Safety Services Company
November 18th 2014
“I have some questions concerning lockout tag out and shift change with group lockout…We use what is called a “cross-turn tag” at shift change, ONLY when there is no employee to take over as a primary lockout person. These tags have numbers and those numbers are documented on the lockout paper that also shows what equipment is locked, how many locks are currently being used and what kind of energy source is being isolated. The main concern we are having is, when a new employee comes to lockout the box (group lock out), that employee HAS to cut the cross-turn tag prior to placing the his/her lock and they assume responsibility of becoming the new “master”. Some of the employees believe that having to cut this tag should not be required and it should be used as a “anti-tamper” device so they know that the box and it’s content has not been compromised.”
“I do see a problem with the process that you’ve described, and it’s not in the changeover process when a new employee comes onto the job that you described, but it’s in setting up a group lockout procedure where there is no initial primary lockout person.
While a group lockout is a way to decrease the amount of locks (one for each individual on the job) on each hasp on the equipment, it is not a way to relinquish the responsibility to have one person responsible for the integrity of the lockout/tagout process. That’s spelled out in the OSHA regulations on group lockout, 1910.147(f)(3).
“Primary responsibility is vested in an authorized employee for a set number of employees working under the protection of a group lockout or tagout device (such as an operations lock).” – 1910.147(f)(3)(ii)(A)
The OSHA regulation requires specific procedures to be developed to ensure continuous protection between off-going and oncoming employees – 1910.147(f)(4) – , but does not spell out what they need to be. So a properly developed and executed “cross-turn tag” may be effectively used to indicate the change from one primary lockout person to another. Still OSHA shows a preference toward using a lockout device first and tagout only when a lock is infeasible.
Instead of creating a procedure that starts with nobody in charge of the group lockout, I would create a permit system where there is always a primary person responsible for everyone’s safety in charge of the lockbox that has the key to the lockout devices and the hasp to the lockbox has a lock for every individual employee on the project. The permit will name the primary person and each employee on the project. Then when a new employee comes onto the project, they can check with the primary person who can take note of the new employee on the permit and the new person can add their lock to the hasp on the lockbox.”
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