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,…
Category: Lockout Tagout Facts
2. Audits are required — every year. There’s no way around it and don’t waste time looking. The requirement is every procedure, every year. This means each machine-specific procedure in your facility must be reviewed at least annually to ensure it’s still available and accurate. Additionally, OSHA requires that you audit your authorized employees — those applying locks — to confirm they comprehend the proper usage of the program. Any deficiencies identified during the procedure or the…
3. Procedures are required. OSHA requires machine-specific procedures for all equipment in your facility. Some might argue there are exceptions to this rule, but experience has shown it’s not worth the effort to identify the very small percentage (less than 5%) that doesn’t require a procedure. In short, if you can service it, it needs a procedure. A LOTO procedure’s purpose is to detail out all the critical information that needs to be known to…