July 20, 2006

Mr. William Fiordimondo
361 Ferrell Road
Mullica Hill, NJ 08062

Dear Mr. Fiordimondo:

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 follow 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 and 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 by a means other than the field lock's key impermissibly 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, although still in the facility, is not available at the LOTO location. The procedures you refer to, at 1910.269(d)(8)(i)(A)-1910.269(d)(8)(i)(E), may not be used when the authorized employee is at the facility. Individual control is 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 prescribes procedures for the temporary removal of LOTO devices and the re-energization of the machine in order to perform particular tasks that require energization - i.e., when power must be restored to test or position machines, equipment, or their components. See §§ 1910.269(d)(7)(iv) and 1910.269(d)(8)(i).¹ 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. In such situations, you may consider using an energy control procedure that requires employees to remove their personal locks from the lockout point on the master lockbox (or satellite lockbox, if used) when they have finished performing servicing or maintenance or leave the facility. This procedure would provide an equivalent control alternative to requiring supervisory action to remove each employee's personal lock when the employees are not at the facility and it would enhance the shift supervisor's 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 may consult OSHA's website at http://www.osha.gov If you have any further questions, please feel free to contact the OSHA Office of General Industry Enforcement at (202) 693-1850.



Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs

¹ Section 1910.269(d)(7)(iv) provides that each lockout or tagout device shall be removed from each energy isolating device by the authorized employee who applied the lockout or tagout device before energy is restored to the equipment. This requirement also applies to the temporary removal of lockout or tagout devices for testing or positioning equipment under §1910.269(d)(8)(i). [back to text]