On New Year’s Eve, I hope many safety pros will choose a 2024 resolution to end the regurgitation of OSHA standards as their “written programs.” I have always used the OSHA standard as my baseline, but these programs need to EXPLAIN HOW the facility will meet the requirements – not repeat the requirements. For example…
I hope we can move on from simply cutting and pasting the OSHA standard into a document and claiming this to be a written program. This year, we came across numerous LOTO programs at multiple billion $ businesses that regurgitated the LOTO standard in their written program…
Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size…
The written program MUST state how the facility has chosen to identify its lockout locks, either by color or multiple colors, shape(s), or size(s). Then, the facility trains EVERYONE on how to identify these locks using one of these visual methods.
Another example of DEFINING our safety matters! OSHA gives us options; we have to DEFINE the means/method we will use to IDENTIFY our LO locks.