# LOTO Q: Spare Keys?



## MDShunk

Does the existence of spare keys do anything to invalidate a LOTO program? Does the existence of spare keys do anything to cause a contractor to run afoul of OSHA rules? 

Would it make a difference if the spare keys were locked up in a box, under control of the owner or supervisor only?


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## electricmanscott

I'm pretty sure spare keys are not allowed and would be a violation. Took OSHA class last week and that's what was said.


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## Widestance_Politics

I vote yes that it is a violation according to OSHA.....I have no solid evidence other than the fact that I have never noticed an approved LOTO padlock that had more than one key.....also the current job I am on has around 200 people working on it with an extensive LOTO program....if you leave a lock on without approval and it needs to be removed....you will be expected to return to site no matter the time or circumstance.....if the lock needs to be cut you will be removed from the site.

I hear that there is a pile of paperwork involved also when cutting a LOTO lock.....I can't actually see a reason or situation where more then one key would be needed myself....


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## Jlarson

I think spare keys are technically a violation too. All of my _personal_ LOTO locks only have one key, officially :shifty:



Widestance_Politics said:


> I vote yes that it is a violation according to OSHA.....I have no solid evidence other than the fact that I have never noticed an approved LOTO padlock that had more than one key.....also the current job I am on has around 200 people working on it with an extensive LOTO program....if you leave a lock on without approval and it needs to be removed....you will be expected to return to site no matter the time or circumstance.....if the lock needs to be cut you will be removed from the site.
> I hear that there is a pile of paperwork involved also when cutting a LOTO lock.....I can't actually see a reason or situation where more then one key would be needed myself....


Yeah SRP is pretty tough on contractors when it comes to LOTO.


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## Bob Badger

I can't find any OSHA rule that prohibits spare keys.

There is a procedure to follow if you have to remove someones LOTO.


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## MDShunk

Bob Badger said:


> I can't find any OSHA rule that prohibits spare keys.


I can't either, which is why I think this "one key per lock" might be a good idea, but not necessarily in the OSHA rules. I think it's an old wive's tale, but I'm still not 100% sure.


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## Bob Badger

MDShunk said:


> I can't either, which is why I think this "one key per lock" might be a good idea, but not necessarily in the OSHA rules. I think it's an old wive's tale, but I'm still not 100% sure.



I think these should make you sure.


2000 - 02/28/2000 - Removal of lockout devices by persons other than those who applied them.

1  2000 - 07/10/2000 - Evaluation of proposed modifications to the Bureau of Prisons' Lockout/Tagout (LOTO) procedures.


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## drsparky

No one has a key to my locks but me. What would be the point of having an extra key? Are you looking to save the cost of a lock? The peace of mind that of one key in more valuable than a stupid padlock.


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## HackWork

The whole thing is a moot point since 95% of LO-TO is done with Masterlocks in which the whole world has spare keys.

You can buy keychains with every M1 key ever made for cheap.


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## CJE

FWIW, My manager has my spare key locked in his desk. He is the only one who can remove my lock, besides me. He has to actually speak to me (phone is acceptable) before he uses that key. Since I have not yet forgotten to remove my lock or something similar, it has never come up for us in practice. So far, if something is locked out at the end of the day, there is a reason why it can't be operated. It's a lot easier for us because we wrote the procedure ourselves. :thumbup:


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## Bob Badger

From OSHA


> *Lockout device.* A device that utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in the safe position and prevent the energizing of a machine or equipment. Included are blank flanges and bolted slip blinds.


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## MDShunk

drsparky said:


> No one has a key to my locks but me. What would be the point of having an extra key? Are you looking to save the cost of a lock? The peace of mind that of one key in more valuable than a stupid padlock.


You pay your bills with "peace of mind" or actual money?

You might have the luxury of being the same guy that returns to a job the next day to continue work on a piece of equipment that needed to remain locked off overnight, but that's not always the case for everyone.


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## HackWork

_A device that utilizes a positive means such as a lock, either key or combination type,_

What if you use a combination lock, you would have to kill everyone else who knows the combo :whistling2::whistling2: :thumbup:


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## drsparky

MDShunk said:


> You pay your bills with "peace of mind" or actual money?
> 
> You might have the luxury of being the same guy that returns to a job the next day to continue work on a piece of equipment that needed to remain locked off overnight, but that's not always the case for everyone.


The idea that anyone can remove my lock without any physical proof just so they can save a buck does not give me a warm fuzzy. Removing a lock is a last resort, the paperwork to do it would cost more than a silly lock. I have worked for many very good supervisors who I valued and trusted but also a few idiots that gained their positions do to the peter principle.
Cutting a lock should be a very rare occurrence, it should never become as easy as getting a spare key, someones life may depend on it.


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## MDShunk

drsparky said:


> The idea that anyone can remove my lock without any physical proof just so they can save a buck does not give me a warm fuzzy. Removing a lock is a last resort, the paperwork to do it would cost more than a silly lock. I have worked for many very good supervisors who I valued and trusted but also a few idiots that gained their positions do to the peter principle.
> Cutting a lock should be a very rare occurrence, it should never become as easy as getting a spare key, someones life may depend on it.


Since it appears to be legal, I will disregard any lack of warm fuzzies. Decisions made according to the warm fuzzy index are seldom sound business decisions.


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## drsparky

MDShunk said:


> Since it appears to be legal, I will disregard any lack of warm fuzzies. Decisions made according to the warm fuzzy index are seldom sound business decisions.


Well, how much are you saving by having an extra key and controlling them vs the cost of a lock? You could go years (hopefully) without having to remove a lock. If you are determined to use a spare key use it wisely.
Chuck


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## Bob Badger

1910.147(e)(3)

Lockout or tagout devices removal. Each lockout or tagout device shall be removed from each energy isolating device by the employee who applied the device. Exception to paragraph (e)(3): When the authorized employee who applied the lockout or tagout device is not available to remove it, that device may be removed under the direction of the employer, provided that specific procedures and training for such removal have been developed, documented and incorporated into the employer's energy control program. The employer shall demonstrate that the specific procedure provides equivalent safety to the removal of the device by the authorized employee who applied it. The specific procedure shall include at least the following elements:
1910.147(e)(3)(i)

Verification by the employer that the authorized employee who applied the device is not at the facility:
1910.147(e)(3)(ii)

Making all reasonable efforts to contact the authorized employee to inform him/her that his/her lockout or tagout device has been removed; and
1910.147(e)(3)(iii)

Ensuring that the authorized employee has this knowledge before he/she resumes work at that facility.


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## rlc3854

Bob Badger said:


> 1910.147(e)(3)
> 
> 
> Just my two cents, Bob hit the mark with the OSHA quotations. Everything is done by procedures that are set in place by the contractor and agreed by the client or set in place by the client meeting OSHA minium standards. I have never seen any direct specific detail from OSHA of how do anything. However if something goes wrong they will cite the regulations that you failed to meet, then make you do a corrective action plan to correct the problems and how you are not going to fail again.


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## brother

MDShunk said:


> You pay your bills with "peace of mind" or actual money?
> 
> You might have the luxury of being the same guy that *returns to a job* the next day to continue work on a piece of equipment that needed to *remain locked off overnight*, but that's not always the case for everyone.


MD, 
You appear to have a misunderstanding of the proper loto intent. I put 2 points I wanted to address in bold. *'Personal'* locks (ones that *you should only* have the key to) are for your *'personal'* protection when you are exposed to any potential hazard wheather it be electrical, pressure, steam, heat etc... If you are leaving the job, or its at the end of your shift, then your *Personal* lock' is suppose to be removed by you before you leave. 

If the equipment or circuit needs to be kept lock out *over night or any extended period of time* and you are *NOT* working on it, then you should be putting an *EQUIPMENT* lock on it and not leaving your personal lock. Equipment locks can have EXTRA keys and other authorized qualified people can have a copy of that key so if they need to unlock it, or continue working on it (pick up where you left off) for any reason.

I seen this issue come up where I worked at, and I had to show them (coworkers) in our policy and state/osha laws that cover the issue of 'locks' left over night, or the person left town or whatever. 

The confusion was that people did not know the difference in a PERSONAL lock and an EQUIPMENT lock. Just remember that *PERSONAL* locks are for *your personal protection* when *YOU* are working on the circuit etc.. , and EQUIPMENT locks are just for keeping the equipment or circuit down for extended period of time when YOU are not working on it.  And yes there is suppose to be a 'written' policy just in case someone accidently left their personal lock on when they left the job site.

Here, the supervisor is the ONLY one allowed to 'cut' remove someone elses personal lock, and even BEFORE he does that he has to document what he did to find and contact the person who's lock is on there. 

Hope this helps.


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## Bob Badger

Brother, Nothing Mark has suggested violates the OSHA standards.


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## oldtimer

brother said:


> MD,
> You appear to have a misunderstanding of the proper loto intent. I put 2 points I wanted to address in bold. *'Personal'* locks (ones that *you should only* have the key to) are for your *'personal'* protection when you are exposed to any potential hazard wheather it be electrical, pressure, steam, heat etc... If you are leaving the job, or its at the end of your shift, then your *Personal* lock' is suppose to be removed by you before you leave.
> 
> If the equipment or circuit needs to be kept lock out *over night or any extended period of time* and you are *NOT* working on it, then you should be putting an *EQUIPMENT* lock on it and not leaving your personal lock. Equipment locks can have EXTRA keys and other authorized qualified people can have a copy of that key so if they need to unlock it, or continue working on it (pick up where you left off) for any reason.
> 
> I seen this issue come up where I worked at, and I had to show them (coworkers) in our policy and state/osha laws that cover the issue of 'locks' left over night, or the person left town or whatever.
> 
> The confusion was that people did not know the difference in a PERSONAL lock and an EQUIPMENT lock. Just remember that *PERSONAL* locks are for *your personal protection* when *YOU* are working on the circuit etc.. , and EQUIPMENT locks are just for keeping the equipment or circuit down for extended period of time when YOU are not working on it.  And yes there is suppose to be a 'written' policy just in case someone accidently left their personal lock on when they left the job site.
> 
> Here, the supervisor is the ONLY one allowed to 'cut' remove someone elses personal lock, and even BEFORE he does that he has to document what he did to find and contact the person who's lock is on there.
> 
> Hope this helps.


 This is basically the same system we had at the mines. Good System. :thumbsup::thumbsup:


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## rlc3854

brother said:


> Can you cut and paste those specifics from any OSHA sources or from your State/County/City regulations? Or are speaking specifically of the employers policies based on some regulatory agency?


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## leland

OSHA standards.

That sums it up. A procedure based on a minimum standard.

Power plants that I work in, some just use tye wraps & tags. For some applications.
But all are labeled and names are affixed.

Professionalism and respect of the hazards are common place there.

Obviously,in an unfamiliar setting I would want a 'LOCK'.


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## brother

rlc3854 said:


> brother said:
> 
> 
> 
> Can you cut and paste those specifics from any OSHA sources or from your State/County/City regulations? Or are speaking specifically of the employers policies based on some regulatory agency?
> 
> 
> 
> Heres a good link from mike holt site comments by Sparketta
> http://forums.mikeholt.com/showthread.php?t=94803&page=3&highlight=lock
> 
> The specifics of the program we follow is a 'combination' of state codes and company policy.
> 
> 
> Here's an excerpt from the 'state law/codes'.
> 
> 
> The employer may have the lockout or tagout device removed by someone other than the authorized employee who applied it if *all* of the following conditions are met:
> 
> 
> – The energy control program has documented, specific procedures and training for this situation
> – You can show that the specific procedures used are as safe as having the device removed by the authorized employee who applied it<LI sizset="141" sizcache="0">– The specific procedures include *at least* the following:
> 
> Verifying the authorized employee who applied the device isn't at the facility
> Making all reasonable efforts to contact and inform the authorized employee that the lockout or tagout device is being removed
> Making sure the authorized employee is informed, before resuming work at the facility, that the lockout or tagout device has been remove
> 
> 
> 
> You must
> 
> Do the following before energizing or starting the machine or equipment:
> – Notify affected employees that the lockout or tagout devices have been removed.
> 
> Protect employees during shift or personnel changes
> 
> You must
> 
> Use specific procedures for shift or personnel changes to:
> – Make sure there’s continuous lockout or tagout protection during the change
> *and*
> – Provide for the orderly transfer of lockout or tagout device protection between employees.
Click to expand...


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## MDShunk

brother said:


> MD,
> You appear to have a misunderstanding of the proper loto intent. I put 2 points I wanted to address in bold. *'Personal'* locks (ones that *you should only* have the key to) are for your *'personal'* protection when you are exposed to any potential hazard wheather it be electrical, pressure, steam, heat etc... If you are leaving the job, or its at the end of your shift, then your *Personal* lock' is suppose to be removed by you before you leave.
> 
> If the equipment or circuit needs to be kept lock out *over night or any extended period of time* and you are *NOT* working on it, then you should be putting an *EQUIPMENT* lock on it and not leaving your personal lock. Equipment locks can have EXTRA keys and other authorized qualified people can have a copy of that key so if they need to unlock it, or continue working on it (pick up where you left off) for any reason.
> 
> I seen this issue come up where I worked at, and I had to show them (coworkers) in our policy and state/osha laws that cover the issue of 'locks' left over night, or the person left town or whatever.
> 
> The confusion was that people did not know the difference in a PERSONAL lock and an EQUIPMENT lock. Just remember that *PERSONAL* locks are for *your personal protection* when *YOU* are working on the circuit etc.. , and EQUIPMENT locks are just for keeping the equipment or circuit down for extended period of time when YOU are not working on it.  And yes there is suppose to be a 'written' policy just in case someone accidently left their personal lock on when they left the job site.
> 
> Here, the supervisor is the ONLY one allowed to 'cut' remove someone elses personal lock, and even BEFORE he does that he has to document what he did to find and contact the person who's lock is on there.
> 
> Hope this helps.


Personal locks and equipment locks are two terms you invented, not OSHA. It really makes no difference what you call the lock. To OSHA, apparently if someone installed it, it's a lockout device that only they can remove or their employer if they are not available.


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## brother

Heres an osha link.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804


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## brother

MDShunk said:


> Personal locks and equipment locks are two terms you invented, not OSHA. It really makes no difference what you call the lock. To OSHA, apparently if someone installed it, it's a lockout device that only they can remove or their employer if they are not available.


I didnt 'invent' the terms. Maybe they are not 'specifically' stated in Osha, (I am influenced by our policy terms and state code requirments) . You should check out the 'excerpts' I posted from our state codes. Maybe you could implement them. Its not good leaving your personal lock overnite or when you are not there working on it.


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## MDShunk

brother said:


> Its not good leaving your personal lock overnite or when you are not there working on it.


Yeah, I know, which is why I'm going to now have spare keys to every lock. Thanks.


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## Widestance_Politics

MDShunk said:


> Yeah, I know, which is why I'm going to now have spare keys to every lock. Thanks.


Why waste that income on locks or keys at all? Just stick a piece of 33 over the breaker handle, leave a poorly written note, or just assume that nothing will go wrong.........


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## brother

MDShunk said:


> Yeah, I know, which is why I'm going to now have spare keys to every lock. Thanks.


 *SIGH* well I tried  You gonna continue with the extra key thing huh??


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## MDShunk

Widestance_Politics said:


> Why waste that income on locks or keys at all? Just stick a piece of 33 over the breaker handle, leave a poorly written note, or just assume that nothing will go wrong.........


Mainly because that's illegal. Surely you can get from this thread that I'm looking to comply with the law, right?


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## MDShunk

brother said:


> *SIGH* well I tried  You gonna continue with the extra key thing huh??


Yes, which is why I asked the question related to their legality. Seems they are. If I was interested in being safer than the law prescribes, then I wouldn't have even opened this thread. I'm looking, mostly, to comply with the letter of the law.


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## 480sparky

Me? I just _PhotoShop_ an image of the breaker in the "OFF' position with a LOTO and padlock on it. :laughing:


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## Bob Badger

brother said:


> Heres an osha link.
> 
> http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9804


So in other words you really did not read the thread because the thread is full of OSHA info and links already.


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## Bob Badger

brother said:


> *SIGH* well I tried  You gonna continue with the extra key thing huh??



OSHA allows a master key so how would a spare key be different?


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## eric7379

brother said:


> MD,
> You appear to have a misunderstanding of the proper loto intent. I put 2 points I wanted to address in bold. *'Personal'* locks (ones that *you should only* have the key to) are for your *'personal'* protection when you are exposed to any potential hazard wheather it be electrical, pressure, steam, heat etc... If you are leaving the job, or its at the end of your shift, then your *Personal* lock' is suppose to be removed by you before you leave.
> 
> If the equipment or circuit needs to be kept lock out *over night or any extended period of time* and you are *NOT* working on it, then you should be putting an *EQUIPMENT* lock on it and not leaving your personal lock. Equipment locks can have EXTRA keys and other authorized qualified people can have a copy of that key so if they need to unlock it, or continue working on it (pick up where you left off) for any reason.
> 
> I seen this issue come up where I worked at, and I had to show them (coworkers) in our policy and state/osha laws that cover the issue of 'locks' left over night, or the person left town or whatever.
> 
> The confusion was that people did not know the difference in a PERSONAL lock and an EQUIPMENT lock. Just remember that *PERSONAL* locks are for *your personal protection* when *YOU* are working on the circuit etc.. , and EQUIPMENT locks are just for keeping the equipment or circuit down for extended period of time when YOU are not working on it.  And yes there is suppose to be a 'written' policy just in case someone accidently left their personal lock on when they left the job site.
> 
> Here, the supervisor is the ONLY one allowed to 'cut' remove someone elses personal lock, and even BEFORE he does that he has to document what he did to find and contact the person who's lock is on there.
> 
> Hope this helps.


Where does it state this in the OSHA link that you posted? Unless I looked through it too quickly, I did not see anything in there that even remotely suggested this.


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## Bob Badger

eric7379 said:


> Where does it state this in the OSHA link that you posted? Unless I looked through it too quickly, I did not see anything in there that even remotely suggested this.


I would guess it was a bastardization of this.




> 1910.147(f)(4)
> 
> Shift or personnel changes. Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout device protection between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.


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## eric7379

MDShunk said:


> Personal locks and equipment locks are two terms you invented, not OSHA. It really makes no difference what you call the lock. To OSHA, apparently if someone installed it, it's a lockout device that only they can remove or their employer if they are not available.


Cut & pasted (sorry 480, I didn't Photoshop it!) from the OSHA link that Brother provided:

*Group lockout or tagout.*
*1910.147(f)(3)(i)* 
When servicing and/or maintenance is performed by a crew, craft, department or other group, they shall utilize a procedure which affords the employees a level of protection equivalent to that provided by the implementation of a *personal* lockout or tagout device.

*1910.147(f)(3)(ii)(D)* 
Each authorized employee shall affix a *personal *lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work, and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained.

*1910.147(f)(3)(ii)(A)* 
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);


This section does apply to group LOTO. Maybe this is where the terms "personal" and "equipment" came from? (Equipment=Operations?)


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## eric7379

I am sure that I will get bashed over the head for this, but oh well.

At the plant that I work at, we have 6 electricians. Each of us have our own "personal" set of LOTO locks, to which there is only one key for each lock. I have 8 LOTO locks, so I have 8 separate keys. 

All of the electrical panels within the building are locked by what we commonly term "electricians" locks. We have 3 different types of locks, to which only the electricians have the keys. Sometimes, when a machine needs to be worked on for more than one shift, we take our "personal" locks off and instead put on the "electricians" lock (AKA "operations" or "equipment" lock). The reason for this is because the next shift electricians have a tendency of flying through the door right when their shift is supposed to start and management only pays me in 1/2 hour increments. 
Why should I have to stay past the end of my shift for 5 minutes to do a "proper" LOTO lock exchange with the next shift and not get paid for it? (This is my personal gripe with the company, I know I am not following the OSHA guidelines.)

Is the machine locked out, per se? No, just because it is locked and under the control of 6 individuals, it does not neccessarily meet the quidelines of OSHA LOTO guidelines. 

Is it safer to have the machine locked off with a lock that only us 6 electricians have the key to? Yes. Does it mean that I am in the right? No.

Does it justify my argument of not following LOTO procedures? No, it does not. I am still not following the guidelines. I know this, and if I get reprimanded for it, I will suffer the consequences for it. This is my personal choice.


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## frenchelectrican

I have work in couple industrail plants before and this part was pretty much simauir many years ago with multi shift operation.



> 1910.147(f)(4)
> 
> Shift or personnel changes. Specific procedures shall be utilized during shift or personnel changes to ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout device protection between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.


Sorry Bob to steal your qoute but this what I pretty much memorized that rules over 20 years ago however that rules is still apply simair way in France so what the OSHA written other countries do intend to follow it one way or other.

Merci.
Marc


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## oldtimer

I am not sure where to post this: 

The word ELECTROCUTE, as in Electrocution. The dictionary defines Electrocution as DEATH by electricity. Therefore when you receive an electric shock, you have not been Electrocuted, or else you would be dead.
I have been as guilty as anyone, for using this word out of context. 

(It's in the book) PLEEEEASE FORGIVE ME!!


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## 480sparky

oldtimer said:


> I am not sure where to post this:
> 
> The word ELECTROCUTE, as in Electrocution. The dictionary defines Electrocution as DEATH by electricity. Therefore when you receive an electric shock, you have not been Electrocuted, or else you would be dead.
> I have been as guilty as anyone, for using this word out of context.
> 
> (It's in the book) PLEEEEASE FORGIVE ME!!


I have people ask me all the time how many times I've been electrocuted. I dead-pan, "Never." Most think I'm lying.


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## Bob Badger

480sparky said:


> I have people ask me all the time how many times I've been electrocuted. I dead-pan, "Never." Most think I'm lying.


Well if you actually got something done they would not think you were dead.


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## 480sparky

Bob Badger said:


> Well if you actually got something done they would not think you were dead.


I get more done in my dreams than you get done all day.


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## Bob Badger

480sparky said:


> I get more done in my dreams than you get done all day.


Exactly, in your dreams but not for real. :laughing:


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## HARRY304E

oldtimer said:


> I am not sure where to post this:
> 
> The word ELECTROCUTE, as in Electrocution. The dictionary defines Electrocution as DEATH by electricity. Therefore when you receive an electric shock, you have not been Electrocuted, or else you would be dead.
> I have been as guilty as anyone, for using this word out of context.
> 
> (It's in the book) PLEEEEASE FORGIVE ME!!


 
Thats great news. Thanks for clearing this up for us!:laughing:


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## Jlarson

oldtimer said:


> I am not sure where to post this:
> 
> The word ELECTROCUTE, as in Electrocution. The dictionary defines Electrocution as DEATH by electricity. Therefore when you receive an electric shock, you have not been Electrocuted, or else you would be dead.
> I have been as guilty as anyone, for using this word out of context.
> 
> (It's in the book) PLEEEEASE FORGIVE ME!!


I'm supposed to be dead according to the dictionary, awesome :clap: :laughing:


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## 480sparky

Bob Badger said:


> Exactly, in your dreams but not for real. :laughing:



In my dreams, neither are you. :whistling2:


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## MDShunk

oldtimer said:


> I am not sure where to post this:
> 
> The word ELECTROCUTE, as in Electrocution. The dictionary defines Electrocution as DEATH by electricity. Therefore when you receive an electric shock, you have not been Electrocuted, or else you would be dead.
> I have been as guilty as anyone, for using this word out of context.
> 
> (It's in the book) PLEEEEASE FORGIVE ME!!


My wife is a nurse, and some of her nursing texts refer to "electrocution injury".

There's even an ICD-9 code (code every disease and injury is given for insurance purposes) for "nonfatal electrocution". 

In purely medical terms, electrocution does not mean dead. In fact, when death warrants are signed for people getting put in the electric chair, the order will read, "electrocuted UNTIL dead".


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