On the loto document you can apply any tech's name regardless of loto level. Also, if I TYSHW sign a loto step I can put another tech name down for the verification for the next step making him responsible with no knowledge.

For instance,
we started the hub loto document I signed off the first step for rotor pin. The following step is loto on a breaker I can put a different techs name for that step and continuing this throughout all the steps. Including putting techs that are not the proper loto level.