Recently, one of our subscribers asked the following question:
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Our general energy control LOTO procedure states that the key for a persona lock must be secured and controlled on a person when the LOTO lock is being used. Does the standard cover this?
This was our answer:
OSHA interprets the LOTO rule requirement for who controls the lockout devices (see 29 CFR 1910.147(e)(3)) in a letter of interpretation that says, “…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.
If the employer can demonstrate that [a] specific alternative procedure, which the employer follows prior to removing the device, provides a degree of safety that is equivalent to the removal of the device by the authorized employee who first affixed it, then the alternative method is acceptable. 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 the OSHA letter at http://1.usa.gov/24xwntw.
The OSHA rule or interpretations do not specify how or where the key holder (authorized employee) must keep the key–only that it must be under his/her control.