DOE OSH Standards Interpretations Response Line

Section 6 - Lockout / Tagout

Frequently Asked Questions (FAQs)

LOCKOUT/TAGOUT - 29 CFR 1910.147

• What does OSHA/DOE require for certifying training under 1910.147(c)(7)(iv)?

• Are there any interpretations that deal with the situation of worker who has not received the LOTO training, but who must enter an area where LOTO is in effect? Could that employee enter with an escort? For example, access to an overhead area in a reactor requires that the overhead crane be locked out to prevent it from rotating which would misalign the access ladders. An employee may only need to access this area once.

• Under the lockout/tagout standard, is lockout/tagout required in the situation where the repair technician of a piece of machinery, such as a pump, is in direct control of the wall switch? The caller recognizes that there could be a problem if the technician had to leave the area before the repair job was completed, but if the technician is right there continuously, does the switch have to be locked out?

• Are there any requirements for logs in the OSHA lockout/tagout standard, 1910.147?

• The caller is in the process of reviewing their lockout/tag out program and would like to know if it is acceptable to OSHA and DOE to exclude from their program any work on piping systems that have pressures less than 15 psig or temperatures less than 120 degrees fahrenheit. They do not consider these conditions to pose a risk to workers.

• Is there a requirement for each employee to hang a tag when he hangs a lock in a lockout/tagout? Is there a difference in the electrical requirements for this under 1910.333 and under the general requirements under 1910.147? The previous prime contractor required every man to hang a personal lock and a personal tag on each lockout/tagout. The current prime contractor is only requiring a personal lock, which is number coded to the employee, and is not requiring each employee to also hang a personal tag.

• Does each affected construction employee in an operating contractor's facility have to have a personal lock or tag affixed to a lockout/tagout? Must it be each authorized employee or a designee of that group? Is a group lockbox required? In the caller's situation, the foreman puts on a lock for everyone.

• Within the LOTO standards and codes, what are the specifications for how long used tags must be retained before being disposed or recycled? Also, are there specifications for how long completed LOTO Logbooks or similar records must be saved or stored before being discarded?

• 1. There is some debate about the meaning of "capable of being locked out" in 1910.147(b). If a ball valve has no built-in locking device associated with the handle, but it will accept a locking device sold by a manufacturer, is the handle considered to be "capable of being locked out"? An alternative to attaching a locking device is to remove the handle after positioning it in the proper position. A tag is then attached to the handle attachment point. If a purchased locking device is included in the definition of "capable of being locked out", then the alternative method would not be acceptable under 1910.147(c)(2).

• What is the hierarchy of controls under 1910.147? The Manual chapter is not clear on this. Is the first priority lockout, followed by tagout?

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Last modified: 04/18/96 08:50:32