Lockout Requirement - Mike Holt's Forum

28, Jul. 2025

 

Lockout Requirement - Mike Holt's Forum

If it is capable of being locked out it must be locked out.

The control of hazardous energy (lockout/tagout). - .147

.147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.

.147(c)(2)(ii)
If an energy isolating device is capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.

.147(c)(2)(iii)
After January 2, , whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device.

.147(c)(5)(ii)(C)(1)
Lockout devices. Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools.

.147(c)(5)(ii)(C)(2)
Tagout devices. Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie.
At what point is a lock not needed?
When you finish your work :grin:
or when there is an upstream lock.

If the disconnect handle is tagged and fuses are pulled? (doubt it)
This is called Tagout and can be used if per your company LOTO policy. Not considered to be as safe as Lockout since some helpful Jack-n-ape may decide the circuit *must* be powered up.

If the disconnect handle is tagged, fuses are pulled, and T-leads disconnected?
How about disconnect handle is tagged, fuses are pulled and contactor coil wire disconnected?
As the prior answer. Most Tagout policies don't require going so far. Again go and see your company LOTO; it is required to have the correct answer.

Or none of the above.
Your company policy may not permit Tagout per their LOTO policy

So in reality though peeps in the forum can help guide you to a reasonably safe conclusion on the LOTO issues they cannot really answer this question. Your company LOTO must be followed so you have to look it up there.

Otherwise when you run out of locks it becomes your boss' problem. Dept. Lock and Lock Box

Dept. Lock and Lock Box

Save On Locks:
A lock out station with Department lock out supplies should be part of any companies LOTO policy. The additional locks at the station along with the lock box allows one to us companies Department locks for equipment, put the keys from these locks in a lock box and lock the keys with a personnal safety lock. This meets the intent that a personal lock is used for lock out.
Example:
Machine has 8 primary power sources and 4 electricans working on machine then 8 Dept locks are used to lock out the 8 primary sources the keys are placed in a lock box and the 4 electricians place their personal locks on the box.
8 + 4 = 24 Locks required
8 * 4 = 32 Locks required without lock box.

ECPL Facilitator
This is called Tagout and can be used if per your company LOTO policy. Not considered to be as safe as Lockout since some helpful Jack-n-ape may decide the circuit *must* be powered up.

Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

.147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

Not true, if your company wants to they can use a tagout policy, very few do but I have seen them. Your quoted OSHA article says the opposite, it says if it cant be locked out you must have tagout procedures in your LOTO program, dosent say you cant use a tag system on something that can be locked out.
Save On Locks:
A lock out station with Department lock out supplies should be part of any companies LOTO policy. The additional locks at the station along with the lock box allows one to us companies Department locks for equipment, put the keys from these locks in a lock box and lock the keys with a personnal safety lock. This meets the intent that a personal lock is used for lock out.
Example:
Machine has 8 primary power sources and 4 electricans working on machine then 8 Dept locks are used to lock out the 8 primary sources the keys are placed in a lock box and the 4 electricians place their personal locks on the box.
8 + 4 = 24 Locks required
8 * 4 = 32 Locks required without lock box.

ECPL Facilitator

8+4=12 last I checked Interesting... Allow me to add a little twist to this thread. Lets say I have three small conveyor motors controlled by seperate contactors being fed by a common disconnect, all motors are within sight of by the way. One of the conveyors needs to be serviced, however, production can and wants to continue running product with the two remaining conveyors. Is it not exceptable to remove the energy source by removing the t-leads and tagging them indicating the reason why they have been removed? Does this fall into the catagory of .147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
? I know it might be suggested that each motor should be fitted with a lockable disconnecting means, but most of the production machine come into our plant with one common lockable disconnect. It seems to get a little confusing when I try to put the NEC, NFPA 79 and OSHA together.
Interesting... Allow me to add a little twist to this thread. Lets say I have three small conveyor motors controlled by seperate contactors being fed by a common disconnect, all motors are within sight of by the way. One of the conveyors needs to be serviced, however, production can and wants to continue running product with the two remaining conveyors. Is it not exceptable to remove the energy source by removing the t-leads and tagging them indicating the reason why they have been removed? Does this fall into the catagory of .147(c)(2)(i)
If an energy isolating device is not capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize a tagout system.
? I know it might be suggested that each motor should be fitted with a lockable disconnecting means, but most of the production machine come into our plant with one common lockable disconnect. It seems to get a little confusing when I try to put the NEC, NFPA 79 and OSHA together.


Hard to tell without seeing the system but that sounds OK As long as your written LOTO program reflects this . Not many companies EHS depts can justify or feel comfortable have a tagout system in place, nuclear plants and military facilities re the only places I have seen this allowed. You know, places that can make you dissapear for violating the LOTO policy.
Regardless of any in house polices regarding 'tagout' OSHA does not permit tag out unless the item is not capable of being locked out.

As posted above

.147(c)(2)(ii)
If an energy isolating device is capable of being locked out, the employer's energy control program under paragraph (c)(1) of this section shall utilize lockout, unless the employer can demonstrate that the utilization of a tagout system will provide full employee protection as set forth in paragraph (c)(3) of this section.

.147(c)(3)(i)
When a tagout device is used on an energy isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached, and the employer shall demonstrate that the tagout program will provide a level of safety equivalent to that obtained by using a lockout program.

You should read the OSHA stuff farther. Tagout is permitted in place of lockout under specific conditions. I also did presume that the company LOTO policy was in compliance rather than presume incompetence on the part of the company.

The Role of Lockout Tagout in Electrical Safety

The Role of Lockout Tagout in Electrical Safety

For construction workers, working with and around electrical equipment, electrical conductors or circuit parts, and power lines is a common occurrence. Therefore, safeguarding workers against electrical hazards is a critical element of workplace safety and health procedures. Recognizing this need, OSHA has put in place safety and health regulations 29 CFR Subpart S for the general industry and 29 CFR Subpart K construction industry related to electrical hazards to guide and support employers in implementing adequate safety measures in the workplace.

Read more

Moreover, employees who undertake maintenance, repair, and service work for electrical equipment and machinery are also exposed to electrical hazards. There is always the possibility of de-energized equipment becoming suddenly energized while employees are inspecting, servicing, or repairing electrical equipment, circuits, and conductors. Therefore, not only must employees fully understand the hazards associated with electrical work (for example shocks, burns, fires, explosions, and arc flash) but must be conversant with the lockout tagout procedures to operate within electrically safe work conditions.

De-energized means “Free from any electrical connection to a source of potential difference and electrical charge; not having a potential different from that of the earth.”

What is Lockout Tagout?

OSHA’s standard for the Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part .147, sets forth the work practices and controls employers must implement to prevent accidents associated with hazardous energy. This standard is not only for construction industry workers but workers across industries such as craft workers, machine operators, electricians, laborers, etc., using electrical or other equipment that can generate energy even when it is shut off.

The lockout tagout (LOTO) is a process whereby a lock and tag are added to any type of industrial equipment or machinery when it is shut down for repair, servicing, or maintenance as part of OSHA-recommended best practices. OSHA defines LOTO as “specific practices and procedures to safeguard all workers from the unexpected startup of machinery and equipment or the release of hazardous energy during service or maintenance”.

Goto MING JIANG to know more.

Importance of Lockout Tagout

Lockout Tagout supports the controlling of electrical hazards and facilitates an electrically safe work condition.

According to Article 100 of the NFPA 70E, an “electrically safe work condition” is a state wherein all energized electrical conductors or circuit parts that could potentially expose employees to electrical hazards are maintained in a de-energized state.

This means putting electrical equipment, conductors, or circuits in an ‘electrically safe work condition’, can temporarily eliminate electrical hazards for the duration of work activity on or near energized electrical components. The process involves disconnecting from energized parts, locking and tagging, testing to verify the absence of voltage, and when required, temporarily grounding for worker protection.

The Lockout Tagout Procedure

The lockout tagout procedure can be broken into six steps. When employees begin repairing or doing maintenance work on electrical equipment, they must ensure to follow these steps to ensure their safety and the safety of other employees working in proximity to them.

Watch this animated video to get a better idea about the lockout and tagout procedures.

However, for comprehensive training in compliance with the OSHA standard for the Control of Hazardous Energy, enroll in our OSHA Lockout Tagout (LOTO) Training. If employers and employees require in-depth details on electrical safety, enroll in our Electrical Safety Training course which is in accordance with Federal OSHA Regulations 29 CFR Subpart S and 29 CFR Subpart K as well as the National Fire Protection Association (NFPA) 70E standard.

Bonus: General Safety Tips!

Below are some general safety tips when working with electrical equipment, conductors, and circuits.

If you want to learn more, please visit our website Electrical Lockout.