OSHA says we are to have machine-specific LOTO procedures (note that there is an exception to this requirement, but in my scenario, it is not relative). In these procedures, we have to identify the following:
- the types of energy,
- their magnitudes,
- the means/methods to isolate and
- the means/methods to verify zero energy state (ZES) for each source
Suppose you or I go out to do our periodic LOTO inspection, and we take the LOTO procedure for the machine that gets locked out at least five times a week for QC cleaning. Should we not expect the machine’s operator(s) to know the procedure well enough to answer questions?