Scenario: You are a regional safety manager for a large manufacturing company with plants located throughout the United States. One of your responsibilities is to conduct routine site OSHA/safety inspections at various facilities. During one of your audits, you observe that maintenance personnel are using their lockout lock to lock their tool boxes and lockers. At first you don’t think much of it, but then you begin to wonder if this is a good idea and if it could possibly be a violation of the OSHA standard 1910.147 Control of Hazardous Energy using a lockout lock for something other than Lockout.
Under 29 CFR 1910.147(c)(5)(ii), lockout/tagout devices has the statement “. . . shall not be used for other purposes; . . .” Also, when you review the scope of the standard 29 CFR 1910.147(a)(1)(i), it states: “This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees.”
Question: Is it a violation of 29 CFR 1910.147(c)(5)(ii) when locks, intended for the control of hazardous energy, are used for purposes other than the servicing or maintenance of machines and equipment?
Answer: Yes. Applying lockout/tagout devices to secure tool boxes or other activities not related to service or maintenance of equipment would not preserve the integrity of the Lockout/Tagout program. The preamble to the final rule, at 54 Federal Register 36671 (Sept. 1, 1989) states: “. . . the sight of a distinctive lock or tag will provide a constant message of the use that the device is being put to and the restrictions which this device is intended to convey. If lockout or tagout devices are used for other purposes they can lose their significance in the workplace. For the energy control procedure to be effective, these devices must have a single meaning to employees: ‘Do not energize the equipment when such a device is affixed to it.'”
Is a combination lock acceptable for Lockout?