One of the most misunderstood concepts of OSHA’s Control of Hazardous Energy or Lockout Tagout 29 CFR 1910.147 is what “Lockout Tagout” actually means.  From a visual perspective, it’s common to see a padlock with a lockout tag attached to it, which leads many to believe that this is what is meant by “lockout tagout”, as you have the two physical features of a lock and tag.

This is not “Lockout Tagout”

The term “Lockout” is not the lock itself but rather the placement of a lockout device on an energy-isolating device ensuring that the energy isolating device and the equipment being controlled cannot be operated until the lockout device is removed.  The lock itself (or lockout device) must indicate the identity of the employee applying it.  While applying a tag to the lock is an acceptable means for identifying the person who applied it, it's not the only solution.  Alternative options include write-on locks or photo ID locks such as the one shown here from Master Lock.

So if a tag isn’t required with a lock, then what is “Tagout”?  Both Lockout and Tagout and forms of Hazardous Energy Control, but are different programs and methods.  In some circumstances, a lock is not possible or practical, in which case a “Tagout” program can be implemented if it will provide a level of safety equivalent to that obtained by using a lockout program. 

As one example, in order to block the flow of liquid in a large pipe, there are two viable options:  1) Close the valve(s) and apply a lockout device and lock, or 2) Insert a pipe blank, which is a solid disk bolted into the pipe section to block the flow.  The pipe blank can’t normally be directly locked out, so a tag is placed on the energy isolating device (pipe blank) to indicate that the energy isolating device and equipment being controlled may not be operated until the tagout device is removed.  So lockout tags can be used as a tagout device that informs workers that the device or equipment may not be operated until the tag is removed or identify a person’s lock or lockout device, but when used with a lock for identification, the process is still “lockout” and isn’t “tagout” just because a tag is present.

Although Lockout and Tagout are different methods of hazardous energy control, they both follow the same guidelines in terms of requirements for lockout tag out procedures to be written and the construction and design of the locks, devices, and tags being in compliance with the OSHA codes.

– Jim Schuster is CEO and a Lockout Safety Specialist at Martin Technical, Inc.

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