I am an Electrical Inspector at Los National Laboratory. I have copied below a posting that I have on Mike Holt's forum page for your consideration. I think we have a very serious oversight and problem with 70E LOTO procedure. I am trying to get as many folks as possible involved that I think may send in proposals before the closing date. There is no way that we should have let this go through without comment and objection. The sad part is it was in the 2000 edition also. I think if we get enough people on board they will have to accept someone's proposal. Take care, and thanks for any help.
Here is my opinion and concern:
I have very serious concerns related to the present language in the NFPA 2004 70E Complex LOTO Procedure. I intend to address my concern with a proposal prior to the closing date of 11/25/05.
1. NFPA 70E 2004 Article 120.3(D)(3)(c) which states in part; ..."the person in charge shall be permitted to install locks/tags, or direct their installation, on behalf of other employees," is in direct and irreconcilable conflict with 1910.147(f)(3)(ii)(D) which states,
"Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained."
2. Some argue that NFPA 70E 120.3(D)(3)(b) addresses the issue by requiring the person described as "in charge," be qualified.
3. I contend that NFPA 70E 120.3(D)(3)(b) is nothing more than a halfhearted attempt to comply with 1910.147(f)(3)(ii)(A), 1910.147(f)(3)(ii)(B), and 1910.147(f)(3)(ii)(C).
4. What it so critically leaves out is the very strong "and" at the end of 1910.147(f)(3)(ii)(C) that puts the entire rule back in proper perspective with the very plain statement at the start of 1910.147(f)(3)(ii)(D). (See above)
5. Simply stated, one person cannot hang a lock and tag for another.
I do not want to see us go backwards and allow an "in charge" person, qualified or not, to hang locks and tags for another. One man, one lock, one key, one life still makes good sense.
What I hope we can generate is a national discussion that will provide some quality proposals to the 70E Technical Committee that will change the present rule. Any help will be appreciated, it does not matter to me whose proposal is accepted as long as the present rule gets changed. If you do decide to submit a proposal to the Technical Committee, you can download an NFPA Technical Committee Document Proposal Form at the NFPA site. Please keep the closing date in mind.
Thanks to all for any help. I have no doubt that this rule will eventually be changed to be in line with OSHA, what I feel we can not wait for is a "body count" first.
