Q. Can a duplicate key for the purpose of lock removal under LOTO be held in a secure area with a procedure in place for access to the key and returning the key that does not jeopardize the employee’s safety?
A. Here is a paragraph from an OSHA letter of interpretation dated February 28, 2000, that may be applicable to your situation:
The use of a master key to remove a lockout device would be deemed equivalent (to the removal of the lock by the person who applied it) only if it is performed under the employer’s direction and in accordance with the requirements established in 1910.147(e)(3).
Obviously, the “one person, one lock, one key” practice is the preferred means and is accepted across industry lines, but it is not the only method to meet the language of the standard. However, before the use of the master key method, specific procedures and training, meeting the §1910.147(e)(3) exception, must be developed, documented, and incorporated into your energy control program.
Among the features essential to a compliant master key procedure is a reliable method to ensure that access to the master key will be carefully controlled by the employer such that only those persons authorized and trained to use the master key in accordance with the employer’s program can gain access.
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Q. If equipment has a safety interlock and its own safety disconnect built in the unit, would it still need to be included in a lockout/tagout policy?
A. According to 1910.147(c)(4)(i), procedures must be developed, documented, and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.
You need not document the required procedure for a particular piece of equipment, however, if you can show that your machine meets the following conditions:
- The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shutdown that could endanger employees;
- The machine or equipment has a single energy source that can be readily identified and isolated;
- The isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment;
- The machine or equipment is isolated from that energy source and locked out during servicing or maintenance;
- A single lockout device will achieve a locked-out condition;
- The lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance;
- The servicing or maintenance does not create hazards for other employees; and
- In utilizing this exception, you have had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
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