A careful distinction must be made between LOTO and various other locking practices, collectively referred to as “Administrative Locking” (see Figure 18-9). While LOTO locks are placed by individual workers to protect themselves against inadvertent energization of equipment, Administrative Locks are used when there is the need to provide “operational control” (control of a system, utility, or facility).

Administrative Locking does not provide individual personal protection for at-risk workers as that achieved by LOTO.

Examples of Administrative Locking may include:

• Maintenance shut down and lockout of the controller for an HVAC chiller because it will be serviced by an outside contractor. In this case, LBNL Facilities personnel first shut down and apply Administrative Locking to the controller. Then, each LOTO-Authorized Employee of the chiller contractor applies LOTO to each source of hazardous energy to protect them from accidental startup.


• Facilities electrical shuts down and applies Administrative Locking on a main electrical panel to prepare for a lab user to hook up equipment. Lab personnel are not LOTO-Authorized to shut down the main panel, but they must apply their personal LOTO locks and tags to the individual circuit breaker to provide hazardous energy control.

In these types of situations, the purpose of Administrative Locking is vastly different from the control of hazardous energies for the protection of the worker in the hazard zone. An employee applying Administrative Locking is not near the hazard zone, and therefore does not need to use the specific personalized locks and tags required by traditional LOTO requirements.

If the employee applying the Administrative Lock in any way becomes exposed to the controlled hazardous energies, he or she must first apply his or her LOTO lock and tag.

Administrative Locks can be common locks with more than one key, so that anyone with access to the keys can open the control point as needed. The lock is not specific to an individual, but to a specialized working group or trade. Administrative Tags, likewise, are also common to multiple people and do not need to have an individual’s name shown.

If the person removing the Administrative Lock is not the same person who placed it, a documented understanding must exist between the two persons of the intent behind the placement of the lock and the conditions necessary for its safe removal.

Other examples of administrative locking are:

• Locked fences around high-voltage transformers.
• Locks on overhead-crane disconnect switches.
• A locked door to a laboratory containing hazardous equipment.

In many applications, it is appropriate to use a combination of Administrative Locking and LOTO controls. For example, if one group or shop must retain oversight of a utility while others are performing work associated with that system, an Administrative Lock may be placed by the oversight group in parallel with the individual LOTO locks and tags placed by each LOTO-Authorized Employee.

Figure 18-9. Example of Administrative Locking