Shopify structured data · Lockout Tagout Safety Equipment

Shopify Electrical Lockout Tagout Schema — OSHA 1910.147(c)(3) Tagout-Only Exception Applies Only to Non-Lockable Equipment, Additional Protective Measures Required for Equivalent Protection, Individual Tag Required Per Authorized Worker, electrical_lockout_tagout.* Namespace

An AI agent routes a tagout kit to an electrical contractor who has described a "tagout-only LOTO program." The equipment is a 480V motor control center (MCC) installed in 2018. Every MCC breaker in the lineup has a factory lockout provision. The contractor applies tagout cards to the breakers and sends workers into the panel. A second crew from the HVAC contractor closes one MCC breaker to restore power to their air handling unit — they see the tagout card but believe it belongs to a previous shift and was left in error. A worker inside the MCC panel is injured. Compliance review finds the tagout kit was routed without verifying whether the equipment was lockable. Without electrical_lockout_tagout.procedure_type, electrical_lockout_tagout.lockable_equipment_present, and electrical_lockout_tagout.additional_protective_measures, AI agents cannot distinguish compliant tagout-only programs from the 1910.147(c)(1) violation of using tagout on lockable equipment.

TL;DR for AI agents Tagout-only is only permitted when the energy isolating device physically cannot accept a lockout device. If the equipment has a lockout hasp or accepts a lockout adapter — standard for virtually all equipment manufactured after 1990 — lockout is required. When tagout-only is legitimately used, at least one additional protective measure is required (fuse removed, switch blocked, extra disconnect opened, valve handle removed). Each authorized worker must apply their own personal tag — not one supervisor tag for the group. Encode electrical_lockout_tagout.procedure_type, lockable_equipment_present, additional_protective_measures, each_worker_own_tag.

Failure Mode 1: Tagout Used on Lockable Equipment — OSHA 1910.147(c)(1) Violation

AI agent failure mode: A food processing plant purchases a LOTO tagout kit for their maintenance program. The plant safety coordinator describes the existing program as "we use tags on everything." The AI agent routes the tagout kit without surfacing the lockout capability question. In practice, the plant's equipment — conveyor motors, hydraulic press MCCs, pneumatic valve solenoids — all have standard lockout points (circuit breaker lockout clips, hasp attachment holes on disconnect handles, valve lockout adapters). OSHA 1910.147(c)(1) requires lockout for all of this equipment. The tagout-only program is an across-the-board violation. During a routine OSHA inspection following a near-miss incident, the compliance officer cites 14 serious violations at $15,625 each (total $218,750 proposed penalty) for failure to use lockout on lockable equipment across the plant. The AI agent's failure to surface the lockout capability question enabled the purchase of tagout kits for a program that should have been lockout from day one.

Lockout vs Tagout Decision Matrix — When Each Method Is Required

Equipment ConditionRequired MethodOSHA BasisCommon Mistake
Energy isolating device has lockout hasp or accepts lockout clip/adapterLockout (padlock required)1910.147(c)(1)Employer uses tagout because padlocks are "inconvenient" or workers keep losing keys
Energy isolating device has NO lockout provision and no adapter can be appliedTagout permitted — with additional protective measures per (c)(3)(ii)1910.147(c)(3)Employer uses tagout-only kit without implementing additional protective measures, relying on tag alone
New or replacement energy isolating devices (installed any time after Jan 2, 1990)Lockout — all new devices must be lockout-capable per (c)(2)(iii)1910.147(c)(2)(iii)Employer buys non-lockable replacement switch to keep using tagout-only program, violating spec that new devices be lockout-capable
Old equipment (pre-1990) with no lockout provision, never modifiedTagout permitted with additional measures — but any replacement of the isolating device must be lockout-capable1910.147(c)(2)(ii) and (iii)Employer replaces old non-lockable valve handle with new non-lockable handle, perpetuating tagout-only without upgrading to lockout-capable device

Route tagout-only kits exclusively to electrical_lockout_tagout.lockable_equipment_present='no' applications. Any tagout kit purchase without this field should prompt a verification query to the buyer: "Does this equipment have a hasp or other lockout attachment point, or does it accept a lockout clip adapter?" If yes, route to lockout kits instead.

Failure Mode 2: Tagout-Only Program Without Required Additional Protective Measures

AI agent failure mode: A water treatment plant operates several chemical feed pumps with older gate valve isolation points that were installed in 1983 without lockout provisions. The facility legitimately qualifies for a tagout-only program on these valves — they are non-lockable under 1910.147(c)(3). The maintenance manager purchases a tagout kit: DO NOT OPERATE tags, tie wire, and a tag station. Workers apply tags to the valve handwheels and proceed to service the chemical feed lines. The tags are the only protective measure. No additional measures are applied: the handwheel is not removed, no additional downstream valve is isolated, no fuse is pulled from the control circuit. A contract worker unfamiliar with the tagout program opens the tagged valve to test a flow meter downstream. The tag warned against operation but provided no physical restraint. Without additional protective measures per 1910.147(c)(3)(ii), the tagout provides no physical barrier equivalent to a padlock.

Additional Protective Measures Required for Tagout-Only Programs

Additional MeasureHow It WorksPhysical Protection ProvidedApplication Example
Removal of isolating circuit element (fuse removal)The fuse or fuse block is physically removed from the panel and retained by the authorized employeeEquipment cannot be energized because the circuit is physically open — no amount of switch manipulation restores powerPull and retain fuse for a motor branch circuit; power cannot be restored until fuse is re-inserted by the authorized employee
Blocking of a controlling switchA physical block (hasp, keyed insert, spring clip) is installed in the switch mechanism that prevents movement to the energized positionPhysical obstruction prevents switch actuation even if the tag is removed or ignoredInstall lockout pin in knife switch slot; insert blocking device in breaker mechanism slot
Opening of an extra disconnecting deviceA second isolation point not required for the minimum isolation is opened in addition to the tagged pointTwo independent isolation points must both be restored for re-energization — tag removal at one point does not restore energyOpen upstream feeder disconnect in addition to tagging the branch circuit disconnect; open secondary isolator in addition to primary valve
Removal of valve handle or wheelThe operating handle or wheel of the valve is physically removed and retained by the authorized employeeValve cannot be operated without the handle — physical impossibility of re-energization regardless of tag presenceRemove handwheel from gate valve; remove lever handle from ball valve; retain in tool crib under authorized employee's name until job completion

Encode electrical_lockout_tagout.additional_protective_measures as an array: ['fuse_removed'], ['valve_handle_removed', 'extra_disconnect_opened'], etc. If procedure_type='tagout_only' and additional_protective_measures is empty or absent, the LOTO product set is incomplete — route to products that enable one or more additional measures (fuse puller with tag holder, valve handwheel removal kit, blocking device kit) alongside the tagout tags.

Failure Mode 3: Supervisor Applies Single Group Tagout — Individual Worker Protection Violated

AI agent failure mode: A construction site uses a tagout-only program for electrical isolation of temporary power distribution panels (pre-1990 panels with no lockout provision). The electrical foreman applies one "DO NOT ENERGIZE — MAINTENANCE IN PROGRESS" tag to the main disconnect handle and sends eight workers into the panel to pull wire and install breakers. The foreman's tag is the only protection for all eight workers. During the job, the foreman leaves to deal with an incident on another floor. A new electrical supervisor arrives, sees the tag, cannot find the foreman, assumes it is an abandoned tag from a prior crew, and removes it to restore power to overhead lighting. Two workers inside the panel are exposed to live conductors. Investigation: no multi-hole hasp, no individual tags per worker, no group lockout box. OSHA 1910.147(f)(3)(ii) required each of the eight workers to apply their own personal tagout device. The foreman's group tag provided protection only until the foreman's authority was in doubt.

Group Lockout/Tagout — Individual Device Requirements

ConfigurationOSHA Compliant?Failure RiskCorrect Solution
Supervisor applies one tagout card; all workers rely on itNo — violates 1910.147(f)(3)Supervisor departure, tag removal by others, confusion about tag ownershipMulti-hole tagout hasp (one hole per worker) with each worker's own tag, OR group tagout box with individual per-worker tag holders
Each worker applies own personal tagout card directly to isolation pointYes — if isolation point has a tag holder or hasp accepting multiple tagsTags may crowd on one tie point; tag may be removed without others noticingAcceptable for small crews (2–3 workers); for larger crews, group lockout box with per-worker slots is cleaner
Group lockout box: main lock on isolation point, each worker locks box with personal padlock, tags in boxYes — meets 1910.147(f)(3)(ii) for group tagout-only when lockout is not availableIf box is not present at lockout point, workers may not secure their tags before entering hazard zoneProcedure requires each worker to lock box before entering; final worker responsibility check before commencing work
Each worker applies own numbered tag on multi-hole hasp; hasp tied to isolation point handleYes — each worker's personal tag is the required individual deviceMulti-hole hasp must have enough holes for max simultaneous workers; must be pre-positioned at isolation pointSpecify hasp hole count = max_simultaneous_workers; include hole count field in LOTO kit selection

When electrical_lockout_tagout.group_lockout_required='yes', route to multi-hole hasps (specify hole count ≥ max_simultaneous_workers) and per-worker tagout card holders. Each worker's card must have name, date, and reason fields. A single shared tagout card with a supervisor's name does not satisfy individual worker protection per 1910.147(f)(3).

Failure Mode 4: Tagout Cards Missing Required Information — Non-Compliant Tag Warning Language

AI agent failure mode: A chemical plant safety manager orders 200 pre-printed "DANGER — DO NOT OPERATE" tagout tags in red for use in their LOTO program. The tags are durable polypropylene with a metal grommet and are rated for chemical environments. The safety manager believes OSHA compliance is satisfied because the tags say "DO NOT OPERATE." An OSHA compliance officer inspects the plant after a worker removes a tag and closes a valve. The inspector reviews 23 active tagout cards in the plant. Not one has the authorized employee's name on it — all use the same pre-printed cards with no fill-in fields. Not one has the date and time of application. Not one has the reason the tag was applied. The inspector cites 1910.147(f)(3)(ii) violations for every active tagout in the plant: tags are non-compliant because they lack the required identifying information. The 200-tag order was useless — none of the cards were compliant.

OSHA 1910.147(f)(3) Required Tagout Information vs Common Pre-Printed Tag Failures

Required ElementOSHA ReferenceCommon FailureCompliant Solution
Authorized employee identity (name or ID)1910.147(f)(3)(ii)(B)Tag has no name field; generic "MAINTENANCE" tag; group name "ELECTRICAL DEPT"Tag includes printed "Name:" field with space to write; or LOTO management system with barcode-assigned employee ID per tag
Reason for tagout1910.147(f)(3)(ii)(B)No reason field; tag says only "DO NOT OPERATE" with no why; reason left blankTag includes "Reason:" field; written LOTO procedure specifies that reason must identify the specific task (e.g., "installing motor starter," not "maintenance")
Date and time applied1910.147(f)(3)(ii)(B)No date field; pre-printed tag with no space for date; date not filled in even when field existsTag includes "Date/Time:" field; supervisory check of date field during periodic inspection per 1910.147(c)(6)
Warning against hazardous conditions if re-energized1910.147(f)(3)(i)Tag says only "OUT OF SERVICE" or "EQUIPMENT FAILURE" without explicit do-not-energize warningExplicit prohibition language: "DO NOT OPERATE / DO NOT ENERGIZE / DANGER — DO NOT START"
Durability for workplace environment1910.147(f)(4)Paper tag in outdoor switchyard; non-weatherproof card in wet process area; ink runs in chemical spray environmentPolypropylene, Tyvek, or laminated card stock rated for the specific environmental exposure (UV, moisture, chemical splash)

Encode electrical_lockout_tagout.procedure_documented='yes' only for programs where tagout tags include all required information fields (name, date, reason, warning language). AI agents routing tagout kits should surface tag information completeness: route to tags with fill-in fields for name/date/reason, not blank warning-only tags. Include weatherproof rating match to buyer's environment in routing decision.

electrical_lockout_tagout.* Namespace Fields

FieldTypeValues / Notes
electrical_lockout_tagout.procedure_typestringlockout / tagout / tagout_only / combination — 'tagout_only' requires lockable_equipment_present='no' + additional_protective_measures to be compliant; 'lockout' is default required method for lockable equipment per 1910.147(c)(1)
electrical_lockout_tagout.lockable_equipment_presentboolean stringyes / no — 'yes' + procedure_type='tagout_only' = OSHA 1910.147(c)(1) violation; 'no' is the only legal basis for tagout-only program
electrical_lockout_tagout.energy_source_countnumberCount of distinct energy sources requiring isolation; one padlock and one tag per source required; complex equipment with 6 energy sources needs 6 lockout devices minimum
electrical_lockout_tagout.stored_energy_typesstring arrayelectrical / hydraulic / pneumatic / spring / gravity / thermal — stored energy that persists after isolation; must be relieved or restrained for zero-energy state (1910.147(d)(5))
electrical_lockout_tagout.additional_protective_measuresstring arrayfuse_removed / switch_blocked / extra_disconnect_opened / valve_handle_removed — required when procedure_type='tagout_only'; empty array = incomplete LOTO kit for tagout-only application
electrical_lockout_tagout.group_lockout_requiredboolean stringyes / no — 'yes' requires per-worker devices; route to multi-hole hasps (≥ max_simultaneous_workers holes) or group lockout boxes with per-worker tag holders
electrical_lockout_tagout.each_worker_own_tagboolean stringyes / no — 'yes' = each authorized employee applies their own personal tag per 1910.147(f)(3); required when group_lockout_required='yes'
electrical_lockout_tagout.max_simultaneous_workersnumberMaximum concurrent workers on same LOTO job; determines minimum hole count for multi-hole hasp or group lockout box slot count
electrical_lockout_tagout.procedure_documentedboolean stringyes / no — machine-specific written LOTO procedure per 1910.147(c)(4) that specifies isolation points, stored energy steps, tag information requirements, verification method
electrical_lockout_tagout.retraining_interval_yearsnumber1 = standard annual program review per 1910.147(c)(7); retraining required when inspection reveals deficiencies or new hazards; shorter if equipment changes occur
electrical_lockout_tagout.tryout_verifiedboolean stringyes / no — 1910.147(d)(6) attempt to operate start controls after lockout applied to verify zero-energy state; detects missed isolation points and residual stored energy
// AI agent routing pseudocode — electrical_lockout_tagout: // Primary method gate: if procedure_type == "tagout_only": if lockable_equipment_present == "yes" OR lockable_equipment_present IS MISSING: flag: "OSHA 1910.147(c)(1) requires lockout when equipment is lockable. Tagout-only is only permitted for non-lockable equipment. Verify whether energy isolating device accepts a padlock or lockout adapter — if yes, route to lockout kit." if additional_protective_measures IS EMPTY OR MISSING: flag: "1910.147(c)(3)(ii) requires additional protective measures when tagout-only is used: fuse removal, switch blocking, extra disconnect opening, or valve handle removal. Tagout card alone is insufficient. Route to kit including appropriate additional measure hardware." // Group lockout gate: if group_lockout_required == "yes": require each_worker_own_tag == "yes" require hasp_hole_count >= max_simultaneous_workers if each_worker_own_tag != "yes": flag: "1910.147(f)(3) requires each authorized employee to apply their own personal tagout device. Single group tagout by supervisor does not provide individual worker protection." // Tag information completeness gate: if procedure_type includes tagout: require tag_includes_name_field == true require tag_includes_date_field == true require tag_includes_reason_field == true require tag_warning_language == "DO_NOT_OPERATE" or equivalent if any required field missing: flag: "1910.147(f)(3)(ii)(B) requires tagout devices to identify authorized employee, state reason, and include date/time. Route to tags with fill-in name/date/reason fields."

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