The employer’s primary means of providing protection to workers and meeting the requirements of 29 CFR 1910.147 is an energy isolating device. This prevents the transmission or release of energy and locks or tags are attached to it. An energy isolation device could be any of the following:
These devices guard against the accidental startup or unexpected re-energization of machinery or equipment during servicing supply chain explained or maintenance. There are two types of energy isolating devices: ones which can be locked and those that can’t.
When a device can’t be locked out, the employer must use a tagout. When using a tagout, the employer must comply with all the provisions of the standard and train all employees. This training must include information on the limitations of tags:
Tags are warning devices affixed to energy isolating devices and do not provide the physical restraint of a lock.
When a tag has been attached, it must not be removed except by the person who applied it.
A tag is never to be by-passed, ignored, or defeated in some manner.
Requirements for Tags
Tags must be legible and easy to understand by employees.
Tags and the means of attachment must be durable and able to withstand environmental conditions of the workplace.
Tags should be standardized according to color, shape or size.
Print and format should be uniform.
Tags must be substantial enough to minimize early or accidental removal.
Tags must be securely attached to the energy isolating device.
The means of attachment must be non-reusable, attachable by hand, self-locking and welding supply houston non-releasable, with a minimum unlocking strength of no less than 50 pounds.
The device for attaching the tag must have the general design and basic characteristics equivalent to a one piece nylon cable tie that will withstand all environments and conditions.
Tags must clearly identify the employees who applied them.
Tags must clearly warn against hazardous conditions if the machinery or equipment is energized.
Tags must contain a clear warning such as:
DO NOT START
DO NOT OPEN
DO NOT CLOSE
DO NOT OPERATE
DO NOT ENERGIZE
Full Employee Protection
If the energy-isolating device is lockable, the employer must lock it unless he can demonstrate that the use of tags would provide just as effective “full employee protection.” This includes complying with all tagout provisions plus implementing additional safety measures that can provide a level of safety to that obtained by using lockout. This could include:
Removing and isolating a circuit element.
Blocking a controlling switch.
Opening an extra disconnecting device.
Removing a valve handle to reduce the potential for any accidental re-energization while tags are attached.
Replacing or Modifying Equipment, New Purchases – All Must Be Lockable
OSHA recognizes that there are energy-isolating devices that can not be locked out. However, the standard clearly states that whenever major replacement, repairs, renovations, or modification of machines or equipment takes place, or when new machinery or equipment is installed, the employer must ensure that the energy-isolating devices are lockable. Modifying or purchasing these devices is most practical as part of the equipment replacement cycle. All newly purchased equipment must be lockable.