Tagout rules regarding material strength requirements contained in OSHA 1910.269 have been debated by industry safety experts and those required to comply with these rules since their implementation.
In a previous blog I broke down the regulations for the attachment means for tags. But what about the tag materials themselves?
Like many other industry regulations, OSHA 1910.269 Electrical Power Generation, Transmission, and Distribution contains ambiguous wording that stirs up debate and causes misunderstanding.
In this blog, I’ll break down OSHA 1910.269 and explain what you need to know to be compliant with its rules concerning tagout materials.
Pull Strength Requirements
Both the NESC and OSHA have rules surrounding the lockout tagout process, equipment, and materials.
Although NESC rules are not specific to tag design and materials, OSHA’s are; and also specify strength requirements.
Concerning the graphical design of tags, OSHA references and incorporates as regulation the standard ANSI Z535.5 Safety Tags and Barricade Tapes (for Temporary Hazards).
Within its scope OSHA 1910.269 states the following:
“Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds and shall have the general design and basic characteristics of being at least equivalent to a one-piece, all-environment-tolerant nylon cable tie.”
The common misinterpretation held in our industry is that this regulation requires a minimum 50 lb. pull strength requirement for safety tags themselves.
After careful evaluative reading, I was lead to the conclusion that the 50 lb. strength specification is required of the attachment means only, and not the actual tag itself.
This has since been Electromark’s understanding of the rule and has been substantiated by an official letter of interpretation from OSHA’s Director of Enforcement Programs, Thomas Galassi.
OSHA 1910.269 specifies that the tag shall be, “substantial enough to prevent inadvertent or accidental removal.”
Another paragraph specifies that “lockout devices and tagout devices shall be capable of withstanding the environment to which they’re exposed for the maximum period of time that exposure is expected.”
Although pull strength doesn’t have to meet a minimum 50 lbs., together these paragraphs clearly mean that tags need to be strong enough and durable enough to perform the required task without failure.
Unfortunately, these rules provide little guidance as to what exact materials are appropriate for safety-related applications.
Ultimately, it’s up to the service utility to determine what materials meet these somewhat ambiguous requirements.
What Electromark believes, particularly in the outdoor environments where many service utilities utilize tagout, is that paper and cardstock tags are simply not appropriate for safety-related applications.
The materials and inks they’re printed with aren’t outdoor durable, and tags made from these materials should only be used for non-critical applications such as equipment inspection or maintenance record tags.
For safety and outdoor applications, stronger and more durable plastic tag materials should be utilized.
The tougher and more weather resistant your plastic tag materials are, the better.
The best high-performance plastic tag materials include polyester and vinyl, both of which are resistant to weathering.
Keep in mind that while polyester and vinyl are unaffected by rain and will withstand UV deterioration from sunlight for several years, under extreme conditions such as the whipping forces of high winds the durability of these materials may be limited to weeks or days.
Also note that by definition under ANSI Z535.5 Safety Tags and Barricade Tapes (for Temporary Hazards), tags are identified for temporary hazards.
Conditions such as temporary deenergization while work is being performed, require tags that should only be used for hours, to perhaps days or at most a week. Beyond that, more permanent deenergization, lockout, or marking identification should be considered.
The Electromark advantage
Electromark offers many thicknesses of polyester and vinyl tag stock materials for tags, as well as options such as self-laminating cover flaps to protect user inscribed information, reinforcing eyelets or grommets, regulation compliant 50 lb. rated zip-tie attachments, and more.
We have everything you need to make sure your tags last in the field – including expert insight to assure you’re receiving the right solution for your application.
Whether it be a short-term, temporary deenergization, or a long-term application in extreme weather, Electromark has the tags and unique accessory solutions that will assure your tagout applications keep your workers safe.
To learn more, check out Electromark’s Tagout Marking Solutions product brochure.
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I have been in my present role as Technical Sales and Application Engineer with Electromark for 9+ years, and with the company for 14 years. My earlier experience with the company was with our printing and other manufacturing operations. My knowledge with Electromark and the industries it serves includes materials, products, process capabilities, weathering durability, regulations, and standards. See my Linkedin profile at https://www.linkedin.com/in/brandon-furber-0036644a/
With over 40 years of experience, Electromark specializes in identification and safety marking solutions for the electrical utility industry, other service utilities, and the outdoor industrial workplace. Our products are engineered for the harsh, outdoor environment.