1. You are responsible for contractors too.
Some companies believe they can get around the requirement for creating LOTO procedures because they contract the work out to a third party. The reality is that OSHA requires a procedure to be available when there’s an inspection. If a contractor is hurt while working on a piece of equipment in your facility, OSHA can, and will, cite both companies for lack of LOTO compliance. To achieve compliance, have a LOTO procedure created for the equipment that’s being serviced, and require that your contractor use it.
Confirm your contractor is an authorized employee by providing a quick training session to ensure they understand how to use the procedure, when to use it, and what hazards they’ll be working around while locking out the equipment.