OT: LOTO Transfer per OSHA 1910.147(a) Over Non-Concurrent Shifts

[MikeW]

It's not directly PLC related but it is probably a problem that some forum members have solved in the past.

The issue I have is that we are working two shifts to commission a new facility that has various sections of it locked out for various reasons: Utilities are run to the machine but need to be locked out while the commissioning process is on going for equipment that will use that utility. We can transfer employee locks during first to second shift change but there is no one is at the facility during third shift. We are basically doing a partial lock out of only the items we are doing maintenance on.

We have a lock box that initially had 24 locks in it as there are many subsystems that are being verified by a number of employees. Employees add one of these facility locks to whatever valve, disconnect, etc. where they will be working and then put their personal lock on the group lock box.

The last man to unlock on the late shift can then tag out the lock box with a 50# strength wire tie that is cut by first shift before they start to reapply their locks is the current method. Is there an acceptable / better way to install a lock with a key that that can be transferred to the first shift somehow?

 

[osmanmom]

it's look,

digging our own grave

 

[jparale]

Do you have a separate utility supplies for each of your machine? Anyways for lock out tag out (LOTO) rule states that the only person that can remove a lock out is his own. And if you need to remove somebody else's lockout there are procedure to be followed. And also after doing so, there should be a sign out sheet that needs to be filled up stating the reason why you need to remove somebody else's lockout. This should also be approved by the Supervisor or the Manager. Basically you just need to make sure you cover your *** from what ever incidents that may happen.

 

[realolman]

how about a hasp with everyone's individual lock and then a "master lock " to which all of your people, but no one else, have a key?

I don't see much point in the wire thing, and what I just suggested would be somewhat similar, except for the strength of the "wire". Although I personally think that a wire should be sufficient in any and every case...

If the stuff you are working on is left in a safe state... ie. wires wirenutted , gas lines plugged etc. , I don't see the need for any locks or wires as it should be the responsibility of each person to apply his lock when he works on it for his own safety . I see no difference between equipment that has recently been maintained and equipment that has run for years.

I don't know that it is the purpose of LOTO to keep people from turning on equipment that simply doesn't operate. Seems to me an informational tag stating why it should not be turned on should be sufficient.

 

[OdinIII]

We have an interim lock process that says anytime the equipment can harm a person or itself, an interim lock must be in place.

The locks are color coded for each department/responsibility and everyone in the department has a key.

This lock is only used to protect the equipment and people while the machine is not being worked on. Working on the equipment with an interim lock is the same as no lock. All normal LOTO policy applies, after removing the interim lock you must start at the beginning of the LOTO procedure.

 

[MikeW]

Clarification: This machine is in the initial commissioning phase so a lot of things are being done to check out the various subsystems. There are three separate steam pressure supplies to the unit, three water utility connections, three refrigeration loops, four VFDs and about a dozen disconnects for various electrical loads in the ten "mini machine skids" that makes up the complete machine. We are minimizing total lock outs and isolating only the parts of the machine that need to be made safe as some of the skid are being operationally checked while an isolated subsystem is being modified. When another lock is needed, everyone needs to unlock to get to the master key to add another lock on a subsystem.

jparale:
Everyone has their own key and follow what is required per OSHA. Removing someone else lock is not done without the Plant Managers approval and he doesn't give that very freely (as should be the case). There are many utilities that feed these mini-skids and we are treating each skid with basically a mini LOTO procedure.

CYA is not a problem, our facility is approaching 5000 days without a loss time injury, if you try to do anything that even looks to be not safe a fellow employee will stop you as we have a great safety culture.

realolman:
We have a One Lock/ One Key rule so there are not extra keys, you loose your key, the Plant Manager needs to give the OK to cut the lock. We have only one Master Key to the 24 locks in the common lock box.

The wire thing is to use the Tag Out portion of the law (Tag = Lock but Lock is preferred) to get around having to cut a lock and spending $10 to get another one.

Second shift communicates at the end of their shift with First Shift via email to make sure what is locked and why.

 

[realolman]

Clarification: realolman:
We have a One Lock/ One Key rule so there are not extra keys, you loose your key, the Plant Manager needs to give the OK to cut the lock. We have only one Master Key to the 24 locks in the common lock box.

The wire thing is to use the Tag Out portion of the law (Tag = Lock but Lock is preferred) to get around having to cut a lock and spending $10 to get another one.

Second shift communicates at the end of their shift with First Shift via email to make sure what is locked and why.

I think I missed my point ... I was suggesting only that you replace the wire with a lock to which everyone has a key...

Is there an acceptable / better way to install a lock with a key that that can be transferred to the first shift somehow?

I took your OP to mean that you were not happy with the wire overnight. Would not a lock be "better" than a wire? When the wire "becomes" a lock does that somehow make it unacceptable? I thought ( often incorrectly ) that a tag was to be used only if there was no place to put a lock.


I was not suggesting that anyone perform LOTO to work on the machine with this lock... everyone would still have their own lock with their own key, and use it for LOTO.

And, after all this, it seems you have a system that you would rather defend than modify; therefore, I don't see the point of your original post

If you like the wire, use the wire... If you want a better wire, use a lock