Archive for October, 2013

Corporate Tagging Requirements Gradually Eclipsing OSHA Requirements

Thursday, October 31st, 2013

As we work with companies in their LOTO automation efforts, we are seeing many new increases in tagging requirements.  But, whereas OSHA was the reason that we originally started this endeavor, now we are seeing many more tag types coming into play, none of which are OSHA required.  As corporations become more concerned with employee safety, they are seeing opportunities to shore up weaknesses in the OSHA guidelines that result in an even safer workplace than OSHA envisioned while authoring CFR 1910.147.

One of our customers, a specialty chemical company, has implemented a new tagging requirement called “Verification Tags”.  These green verification tags are placed on every isolation point, on top of the OSHA-required LOTO tag.  It’s a safeguard to be sure energy isolation has been accomplished and reviewed carefully.  Their primary green color provides an easy visual reference (a “green light”, if you will) indicating that the equipment is safe to work on.  This doubles their tag volume, but also provides a very effective check against failure to isolate.  OSHA has nothing to do with this requirement.  This tagging guideline came down from the ivory tower, resulting from an incident that occurred years ago.  These tags contain different information from the LOTO tag, and if the LOTO automation system is not prepared to produce them, they represent an onerous opportunity to handwrite a large volume of tags.

Another one of our customers uses different colored LOTO tags depending upon lockout authority.  That is, if an operator locks out a device, a white LOTO tag is applied.  If an electrician locks out an isolation point, a red tag is applied.  If a contractor locks it out, a blue tag is applied.  Now, the tagging system must segregate isolation tags and lists by task, or, as in the event of a union shop, by trade.  If the LOTO automation system is not prepared to handle this, you find yourself in situations where operators (as the company men) are automated, but contractors are not.  This results in inconsistent levels of safety and efficiency in the facility.

A third new tag type we have seen implemented happened at a massive oil company.  It was noted that in situations where process equipment is opened, and inventory is exposed to the atmosphere, the danger level is elevated significantly.  The fix for this situation was to hang another tag on every spot where these break-ins to the process stream would occur.  The oil company called these tags OPE tags (for Opening Process Equipment) but we are seeing this behavior in many companies, sometimes called “break in” tags or “line break” tags.  This is probably the second most common tag type we see being used in the industry today.  This one presents a much more difficult tagging scenario.  Whereas our isolation points are fairly standard, these break-ins change frequently, if not every single time a piece of equipment is locked out.  This requirement for flexibility makes the break in tags the most difficult situation to automate.  It took us nearly a year to perfect the method.  In the end, it involved more data management than tagging technology in order to maintain user-friendliness while properly handling the requirement.  Ultimately, we nailed it so effectively that we made real fans within the massive oil company, which is a good thing.

OSHA got us all started with this tagging behavior, but now the industry is self-managing itself, which is pretty much always for the best.  Corporate conscience and behavior has moved beyond what was compelled by law, and now has coalesced into a much safer culture.  All the talk of going home every day is not just talk.  Every day, the industry gets safer, without the government pushing us any further.  For more information on a LOTO system that can handle evolving tagging requirements, visit