Wed Dec 17, 2014 1:02 pm 

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269 doesn't require a Lock, a tag out system can be used if the employer can "demonstrate that it's as effective as a lock." Not that I agree with the tag system but it appears most utilities (mine included) use a tag system and forbid locks. Same exception is used in other LOTO standards, how we get away with it is beyond me, must be the money.


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 Post subject: Re: LOTO Procedure
PostPosted: Wed Dec 17, 2014 1:06 pm 
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generation safety adv wrote:
269 doesn't require a Lock, a tag out system can be used if the employer can "demonstrate that it's as effective as a lock." Not that I agree with the tag system but it appears most utilities (mine included) use a tag system and forbid locks. Same exception is used in other LOTO standards, how we get away with it is beyond me, must be the money.


This makes it awkward when a utility works with an industrial facility. One wants to use tags, the other requires locks on everything. We ran into that earlier this year when we were doing work on our main transformers (which belong to us but are of course fed from the utility.) Further complicated it was us employing a contractor that works almost exclusively with utilities, and thus doesn't understand how a lock system works.


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 Post subject: Re: LOTO Procedure
PostPosted: Wed Dec 17, 2014 1:29 pm 

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Our procedure allows contractors and customers to place Locks over our Hold Cards, ours go on first though, I should have clarified that the lock prohibition only applies to our employees.


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 Post subject: Re: LOTO Procedure
PostPosted: Thu Dec 18, 2014 7:52 pm 
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Appendix A of 269 which is hated by utilities explains the "overlapping" problem. If the equipment is 100% distribution, it falls under 269 rules. The customer has to follow 269. If it is strictly utilization, which you can pretty much approach as the last pole or tie, it is 100% subchapter S rules and locks are required. If it is mixed such as a lighting panel in a sub that powers the 125 VDC battery charger, then it must follow BOTH sets of rules. For convenience Appendix A references all the relevant regulations and there are a lot. Locks are required.This is true even if the lighting panel is in a transmission sub with no customer loads. This is a recent (2009) rule change to Subchapter R although it is in reality more of a clarification, not a real change. As to "equivalent protection" in general industry this clause also exists but I have not found an acceptable way to exercise it at least for maintenance. For operations with a risk assessment it can be done under subchapter O.


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