Those of us under Federal OSHA can let our contractors follow their own LOTO program/practices AS LONG AS they explain them to us. However, in some states, their OSHA plan requires contractors to support the “on-site employer’s” LOTO program. As I have written about, most workplaces struggle to manage their contractors PROPERLY when LOTO is involved in their work scope.
From expecting contractors to be LOTO experts on our equipment/process/machinery, including the energy types, their magnitudes, the means to isolate them and the means to verify a ZES – most contractors end up placing themselves in serious jeopardy. This is ON TOP of the fact that when a contractor uses his/her LOTO locks in our workplaces, they may be of a different COLOR, SHAPE, or SIZE than what the affected and other employees have been trained to recognize as a LOTO lock. So the state of California [OSHA] requires contractors to follow the on-site employer’s LOTO procedures…