OSHA and NFPA 70E refer to a Simple LOTO as involving only one person/conductors/circuit part(s). A Complex LOTO is when there are conditions such as more than one person/circuit/shift/source involved - A complex LOTO has significantly more requirements.

Here is this week’s question:

Have you ever performed a complex LOTO?
Yes
No

There are two additional problems that the simple/complex lockout create and this same issue exists with Subchapter J (general LOTO's) by the way.

The first is that MANY operations have no experience with a complex lockout at all and try to jump through all kinds of hoops to attempt to apply a simple lockout when in fact the complex one is required. Most of the time these are the same facilities that also fail to recognize that electrical lockouts have a different (more complex) procedure compared to general lockouts and attempt to apply the same procedure to both conditions. The resulting gyrations frequently leave employees open to exposure to hazards.

The second is that SOME operations (typical for large petrochemical industrial plants) have actually eschewed simple lockouts altogether and treat everything as a complex lockout.

Neither strategy is correct. A complex lockout has substantially more procedures and layers of procedures. Quite often the person actually putting locks on equipment is not exposed to hazards and thus has no personal responsbility (vested interest) in making sure it gets done correctly while the person who is potentially exposed has no idea whether or not the LOTO was done correctly or not. Theoretically adding enough signoffs, verifications, and other checks reduces the probability of failure but time and again what I've found in practice from auditing these things is that the whole process gets pencil whipped because nobody outside of the guy doing the work has any personal risk in assuring that it gets done, whether or not those individuals have enough personal experience to have a vested interest in making sure that LOTO gets done correctly.

In contrast simple lockouts push the responsibility down to the personnel who are potentially exposed to hazards. Although theoretically the employer is responsible for making sure that LOTO is done, ultimately responsibility lies with the person who the lock is protecting and the consequence affects that person more than any other.

Unfortunately it is the nature of complex lockouts that the ideal world of everyone having a personal responsibility and being subjected to all the risk of messing up a LOTO procedure cannot exist with complex lockouts. They are inherently more risky compared to the simple lockout. The whole purpose of the extra requirements in a complex lockout isn't to try to make them safer but to attempt to make an inherently less safe LOTO scenario (compared to a simple lockout) as safe as practically possible. Complex lockouts can never be as safe as simple ones.

Thanks Paul. I thought this one might create a bit of discussion - your views are appreciated.

I had a legal/forensic case a few years ago where a person working on his own thought a simple LOTO was good enough. Except the complexity included multiple sources, interlocks, and unforeseen interaction with an operating crew - it should have been a complex LOTO. He was trying to keep it simple as you point out. Long story short, he almost died and the injuries were horrific - he never went back to work.

I'm sure others may join in here as well.

Right now I'm in field service. On my second day as a full time employee I went to one customer's site that had 3 different crews (ours, the riggers, and the company's) on the same site. We worked over 12 hours that day...it was a 1250 HP motor but lots of things complicated what should have been a straight forward job. I was the electrical guy...the rest of the my crew were serving as mechanics (alignment, grease & oil it, etc.). It was my job to do a full PM on the starter (wound rotor) and wire up the motor.

So we pull up to the site and these two 5 year old kids are running around. I mean...it's an industrial site, and two boys think it's a big play ground. And once the motor was pretty much set, they started placing the 3" W beams and the sheet metal roof back in place WHILE we were still under it aligning and setting the motor. I took one look at our rookie (graduated from school about 2 months ago with an associates), pointed up at the roof, and said, let's just step out side for a few minutes for a smoke break. Neither one of us smoke so he looked at me funny until we were outside and I explained why we needed to go outside.

When it came time to re-energize everything the company guys came out and said, "Hey, who put a lock on the disconnect?" As in...they didn't even have locks, let alone use them. Oh and arc flash study? I'm sure they think arc flash is what happens if you just throw on your darkest sun glasses when you are welding.

To be fair this is probably the worst place I've been at so far. But most of the time I'm walking into somewhere that doesn't have anyone that is a "qualified" electrical person. If I don't lock it out, check for voltage, ground it, wear rubber gloves or arc flash PPE, nobody else is going to remind me.

When I was doing field service, I have been in both ends of the spectrum that have no qualified electricians:

1) 0 electrical safety - no one has a clue, no one cares that there are 575-volt panels wide open with nothing preventing someone tripping into a panel (which I have done because they put an inverted length of angle iron on the floor to protect the enclosure from fork trucks)

and 2) suit up with PPE for 40 cal/cm^2 for any electrical work regardless of the actual cal/cm^2.

Couldn't agree with you more Paul. In Generation we use the Complex only. So for the menial tasks the electrician doesn't bother getting the clearance because it takes too long, the work is performed without LOTO. Management doesn't care because the work was completed. When a LOTO violation like this is brought up the Plant Manager has gone as far as saying the LOTO policy was not implemented so there was no LOTO violation. And he has peers and Safety Personnel at two other facilities that go along with him. Stupidity at it's finest.

Unfortunately we are as you described, Operations determines and hangs the Clearances. They don't have their hands in it so they don't care, the clearances are spit out by the computer system that hasn't been updated with the circuit modifications that have taken place. Then the maintenance teams go out on their Easter Egg Hunt to find all the tags and initial them yet never look to see what on that list makes their job safe. Sad to say that Indiana OSHA has been called and not stepped up to the plate to protect the worker.

Hi Jim,

Just wondering. I chair the technical committee up here in Canada for CSA Z460- The Control of Hazardous Energy- Lockout and Other Methods. Back in 2003-04 when we were producing the first edition of this standard (2005 release) we utilized the ANSI Z244 - The Control of Hazardous Energy- Lockout and Oher Control Methods as the seed document to create CSA Z460. In looking at CFR (Code of Federal Regulation) 1910-147 they use the term "Group Lockout". We also use the terms - Individual Lockout, and Group Lockout in CSA Z460, which I also believe are the terms used in ANSI Z244. I was wondering why in NFPA 70E the terms "Simple Lockout" and Complex Lockout" are used? As this seems to be inconsisent with other standards and CFR 1910-147. Could the terms "Individual Lockout and Group Lockout" not be used in oppose to Simple and Complex?

Look at Subchapter S. Subchapter J (1910.147) is for general lockouts which is more or less as you were suggesting based on ANSI Z244. Subchapter S at least in the States is the electrical lockout and has a slightly different procedure from Subchapter J. Subchapter R (1910.269) has multiple variants of it's own as well in terms of lockout-tagout.

However I haven't checked entirely but I believe the terms "complex/simple" lockout only exist in 70E/Z462.

Thanks allot Paul. In CSA Z462, we refer to Individual, Group and Complex Group Lockout as per CSA Z460

Wow, I missed that entirely. The last time I reviewed Z462 was I think based on the 2009 or 2012 edition. As far as I could tell at that time the only difference is that the Z462 numbering scheme was 1.1.1.1 as opposed to the NFPA 70E one (mixed numbers and letters) which is really just a difference in CSA vs. NFPA formatting rules, and that Z462 has several additional Annexes that are not present in NFPA 70E. We never picked up on this slightly different wording although the way that we wrote it into corporate policy we basically ignored the LOTO policy because other corporate standards for this kind of thing already existed and we'd be stepping on toes.

The two are supposed to be harmonized. It would be nice at some point if someone would publish a "differences" list for those that have to deal with cross-border policies. One of these days it won't surprise me if Z462 deviates more from NFPA 70E just because some of the public inputs that the 70E Committee votes down may not be acceptable to the Z462 Committee. I think in the past the track record for acceptance from the Z462 Committee has been something like 25% acceptance rate.

Hi Paul

Yeah, that was part of the agreements with CSA and NFPA is that both standards would be technically harmonized. However the one major area of differences is in our article 4.2- Establishing an Electrical Safe Work Condition. For now it is a cut and paste of certain clauses found in CSA Z460 up here. That will change in the 2018 edition as allot of the content that was cut and paste is being removed. As you have indicated we have added a few annexes that are not in 70E. Another difference is in Clause 4.3.5.5 in Z462 for equipment labelling. Z462 asks for a 4th item, the date the information was determined, or date of evaluation. If you look in the Preface of Z462, NFPA still holds the copyright

During a recent maintenance task, I utilized a lockout box to ensure the safety of the personnel involved. The lockout box allowed us to securely store multiple padlocks, ensuring that the equipment couldn't be re-energized until all maintenance tasks were completed and each individual worker had removed their lock from the box. This comprehensive approach helped prevent accidents and ensured that the machinery was effectively isolated until all necessary work was finished.

Yes, I have experience with complex Lockout/Tagout (LOTO) procedures. In my view, adhering strictly to LOTO checklists and procedures is essential, but I also understand that the process can seem time-consuming. As a pilot, I naturally draw a parallel to aviation, where checklists are extensive, pilots often develop "flows" to streamline the checklist items. These flows help professionals work efficiently while keeping the checklist as a reference guide, similar to a map rather than step-by-step directions. Applying a flow-like mindset to complex LOTO situations can make them feel less burdensome without compromising safety. However, it's crucial to stress that critical safety steps should never be compromised for the sake of expediency. Safety always comes first.