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.
RETJW, Welcome to ECN. 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.
I have seen/managed several different types of LOTO programs and I would not necessarily call one "good" simply because it requires personal locks. Although I agree with you both on the 1 lock/1 person rule as a best management practice.
Master locking/Operations Locks have a long history of being very effective in Power Genration, Trans and Dist. Signing on and off to a LOTO can be very protective provided the system is good. i've been witness to LOTO's that include 50+ people. although this is not excuse to sacrifice safety, 50+ locks could pull a circuit breaker Lockout device off.
Although given the option, I use my overlocks/overtags!
Re: NFPA 70E 2004 Complex LOTO Procedure#150443 04/02/0504:43 AM04/02/0504:43 AM
My real problem with this is that if one person can place a lock for another, that can be interpreted to mean that the manager can remove a lock for another employee.
I couldn't agree more with a statement like that. Although it is written into law over here in NZ, that the person that affixes the tag is the only person authorised to remove it, I can see some Factory Managers over here that would just love to see that rule repealed, so that they can have the gear working again as soon as suits them, not the personnel actually working on it. Having any such wording in the OSHA regulations, will kill someone one day, if not before.