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MFD Safety Program

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Lock and Tag - Implementation Guidance

The intent of this page is to capture LOTO implementation questions and answers that come up in MFD. 

  1. Equipment physically separated from energy sources
  2. Procedure does not explicitly state that it will control all hazardous energy to the equipment you need to work on
     

Equipment physically separated from energy sources

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 be applied. 

Examples:

  • 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 required.
     
  • 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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Procedure does not explicitly state that it will control all hazardous energy to the equipment you need to work on

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.

  1. 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 magnet ABC."
     
  2.  It is very likely that the approver will forward your request to a qualified person.
    1. If the qualified person responds to the approver, who then forwards it to you, then you are good to go.
    2. If the qualified person responds directly to you, then forward the response to the approver and ask for their concurrence.
       
  3. 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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Last update: April 12, 2010