Electrical Lock, Tag & License - Washington (DOSH)

Federal construction rules say that a control switched off during electrical work "shall be tagged." Washington took that sentence and added one word that changes the job: padlock. On a Washington construction site, deactivated controls and deenergized circuits get a tag and a padlock, at every point where they could be energized. Washington also says who may do the electrical work in the first place: only state-certified electricians, with trainees carrying their own training certificates and working under a set ratio. This Washington Electrical Lock, Tag & License Toolbox Talk covers both rules.

Where the boundary of this talk sits#

This talk covers Washington's electrical lock-and-tag rule for construction and the state electrician certification and supervision rules. General lockout for machinery, arc flash, GFCIs, and temporary power belong to their own talks.

The anchor#

Here is the distinction that carries this whole talk: in Washington a tag alone is not the default for electrical work — WAC 296-155-429 requires controls deactivated during work to be tagged and padlocked in the open position, and deenergized equipment or circuits to have tags and locked padlocks at all points where they can be energized, with a tag used without a lock only if a lock cannot be applied or tagging is shown to be equally safe, and then backed by an extra safety measure; and only a person holding a state electrician certificate, or a trainee with a training certificate working under certified supervision at no more than one trainee per certified electrician on journey level work (two on specialty work), may do the electrical work — so a hung tag on an unlocked breaker, or a helper working alone on a circuit, is out of compliance in Washington even where it would pass elsewhere.

Tag and padlock#

WAC 296-155-429 opens with three rules that match the federal wording except for the lock:

• (1) Controls: you must tag and padlock controls that are deactivated during the course of work on energized or deenergized equipment or circuits in the open position.
• (2) Equipment and circuits: you must render deenergized equipment or circuits inoperative and attach tags and locked padlocks at all points where they can be energized.
• (3) Tags: you must place tags to identify plainly the equipment or circuits being worked on.

The full procedure#

Subsection (4) applies while any employee is exposed to contact with parts of fixed electric equipment or circuits that have been deenergized. It requires a written copy of the procedure, kept available for inspection, and sets the steps in order.

Deenergize. Disconnect the circuits and equipment from all electric energy sources. Release stored electric energy that might endanger personnel, discharge capacitors, and short-circuit and ground high-capacitance elements.

Lock and tag. Place a lock and a tag on each disconnecting means used to deenergize the circuits and equipment. Each tag must contain a statement prohibiting unauthorized operation of the disconnecting means and removal of the tag. A tag may be used without a lock only if a lock cannot be applied, or if the employer can demonstrate that tagging provides a level of safety equivalent to a lock. A tag used without a lock must be supplemented by at least one additional safety measure, such as removing an isolating circuit element, blocking a controlling switch, or opening an extra disconnecting device.

Verify. A qualified person must use test equipment to test the circuit elements and electrical parts that employees will be exposed to, and verify they are deenergized. If the circuit is over 600 volts, nominal, the test equipment must be checked for proper operation immediately before and immediately after the test.

Reenergize. A qualified person tests and inspects to verify that all tools and other devices have been removed. Employees exposed to the hazards of reenergizing are warned to stay clear. Each lock and tag is removed by the employee who applied it or under their direct supervision. There must be a visual determination that all employees are clear before the circuit is reenergized.

If the employee who applied a lock or tag is not available, a qualified person designated to do so may remove it, provided the employer makes sure that employee is not at the workplace and is aware that the lock or tag has been removed.

Who may do the electrical work#

RCW 19.28.161(1) says no person may engage in the electrical construction trade without a valid master journey level, journey level, master specialty, or specialty electrician certificate of competency issued by the department. Apprentices and others learning the trade must obtain an electrical training certificate from the department, have it in their possession at all times while performing electrical work, and show it to an authorized department representative on request.

Supervision and ratios#

RCW 19.28.161(3) defines supervision: the trainee must be on the same jobsite and under the control of a certified electrician, and a certified electrician must be on the same jobsite as the noncertified individual for at least 75 percent of each working day, unless the chapter provides otherwise.

RCW 19.28.161(4) sets the ratio on any one jobsite:

• Specialty work: not more than two noncertified individuals for every certified master specialty or specialty electrician working in that specialty, or master journey level or journey level electrician.
• Journey level work: not more than one noncertified individual for every certified master journey level or journey level electrician.

The statute has narrow exceptions, including a higher ratio for students in an approved electrical construction program and reduced supervision for apprentices in the final six months of an approved program.

Washington versus federal#

The federal rule, 29 CFR 1926.417, says controls to be deactivated shall be tagged, deenergized equipment or circuits shall be rendered inoperative with tags at all points where they can be energized, and tags shall plainly identify the equipment or circuits. It does not require a padlock. Federal OSHA also does not license electricians. Washington requires a padlock with the tag, a written procedure, and state-certified electricians with trainee ratios.

Where the duty sits#

WAC 296-155-429 sets tag and padlock on controls (1), tags and locked padlocks on deenergized equipment and circuits (2), identifying tags (3), and the written lockout and tagging procedure (4): deenergize, lock and tag, verify, and reenergize. RCW 19.28.161 sets electrician certificates, training certificates in possession, supervision, and ratios. For contrast, federal 29 CFR 1926.417.

What can go wrong?#

• A tag is hung on a breaker with no lock, "just for a few minutes."
• The capacitor bank is not discharged before hands go in.
• Nobody tests for absence of voltage because "the breaker's off."
• A helper finishes a circuit while the journeyman is on another floor most of the day.
• A lock is cut off because the electrician who hung it went home.

How do we manage this properly?#

• Lock and tag every point — where the circuit can be energized.
• Tag only if a lock won't fit — and add a second safety measure.
• Release stored energy — discharge capacitors, ground high-capacitance parts.
• Test before touching — a qualified person, with a working tester.
• Your lock, your key — removed by you or under your direct supervision.
• Certified hands only — journey level or specialty certificate; trainees carry theirs and stay within the ratio.

Before you start#

Know whose locks are on the panel today and where every disconnect for your circuit is. If you're a trainee, have your training certificate on you and know which certified electrician is supervising you.

Talk it over#

• How many points can energize the circuit we're working on today?
• Who is the qualified person testing it dead?
• What is our trainee-to-journeyman ratio on this site right now?

The bottom line#

Washington took the federal electrical tagging rule and added the padlock. Deactivated controls are tagged and padlocked, deenergized equipment and circuits carry tags and locked padlocks at every point where they can be energized, and a tag alone is allowed only where a lock can't be used or tagging is proven equally safe, with an extra measure. A written procedure covers deenergizing, locking and tagging, testing, and reenergizing. Only state-certified electricians do the work, with trainees carrying their certificates and supervised one-to-one on journey level work.

Frequently asked questions about Washington electrical lockout#

Does Washington require a lock, or is a tag enough, on electrical circuits?

A lock and a tag. Under WAC 296-155-429, controls deactivated during work must be tagged and padlocked, and deenergized equipment or circuits must have tags and locked padlocks at all points where they can be energized. A tag alone is allowed only if a lock cannot be applied or tagging is shown to be equally safe, and then with at least one additional safety measure.

Download the Washington electrical lock, tag and license toolbox talk PDF#

Download this Washington Electrical Lock, Tag & License Toolbox Talk as a printable PDF in English and Spanish, and review it before the next panel shutdown.

Related toolbox talks#

• Lockout/Tagout
• Electrical Safety
• Energized vs. De-energized Work
• Grounding and Arc Flash

Sources#

• Washington State Legislature, WAC 296-155-429 — Lockout and tagging of circuits ((1) tag and padlock controls; (2) tags and locked padlocks at all points; (3) identifying tags; (4) written procedure; deenergize and release stored energy; lock and tag each disconnect, tag statement, tag without lock only if lock cannot be applied or equivalent safety shown, plus an additional measure; qualified person tests, over 600 V tester checked before and after; reenergizing steps; removal by the employee who applied it or a designated qualified person; WSR 16-09-085, effective 5/20/16): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-429
• Washington State Legislature, RCW 19.28.161 ((1) certificate of competency required; (2) training certificate in possession; (3) supervision, same jobsite at least 75% of each working day; (4)(a) two noncertified per certified for specialty work; (4)(b) one per certified for journey level work): https://app.leg.wa.gov/rcw/default.aspx?cite=19.28.161
• OSHA, 29 CFR 1926.417 (controls tagged; deenergized equipment rendered inoperative with tags; tags identify equipment): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.417

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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