This is a great example of how businesses make the mistake of viewing LOTO as a “maintenance function” and therefore ONLY maintenance personnel need to be trained in LOTO. This case covers Training, Machine Specific procedures, and application of LOTO devices. It also shows how operations personnel can actually do “maintenance and servicing” activities (as defined by 1910.147) and at least will be “affected personnel” under a properly implemented LOTO program. The case also gets into the level of details that are needed in “machine specific procedures” and how regurgitation of 1910.147 Appendix A is not sufficient to be a “machine specific” procedure. Here is the case, as explained by the OSHRC: