Last month I wrote a few posts about how a compliance manual made up of dozens of individual safety programs written for OSHA compliance needs is not a safety management system (SMS). That post got a lot of friends to encourage me to expand on that position and explain what I meant. So using one of my favorite OSHA standards, I want to demonstrate how Lockout/Tagout (LOTO) can indeed be managed as its own miniature SMS and how this fits into the more significant SMS for the facility.
Complying with OSHA’s LOTO standard (1910.147) is a never-ending cycle of Plan-Do-Check-Act. This simple fact makes the standard mimic a SMS built upon the same model. So how does LOTO follow the PDCA model?