July 19, 2006

[Name and address withheld]

Dear [Name withheld]:

Thank you for your April 7, 2006, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. You had a question regarding OSHA's Electric Power Generation, Transmission and Distribution standard, 29 CFR §1910.269. Your paraphrased scenario, question, and our reply follow.

Scenario: An electric power generating facility, utilizes lockout/tagout (LOTO) practices in accordance with 1910.269(d). The plant is continually manned by operations personnel; and the operations supervisor coordinates all affected work forces to ensure continuity of protection for the crew members. When a LOTO is initiated and blocking points are selected, the shift supervisor selects a group lock box containing a sufficient number of field locks to accompany the printed lockout tags.

All keys for the field (equipment) locks remain in the group lock box, which is secured by the shift supervisor's individual gold lock. The supervisor's gold lock key is passed between shifts by the supervisors. Once the scope of work and blocking points are discussed with the affected work force, employees verify the LOTO blocking points and place their personal locks on the group lock box along with the shift supervisor's gold lock.

When it is necessary to test or manipulate a device that is part of an existing LOTO, the facility personnel strictly follows the [test or positioning] guidelines in 1910.269(d)(8)(i)(A) through 1910.269(d)(8)(i)(D). In addition to clearing the area, signatures of notification are obtained from all employees associated with that job, and a visual caution tag is applied to the device being tested or manipulated. Employees are tracked by documentation, computer tracking, and have access to an assigned site authorized employee for each job.

Question: When a field lock must be removed from a locked device, for testing or manipulation, as described in 1910.269(d)(8), must the shift supervisor gain access into the group lock box to retrieve that individual field-lock key, or can he remove the field-lock by other means — i.e., bolt cutters, secured master locks, etc.?

Reply: The core concept of lockout/tagout is personal protection such that each individual worker controls his/her own lock or tag. In your scenario, all of the personal lockout devices and the shift continuity device (gold lock) attached to the lockbox must be removed to gain access to the keys for the field lock(s). The removal of a field lock prior to the removal of the lockout devices by-passes individual control over the potentially hazardous energy sources.

Lockout/tagout device removal may not be based on convenience — i.e., it may not be done simply because the employee is not available at the LOTO location, but is still at the workplace. These steps are necessary to ensure that the employee who is protected by the device is not exposed to energy hazards either at the time of its removal or after its removal.

OSHA allows temporary removal of LOTO devices and the re-energization of the machine only when necessary to perform particular tasks that require energization — i.e., when power must be restored to test or position machines, equipment, or their components. When an energized state is no longer required and additional servicing or maintenance work is to be performed, the authorized employees must again de-energize the machine/equipment and resume the energy control measures. See §§ 1910.269(d)(7)(iv) and 1910.269(d)(8)(i). In such situations, you may consider using an energy control procedure that administratively requires employees to remove their personal locks from the lockout point on the master lockbox (or satellite lockbox, if used) when they are finished with the specific job task or leave the workplace. This procedure would provide an effective control alternative to requiring supervisory action to remove each employee's personal lock (because they are not at the facility), and it would enhance the shift supervisor accessibility to the keys for the equipment locks.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs