Can I do Servicing and/or Maintenance tasks without the aid of LOTO?

I like direct statements and clear concise rules when it comes to drawing the lines of safety and production and maintenance.  But too often, these lines get drawn in the wrong spot and cause safety all kinds of issues and let’s admit it… gives safety a bad name.  One such line is when lockoout/tagout (LOTO) applies.  We can not just state that LOTO applies for all “servicing and/or maintenance” tasks as OSHA defines these tasks:

Workplace activities such as constructing, installing, setting up, adjusting, inspecting, modifying, and maintaining and/or servicing machines or equipment. These activities include lubrication, cleaning or unjamming of machines or equipment and making adjustments or tool changes, where the employee may be exposed to the unexpectedenergization or startup of the equipment or release of hazardous energy.

I have actually re-engineered some equipment for the sole purpose of allowing workers to perform certain “servicing and/or maintenance” tasks WITHOUT having to apply LOTO to do the work safely.  In fact, in some facilities, by making these changes we kept several hundred workers as “affected workers” ALL THE WHILE making their work SAFER!  Here is one such real world example of what we did:

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