Incorporating a Transfer Lock System into Your Lockout Program

Many companies face significant challenges in achieving an effective and compliant lockout/tagout program in place—especially as it pertains to lockout.

• By Bill Belongea
• Aug 01, 2020

OSHA has specific regulations for protecting employees from the unexpected energization or startup of machinery and equipment.

Commonly referred to as the “Lockout/Tagout standard,” guidelines for the control of hazardous energy are outlined in OSHA’s 1910.147 standard,1 which requires employers to “establish a program and utilize procedures for affixing appropriate lockout/tagout devices to prevent injury to employees.” Such a program is mandatory not only for OSHA compliance, but also for the overall protection and well-being of employees.

Understanding the OSHA lockout/tagout standard is critically important, especially as the standard consistently ranks on OSHA’s annual list of top ten violations. According to a report released by OSHA2 last year, the lockout/tagout standard was listed as the fourth most frequently cited violation in 2019, with 2,975 violations reported.

Violations not only result in fines that can impact a businesses’ profitability, but OSHA estimates3 that proper compliance with the lockout/tagout standard can prevent over 120 fatalities and more than 50,000 injuries every year.

While it’s critically important to have an effective and compliant lockout/tagout program in place, many companies face significant challenges in achieving this objective—especially as it pertains to lockout.

According to research based on field experience and first-hand conversations with thousands of customers across the U.S., less than 10 percent of employers have a functioning lockout program that meets all or most compliance requirements. Approximately 60 percent of U.S. companies have addressed the major elements of the lockout standard, but in a limited manner. Concerningly, roughly 30 percent of companies currently have no significant lockout program in place.

As organizations look to implement effective lockout programs, careful consideration must be given to the policies and procedures of lockout activities: an important element being procedures related to shift changes.

How Shift Changes Create Gaps in Lockout Safety & Compliance

One of the situations where companies and employees are most vulnerable to the hazards of improper or inadequate lockout is during a shift change.

Gaps in the effort to control hazardous energy can occur when the first shift of workers transfer lockout responsibility on to the second shift (and in some cases, the second on to the third).

In order to address this issue, OSHA standard 1910.147(f)(4)4 states the following:

“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 on-coming employees, to minimize exposure to hazards from the unexpected energization or start-up of the machine or equipment, or the release of stored energy.”

When it comes to shift changes, employers have four options for meeting the OSHA requirements:

1. Authorized employees can leave their personal lockout devices in place until the job is completed.

2. On-coming employees may apply their personal lockout devices before the off-going employees remove their personal lockout devices.

3. On-coming employees start the lockout process from scratch by applying and releasing lockout for the entire time of servicing. The equipment is first returned to operational status (with guards in place), and then employees administer lockout procedures on the equipment.

4. The company may incorporate and utilize continuity devices into their lockout/tagout program. These devices are often referred to as “transfer locks.”

While all four options are sufficient in meeting the OSHA requirements, the use of a transfer lock system has proven to be one of the most effective in ensuring the continuity of protection between shifts.

Incorporating a Transfer Lock System into Your Lockout Program

Workplaces that frequently require a transfer of lockout responsibility should consider the use of transfer locks. The intention of continuity devices is to ensure that all employees are protected during shift and personnel changes.

The basic procedures for using a transfer lock are:

1. An authorized employee places a transfer lock onto the hasp, lockbox or other energy isolation device.

2. Employees from the first shift place their own individual padlocks onto the same energy isolation device. If an energy isolating device cannot accept multiple locks, a hasp or group lockout box may be used.

3. Employees from the first shift remove their individual padlocks before going home at the end of the day.

4. Employees from the second shift add their individual padlocks to the energy isolation device before working on the hazardous energy source.

5. This process continues until the work is completed and employees from the last shift remove their individual padlocks.

6. The transfer lock should be the last to be removed, once the job is complete.

It’s important to note that employees from the on-coming shift must verify for themselves that the de-energization and isolation of hazardous energy has been completed. Employees should never depend upon the actions of the off-going shift, nor should they assume that the hazardous energy has already been isolated.

It is also recommended that the transfer locks are a different color or type than the employees’ individual padlocks. This enables workers to quickly and easily identify the presence of a continuity device.

Because there are many steps involved, it’s recommended that companies designate individuals on each shift to be responsible for managing the lockout. This “primary authorized employee” is usually the shift supervisor or department manager and is responsible for ensuring shift change continuity. He or she is in charge of administering the shift transfer devices, managing the key(s) and coordinating authorized employee changes for affected workforces. They must also be familiar with their company’s lockout/tagout policies and procedures.

If the use of continuity devices has been chosen as the method for meeting shift change compliance, the written program should include the following information:

• The identified colors of continuity device locks.
• The steps and procedures for implementing lockouts that involve continuity devices.
• The established methods for involving contractors in shift change lockouts.
• The necessary training that employees must complete on the shift change process.
• Whether or not shift change permits are required.

Shift change permits can be a useful way to manage and track who has possession of the keys for your job locks/shift transfer devices. Permit systems are generally recommended when lockout activities extend beyond two or more shifts.

Resources for Implementing a Transfer Lock System

The key to ensuring continuity of employee protection during shift changes is to have clearly defined and well-written procedures and provide sufficient employee training.

By putting effective shift change procedures in place, workers can gain peace of mind knowing that gaps in protection are covered, and they can proceed with the work in a safe manner.

Continuity devices and a transfer lock system also enable companies to provide optimal protection for their employees, empowering them to maintain compliance and become industry leaders for the effective control of hazardous energy.

For organizations looking for additional support with implementing a transfer lock system into their lockout program, consider contacting a third-party safety expert who can make assessments and help develop the written programs and procedures.

Companies like The Master Lock Company provide professional services5 that offer expert guidance and industry-leading experience in helping businesses achieve their safety goals and maintain compliance. Whether for shift change procedures or other lockout needs, safety managers are encouraged to consider resources that can assist their organization in achieving safer, more compliant work environments.

This article originally appeared in the August 2020 issue of Occupational Health & Safety.