Using a master key for lockout/tagout

The lockout/tagout standard generally relies on each authorized employee applying a personal lock and retaining the key for it. According to 1910.147(e)(3), the authorized employee who applied a lock or tag should be the one who removes it. However, that paragraph contains an exception:

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.

Since a tagout device must be non-reusable, destruction of the device would be required to remove it. Many employers apply a similar standard to locks, using bolt cutters or other destructive methods if a lock needs to be removed by someone other than the authorized employee who applied it.

Procedures and training

Using a master key to remove a lock could be acceptable — after putting some procedures in place and providing training. The exception says the employer must provide equivalent safety to having the authorized employee remove his lock. These procedures must include:

• Verification that the authorized employee who applied the device is not at the facility;
• Making all reasonable efforts to contact that authorized employee to inform him/her that the device has been removed; and
• Ensuring that the authorized employee knows the lock was removed before he resumes work at that facility.

In a letter of interpretation from February 28, 2000, OSHA clarified that bolt cutters or other destructive methods are not the only options for someone other than the authorized employee to remove a lock. That letter stated, "Safety is ensured not through the use of a specific removal device, be it a master key or bolt-cutter; rather, it lies in effective procedures, careful training, and procedures designed to ensure accountability."

OSHA clarified that using a master key would be deemed equivalent only if lock removal was performed under the employer’s direction and in accordance with 1910.147(e)(3), as summarized above. Specific procedures and training must be developed and included in the energy control program, with procedures to ensure that only persons authorized and trained to use the master key can gain access to it.

That letter concluded by noting, "The success of any employer's energy control program, including lockout or tagout device removal actions, depends upon ensuring that its employees follow established, effective procedures, thereby respecting the sanctity of another employee's lockout or tagout device."