What Can be Used as a Lockout Device?

Most modern machinery is designed with hazardous energy control in mind. The equipment is capable of receiving a lock and no other lockout devices are required. However, there are times when a lockout device other than a lock becomes necessary. There are many products on the market that are designed for the purpose of being a lockout device in specialized situations, but what if you don’t have them available? What are the requirements?

It is important to understand the distinction between energy isolation devices and lockout devices. Energy isolation devices physically prevent the transmission or release of energy. Examples of energy isolation devices include electrical disconnects, valves, and gravity pins. A lockout device is a “Positive means” that is used to hold the energy isolating device in a safe position. When energy isolation devices are designed to receive a lock, the only lockout device that is required would be the lock itself. If the equipment is not designed to receive a lock, then additional lockout devices become required.

Are homemade lockout devices ever permitted? If the device is designed to meet all of the standards as required by OSHA, yes it can be used. The lockout device needs to be able to be applied directly to an energy isolating device and capable of holding the energy isolating device in a safe position. It needs to be able to receive a lock. The lockout device also must also only ever be used as a lockout device. It cannot have multiple purposes. The lockout device must also be durable and substantial. Meaning that the environment in which it is used cannot damage the device and the device should not be able to be removed unless the lock is removed or a tool is required to cut it off. Authorized employees must be trained how to use the device and all lockout procedures need to be updated to include the use of the device.

A common scenario in which additional lockout devices are usually required is in an electric breaker panel. Many circuit breakers are not designed to receive locks. Is it permissible to trip the breaker and then lock the panel door to prevent others from accessing the breakers? The answer is found in the very definition of lockout. OSHA 1910.147(B) defines lockout as “The placement of a lockout device on an energy isolating device…”. Furthermore, the definition of a lockout device states that lockout devices must “…hold an energy isolating device in a safe position…”. In our example with the circuit breaker panel, locking the panel door fails to place the lockout device on the energy isolating device and also fails to hold the energy isolating device in a safe position. Simply locking the panel door is not permitted.

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