RETJW,
Welcome to ECN.
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Thanks for posting this here and having read your post I can agree fully with what you are proposing.
LOTO is a very important part of our workplace safety practice and to have it "watered down" by legislation would not be good at all.
I would expect as a minimum, that any person who is applying Tags in a LOTO system, have relevant Electrical Qualifications.
Simply stated, one person cannot hang a lock and tag for another.
Yes and I agree, I look at a Lockout Tag as part of my PPE, just like my Testers and Live Gloves and there is no way that I would ever let another person use them, they are after all keeping me alive.
I'd like to hear other peoples thought's on this thread.