July 27, 2023

Thomas Van Hooser
131 Northwest 10th Court
Baca Raton, Florida 33486

Dear Mr. Van Hooser:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the verification of energy isolation and placement of lockout/tagout (LOTO) devices while using a group lockbox system. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased scenario and questions are below, and OSHA's responses follow.

Scenario: A group lockbox is positioned in an area remote from the main electrical energy isolation device. The energy isolation device is located in the motor control center. An authorized employee isolates and locks out the main energy isolation device located within the motor control center. That employee places the key to the de-energized isolation device inside a group lockbox and places their lock and tag on the group lockbox and retains the key. Other authorized employees, who are also part of the work, place their locks and tags on the lockbox and retain their keys.

Question 1: Does OSHA require all authorized employees, who place their locks on the group lockbox, to verify that the energy source was deenergized before performing servicing and maintenance work?

Response: No. When a primary authorized employee verifies isolation, all other authorized employees may, but are not required to, verify energy isolation during group lockout. In accordance with OSHA's Compliance Directive 02-00-147:

When a primary authorized employee verifies isolation, all of the authorized employees participating in the group LOTO must be informed of their right also to verify the effectiveness of the lockout measures and must be allowed to personally verify that hazardous energy sources have been effectively isolated, if they so choose. An authorized employee who opts to verify the effectiveness of the isolation measures must perform this verification after affixing his personal lockout or tagout device to the lock box and before performing servicing/maintenance activities.

Question 2: How could a change of condition(s) (e.g., where the lock at the motor control center was tampered with, cut off, or otherwise any abnormal situation that could cause a concern to worker(s) doing work on the field equipment) be identified if all authorized employees do not verify that all energy sources were deenergized?

Response: Intentional tampering with a lockout or tagout device is not a known or predictable hazard and is not covered by the OSHA control of hazardous energy regulation. However, employers are required to use specific procedures to ensure continuity of hazardous energy control, including provision for orderly transfer of lockout or tagout devices between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.

Question 3: Does the group lockbox have to be located in the same facility as the main energy isolation device?

Response: No. OSHA does not require the group lockbox to be located in the same facility or secured at a designated location. Employers must develop and use a procedure that affords employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device. OSHA's Compliance Directive 02-00-147 provides examples of various procedures that can be utilized during group lockout/tagout, including the use of master lockbox/tagbox and the use of satellite lockbox/tagbox.

Question 4: Does OSHA require group lockboxes to be securely mounted at a designated location (e.g., on the wall) in general industry facilities or on construction sites?

Response: See the response to question # 3 above.

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 https://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Kimberly A. Stille, Director
Directorate of Enforcement Programs