Equipment and Machinery Safety, Lockout-Tagout, Q&A

Q&A: Transferring Locks Between Shifts

Recently, one of our subscribers asked the following question:

I am looking for guidance on developing a lockout program where I can protect my employees from disassembled equipment while transferring the locks without having a physical hand off. Our second shift must leave equipment disassembled and locked out at midnight when they go home. We cannot reassemble the equipment until it has been inspected in the morning by the next work shift. There is no overnight shift to physically transfer keys to the locks.

This was our answer:

OSHA’s lockout/tagout rule includes procedures for the removal of lockout devices by persons other than those who applied them, group LOTO, and shift changes.

The OSHA LOTO rule at 29 CFR 1910.147(e)(3) allows for an exception to the transfer by physical hand off requirement:

“When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented and incorporated into the employer’s energy control program.”

For example, 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). See OSHA letter of interpretation that describes the master key exception.