Lock and Tag - Implementation Guidance
The intent of this page is to capture LOTO
implementation questions and answers that come up in MFD.
Equipment physically separated from energy sources
Procedure does not explicitly state that it will control
all hazardous energy to the equipment you need to work
Equipment that is physically disconnected from all
hazardous energy sources, where the physical separations are
within site of the employee while he is working on the
equipment, does not need LOTO. If the physical
disconnection is remote from the equipment, then LOTO must
- Power supply ABC located in the gallery feeds magnet
XYZ located in the tunnel. The leads to the magnet
have been physically disconnected from the power supply
but are still connected to the magnet. Since the person
working on the magnet cannot see this physical
separation while he is performing work, LOTO must
be applied to the leads up at the power supply.
This protects from the potential of having someone hook
the wires to the power supply while the employee is
working on the magnet.
- Same example above, but in this case a ground strap
is applied to the magnet leads. LOTO is still
- Disconnect ABC feeds pump XYZ. The wires
leading from the pump are physically removed from
disconnect ABC, and the worker can see the ends of the
wires while working on the pump. LOTO is not required.
Regulatory Reference: NFPA 70E 120.2(A)
General. All electrical circuit conductors and circuit
parts shall be considered energized until the source(s) of
energy is (are) removed, at which time they shall be
considered deenergized. All electrical circuit conductors
and circuit parts shall not be considered to be in an
electrically safe condition until all sources of energy are
removed, the disconnecting means is under lockout/tagout,
the absence of voltage is verified by an approved voltage
testing device, and, where exposure to energized facilities
exists, are temporarily grounded. (See 120.1 for the
six-step procedure to establish an electrically safe work
condition.) Electrical conductors and circuit parts that
have been disconnected, but not under lockout/tagout,
tested, and grounded (where appropriate) shall not be
considered to be in an electrically safe work condition, and
safe work practices appropriate for the circuit voltage and
energy level shall be used. Lockout/tagout requirements
shall apply to fixed, permanently installed equipment, to
temporarily installed equipment, and to portable equipment.
Note: The term "disconnected" in the paragraph above means
that the disconnecting means (i.e. the breaker or disconnect
box, etc) is in the off position - it is not referring to
physical disconnection (wires removed).
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An equipment lockout procedure must explicitly state that
it will control all hazardous energy to the equipment you
will be working on. For example, if you will be
working on magnet XYZ, then the procedure must state that it
will control all hazardous energy to magnet XYZ. If it
does not, then you must obtain additional documentation.
- send an e-mail to the highest level person who
signed the procedure (lets call him the approver).
Example: "A request has been made for MFD to work on
magnet XYZ. We were provided procedure ABC as the
equipment lockout procedure for controlling hazardous
energy to this magnet. This procedure does not
explicitly state that it will control all hazardous
energy to magnet XYZ. Please confirm in writing that
procedure ABC will control all hazardous energy to
- It is very likely that the approver will
forward your request to a qualified person.
- If the qualified person responds to the
approver, who then forwards it to you, then you are
good to go.
- If the qualified person responds directly to
you, then forward the response to the approver and
ask for their concurrence.
- Attach the e-mail confirmation to the ELP, and then
move forward with working with the qualified person to
perform the LOTO.
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