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Old 11-20-2018, 04:41 PM   #1
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I didn't want to derail another thread where this issue is being discussed, nor appear argumentative with someone I have very high respect for, so here's this shiny new thread.

A statement was made which I interpreted to effectively say that LOTO had to be within sight of the workman (or equipment).

I know disconnects have to be within sight of the equipment being worked on according to the NEC, but LOTO is not a NEC requirement; it's a OSHA requirement.

Before posting this I searched osha.gov and can't find any regulation requiring LOTO to be within sight of the workman.

If the disconnect also serves as the LOTO, then the statement made in the other thread would be always true, but we had specifically been discussing that there are NEC disco requirements and there are also OSHA LOTO requirements.

Seems to me, as far as OSHA LOTO requirements, you could LOTO an outdoor padmount transformer and work on the entire building with 100 men, none of whom can see the LOTO and are possibly 100's of feet from the LOTO.

What sayeth the esteemed ET community?
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Old 11-20-2018, 07:07 PM   #2
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I've never heard that it had to be with in sight.

How many times do you LOTO a breaker in a distribution panel to work on a panel elsewhere in a building?
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Old 11-20-2018, 07:30 PM   #3
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I've never heard that it had to be with in sight.

How many times do you LOTO a breaker in a distribution panel to work on a panel elsewhere in a building?
I was told by a inspector we hire to do a osha type walk through that it has more to do with who is expected to require the lock out.

A electrician can use any one of the multiple spots to do a lock out.

A operator should be able to lock out with out entering a restricted area. The device should also be convenient to the operator. (do not give them a excuse for why they did not lock it out)
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Old 11-20-2018, 08:07 PM   #4
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I am trying to wrap my head around how the various regulations apply, it's so nice and clear and concise the way these things are written

Looks to me like:

The NFPA's NEC, which applies mostly to electrical installations, requires motors and appliances (and probably other things I can't think of) have disconnects within sight OR lockable, the idea being if you're within sight, lockable is not necessary. Obviously the idea is if someone wandered up to the disconnect you'd see them and shout at them and get clear of the live parts.

The US Department of Labor's regulation 1910 is the OSHA standards.

OSHA subpart J, General Environmental Controls, contains standard 1910.147, "The control of hazardous energy (lockout / tagout)". I don't think there's anything in there about "within sight."

OSHA Subpart S, Electrical, does have some stuff in there about disconnecting means being within sight of things OR lockable.

So I'd say the NEC either-or requirements may be enough that you can operate with the OSHA Electrical requirements but may not be sufficient to comply with the OSHA LOTO requirements. They aren't the "lock out or be within sight" requirements, they are just "lock out" requirements.
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Old 11-20-2018, 08:07 PM   #5
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Originally Posted by MikeFL View Post
I didn't want to derail another thread where this issue is being discussed, nor appear argumentative with someone I have very high respect for, so here's this shiny new thread.

A statement was made which I interpreted to effectively say that LOTO had to be within sight of the workman (or equipment).

I know disconnects have to be within sight of the equipment being worked on according to the NEC, but LOTO is not a NEC requirement; it's a OSHA requirement.

Before posting this I searched osha.gov and can't find any regulation requiring LOTO to be within sight of the workman.

If the disconnect also serves as the LOTO, then the statement made in the other thread would be always true, but we had specifically been discussing that there are NEC disco requirements and there are also OSHA LOTO requirements.

Seems to me, as far as OSHA LOTO requirements, you could LOTO an outdoor padmount transformer and work on the entire building with 100 men, none of whom can see the LOTO and are possibly 100's of feet from the LOTO.

What sayeth the esteemed ET community?
I’m in the same boat with Grumpy, I have never heard of it having to be within sight of the LOTO either. Then again I have gone my entire career without having laid eyes on an OSHA inspector.

If i’m Working on a sub-panel all I care about is that sub-feed breaker has a padlock on it and i’m the only SD who has the key. I have even been known to duct tape the main panel door shut and write a very strong warning on it with a sharpie. Another safeguard is to tape the tip of your tic tracer to one of the MLO feeds.
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Old 11-20-2018, 08:30 PM   #6
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I’ll answer with a question:

How would you work on any circuit in a panel, if the LOTO had to be within site?

I think someone is applying an NEC requirement with OSHA’s LOTO requirements.
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Old 11-20-2018, 08:34 PM   #7
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Quote:
Originally Posted by jelhill View Post
Quote:
Originally Posted by MikeFL View Post
I didn't want to derail another thread where this issue is being discussed, nor appear argumentative with someone I have very high respect for, so here's this shiny new thread.

A statement was made which I interpreted to effectively say that LOTO had to be within sight of the workman (or equipment).

I know disconnects have to be within sight of the equipment being worked on according to the NEC, but LOTO is not a NEC requirement; it's a OSHA requirement.

Before posting this I searched osha.gov and can't find any regulation requiring LOTO to be within sight of the workman.

If the disconnect also serves as the LOTO, then the statement made in the other thread would be always true, but we had specifically been discussing that there are NEC disco requirements and there are also OSHA LOTO requirements.

Seems to me, as far as OSHA LOTO requirements, you could LOTO an outdoor padmount transformer and work on the entire building with 100 men, none of whom can see the LOTO and are possibly 100's of feet from the LOTO.

What sayeth the esteemed ET community?
I’m in the same boat with Grumpy, I have never heard of it having to be within sight of the LOTO either. Then again I have gone my entire career without having laid eyes on an OSHA inspector.

If i’m Working on a sub-panel all I care about is that sub-feed breaker has a padlock on it and i’m the only SD who has the key. I have even been known to duct tape the main panel door shut and write a very strong [IMG class=inlineimg]https://www.electriciantalk.com/images/smilies/wink.png[/IMG] warning on it with a sharpie. Another safeguard is to tape the tip of your tic tracer to one of the MLO feeds.
...some companies also require the LOTO circuits to be intentionally grounded as a redundant safety precaution.
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Old 11-20-2018, 08:56 PM   #8
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OSHA does not apply to houses and small commercial buildings. There is a minimum size the business itself has to be before OSHA rules apply (as far is inside of a building).

In the NEC, the location for the means of disconnect for a power source must be clearly labeled if it is not practical for a disconnect to be located there.

In LOTO, the means of disconnect refers to the mechanical isolation of all forms of energy (mechanical, electrical, gravity). The lockout points are not required to be clearly labeled as lockout points, however it is required that each piece of equipment be provided a procedure for safe servicing by a company if the equipment does not explicitly adhere to the requirements.

Essentially, they are two very different beasts often served by the same equipment.
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Old 11-20-2018, 09:06 PM   #9
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Originally Posted by gpop View Post
I was told by a inspector we hire to do a osha type walk through that it has more to do with who is expected to require the lock out.

A electrician can use any one of the multiple spots to do a lock out.

A operator should be able to lock out with out entering a restricted area. The device should also be convenient to the operator. (do not give them a excuse for why they did not lock it out)
If it's an operator looking to LOTO a machine then he should just do so at the disconnect that is required to be within sight of said machine.
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Old 11-20-2018, 09:42 PM   #10
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I thought that was written as: If the motor has a local disconnect it should be in site of the motor.

Some of our large motors do not have disconnect (500hp) and ive never seen a medium voltage 4160v 1500hp disconnect in the field (not even sure if they make such a thing).
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Old 11-20-2018, 09:56 PM   #11
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Originally Posted by 360max View Post
...some companies also require the LOTO circuits to be intentionally grounded as a redundant safety precaution.
We do that when we are working on the 25kv side. Poco normally will assist as they get bored watching us struggle with a 20' hot stick.
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Old 11-20-2018, 10:39 PM   #12
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Originally Posted by 360max View Post
...some companies also require the LOTO circuits to be intentionally grounded as a redundant safety precaution.


That’s actually in OSHA subchapter S, “when required”. So when is it required? If the line can contain hazardous voltage. It’s pretty much automatic on shielded medium voltage and overhead lines. But for example I was working on a motor about 50 feet from a drive with both drives in the same conduit. Once I isolated both ends and shorted the leads I had about 70-100 VAC induced from a 25 HP drive. Granted current is negligible but it was enough I could feel it.

OSHA has a lot of LOTO procedures not just one. Construction is in 1926, tags required but locks are optional. Subchapter J is the general maintenance one for knuckle draggers (mechanics). It requires locks but not tags. Subchapter O is for Neanderthals (operators). It doesn’t even require a disconnect, just a procedure if it is “equivalent “ so control lockouts or even just a warning tag is acceptable. Subchapter S is for utilization electricians. It is a mixture of a a simplified adaptation of 70E and NEC from the 1980s. 1910.269 is for generation, transmission, and distribution and has four different LOTO procedures including one that has no locks or really anything but an honor system (“clearance”). So there really is no one “lockout” under OSHA.

NEC requires a lockable disconnect within sight of a motor except when work is done by qualified personnel so basically not residential but almost everyone else that has maintenance staff. On pipelines and in mines and utility systems it’s not unusual for a lockout to be miles away. No requirement to not be in a hazardous area either. A lot of electrical rooms and subs are accessible only to qualified personnel (electricians). Operators have no business being in outdoor overhead style sub yards.


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Old 11-20-2018, 10:55 PM   #13
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Originally Posted by sparkiez View Post
OSHA does not apply to houses and small commercial buildings. There is a minimum size the business itself has to be before OSHA rules apply (as far is inside of a building).

In the NEC, the location for the means of disconnect for a power source must be clearly labeled if it is not practical for a disconnect to be located there.

In LOTO, the means of disconnect refers to the mechanical isolation of all forms of energy (mechanical, electrical, gravity). The lockout points are not required to be clearly labeled as lockout points, however it is required that each piece of equipment be provided a procedure for safe servicing by a company if the equipment does not explicitly adhere to the requirements.

Essentially, they are two very different beasts often served by the same equipment.


OSHA 1910.147 says the procedure can be making a copy of 1910.147 available so the written procedure thing is bull dung. It says so in the regulation!

NEC does not state the source must be labeled only readily identifiable. The motor might have no label at all and the combination starter might just be right beside it. Or no label and an MCC bucket says say “vent fan 2”, just as the schedules in load centers say “receps 1/2/3”..

Subchapter S for electrical lockouts has several differences from J:
1. Test for absence of voltage. Note that this step is energized work.
2. Apply grounds if necessary. Discharge energy sources if necessary. This is also energized work.
3. “Try” by qualified personnel among other steps. Operators don’t count in the context of Subchapter S.
4. Visually verify blades on visible break disconnects. Not required if not visible.

Most safety idiots (inspectors) think only 1920.147 exists and totally ignore 2910.269 and subchapter S.


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Old 11-20-2018, 11:22 PM   #14
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That’s actually in OSHA subchapter S, “when required”. So when is it required? If the line can contain hazardous voltage. It’s pretty much automatic on shielded medium voltage and overhead lines. But for example I was working on a motor about 50 feet from a drive with both drives in the same conduit. Once I isolated both ends and shorted the leads I had about 70-100 VAC induced from a 25 HP drive. Granted current is negligible but it was enough I could feel it.

OSHA has a lot of LOTO procedures not just one. Construction is in 1926, tags required but locks are optional. Subchapter J is the general maintenance one for knuckle draggers (mechanics). It requires locks but not tags. Subchapter O is for Neanderthals (operators). It doesn’t even require a disconnect, just a procedure if it is “equivalent “ so control lockouts or even just a warning tag is acceptable. Subchapter S is for utilization electricians. It is a mixture of a a simplified adaptation of 70E and NEC from the 1980s. 1910.269 is for generation, transmission, and distribution and has four different LOTO procedures including one that has no locks or really anything but an honor system (“clearance”). So there really is no one “lockout” under OSHA.

NEC requires a lockable disconnect within sight of a motor except when work is done by qualified personnel so basically not residential but almost everyone else that has maintenance staff. On pipelines and in mines and utility systems it’s not unusual for a lockout to be miles away. No requirement to not be in a hazardous area either. A lot of electrical rooms and subs are accessible only to qualified personnel (electricians). Operators have no business being in outdoor overhead style sub yards.


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I just finished a project where operators where digging a trench in an outdoor overhead style sub yard for new feeders, so they are inside that zone. The excavator machine was required to be bolted/clipped to the ground loop at all times.
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Old 11-20-2018, 11:25 PM   #15
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I thought that was written as: If the motor has a local disconnect it should be in site of the motor.



Some of our large motors do not have disconnect (500hp) and ive never seen a medium voltage 4160v 1500hp disconnect in the field (not even sure if they make such a thing).

They make them. Two types. You can have nonload break which are extensively used in utility subs are load break. A Federal Pacific Autojet for instance is one of the best built on the market. Elbow connectors come in both versions. Elastimold underground breakers can be used purely as switches. Lots of gang operated switches on overhead lines too such as the very nice Siemens Bridges switch. Joslyn Clark also makes an excellent popular load break switch private labeled by multiple manufacturers. I can build one if you need one. There is also the crappy ones made by Powercon and especially ABB that are both highly prone to arcing over from contamination due to short and poor placement of the insulators and support structure but maybe OK indoors only,

Sometimes local disconnects are convenience. Long kilns used to make steel grade lime are up to 600 feet long and the MCC is often over 1000 feet away on a different level from the kiln drive. Royal pain to work on it without a local disconnect so most have one,


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Old 11-20-2018, 11:58 PM   #16
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That's quite a thesaurus you have there Paul!
Thanks for all the great information.
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Old 11-21-2018, 12:15 AM   #17
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Originally Posted by paulengr View Post
That’s actually in OSHA subchapter S, “when required”. So when is it required? If the line can contain hazardous voltage. It’s pretty much automatic on shielded medium voltage and overhead lines. But for example I was working on a motor about 50 feet from a drive with both drives in the same conduit. Once I isolated both ends and shorted the leads I had about 70-100 VAC induced from a 25 HP drive. Granted current is negligible but it was enough I could feel it.

OSHA has a lot of LOTO procedures not just one. Construction is in 1926, tags required but locks are optional. Subchapter J is the general maintenance one for knuckle draggers (mechanics). It requires locks but not tags. Subchapter O is for Neanderthals (operators). It doesn’t even require a disconnect, just a procedure if it is “equivalent “ so control lockouts or even just a warning tag is acceptable. Subchapter S is for utilization electricians. It is a mixture of a a simplified adaptation of 70E and NEC from the 1980s. 1910.269 is for generation, transmission, and distribution and has four different LOTO procedures including one that has no locks or really anything but an honor system (“clearance”). So there really is no one “lockout” under OSHA.

NEC requires a lockable disconnect within sight of a motor except when work is done by qualified personnel so basically not residential but almost everyone else that has maintenance staff. On pipelines and in mines and utility systems it’s not unusual for a lockout to be miles away. No requirement to not be in a hazardous area either. A lot of electrical rooms and subs are accessible only to qualified personnel (electricians). Operators have no business being in outdoor overhead style sub yards.


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Sub-station knife switches are one example. No lock or tag is required. But, you need a hot stick to get to them. They're for "visible air gap" purposes.
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Old 11-21-2018, 12:22 AM   #18
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OSHA 1910.147 says the procedure can be making a copy of 1910.147 available so the written procedure thing is bull dung. It says so in the regulation!

NEC does not state the source must be labeled only readily identifiable. The motor might have no label at all and the combination starter might just be right beside it. Or no label and an MCC bucket says say “vent fan 2”, just as the schedules in load centers say “receps 1/2/3”..

Subchapter S for electrical lockouts has several differences from J:
1. Test for absence of voltage. Note that this step is energized work.
2. Apply grounds if necessary. Discharge energy sources if necessary. This is also energized work.
3. “Try” by qualified personnel among other steps. Operators don’t count in the context of Subchapter S.
4. Visually verify blades on visible break disconnects. Not required if not visible.

Most safety idiots (inspectors) think only 1920.147 exists and totally ignore 2910.269 and subchapter S.


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There are semi-odd ball pieces of equipment out there with more than one type of stored energy that standard LOTO rules do not apply to. In these instances, it is industry standard to have a documented safety procedure by designated company representatives that training is to be performed on. This is especially common when you have multiple sources of energy that are not readily apparent. One such example would be an impingement freezer I used to service. In order to get to the inside, and for cleaning, the machine had 6 4" or 5" hydraulic cylinders that would raise the machine. It was held in place by closing the valves, then pins were inserted to provide two forms of mechanical protection from gravity.

The point I'm making here is that you really have to look at it from two angles. The NEC gives requirements for a means of isolation from electricity, but LOTO encompasses ALL forms of stored energy. It isn't an apples to apples comparison, and should not be thought of in that manner. When I service or design any kind of electrical installation, I care about what that equipment is driving.

Thanks for the great information. I just didn't want that idea to get lost given the subject matter here.
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Old 11-21-2018, 12:38 AM   #19
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Right. Not only does OSHA not specify where, exactly, the LOTO location may/must be, but it's not technically even required by them. WHAT? If it does not exist, you simply aren't permitted to enter the danger zone of the equipment unless you jump through some engineering/paperwork hoops.

Common sense dictates that the operator have a local disconnecting means for all forms of energy, proximal to the hazard and sensibly marked, to encourage use.

One of my gripes, as an electrician, is the use of the terminology IES and ZES as it relates to LOTO. IES for intermediate energy state (only shutting down the hazard in a particular zone of the machine or one particular energy form), and ZES for Zero Energy State for making the whole machine or production line "dead" in terms of all forms of electrical, hydraulic, pneumatic, kinetic, and thermal energy. The ZES (most often) means that the interiors of the control panels will still have power coming into the main lugs, so it's a little misleading. Zero Energy State for everyone but the electrician. We have to go back to the buckets, bus plugs, or MDP for "real" ZES.
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Old 11-21-2018, 03:13 AM   #20
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Quote:
Originally Posted by paulengr View Post
That’s actually in OSHA subchapter S, “when required”. So when is it required? If the line can contain hazardous voltage. It’s pretty much automatic on shielded medium voltage and overhead lines. But for example I was working on a motor about 50 feet from a drive with both drives in the same conduit. Once I isolated both ends and shorted the leads I had about 70-100 VAC induced from a 25 HP drive. Granted current is negligible but it was enough I could feel it.

OSHA has a lot of LOTO procedures not just one. Construction is in 1926, tags required but locks are optional. Subchapter J is the general maintenance one for knuckle draggers (mechanics). It requires locks but not tags. Subchapter O is for Neanderthals (operators). It doesn’t even require a disconnect, just a procedure if it is “equivalent “ so control lockouts or even just a warning tag is acceptable. Subchapter S is for utilization electricians. It is a mixture of a a simplified adaptation of 70E and NEC from the 1980s. 1910.269 is for generation, transmission, and distribution and has four different LOTO procedures including one that has no locks or really anything but an honor system (“clearance”). So there really is no one “lockout” under OSHA.

NEC requires a lockable disconnect within sight of a motor except when work is done by qualified personnel so basically not residential but almost everyone else that has maintenance staff. On pipelines and in mines and utility systems it’s not unusual for a lockout to be miles away. No requirement to not be in a hazardous area either. A lot of electrical rooms and subs are accessible only to qualified personnel (electricians). Operators have no business being in outdoor overhead style sub yards.


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