Lockout Tagout

The Eleventh Circuit reinstates OSHA’s LOTO Citation regarding a contractor death

This is SIGNIFICANT for those who truly believe in the purpose and function of OSHA’s LOTO standard.  I was never more disappointed in an ALJ than after they decided to vacate such a clear violation of LOTO.  I may have even said, “Why do lawyers/judges make for bad safety professionals.”  This fatality involved an apprentice…...

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The Eleventh Circuit reinstates OSHA’s LOTO Citation regarding a contractor death Read More »

LOTO is NEVER based on how “slow it moves”, even when it is 1 revolution/10 minutes

Have you ever been told… “it moves too slow to be a hazard”?  If you stay in the safety profession long enough, you will be presented with this viewpoint.  But LOTO is NEVER about how slow something moves; there is no exemption in the standard for such a thing.  Here is a case we can…...

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LOTO is NEVER based on how “slow it moves”, even when it is 1 revolution/10 minutes Read More »

My Group Lockout – Lockbox method

This is a written explanation of how I was taught to perform Group Lockout and how to manage contractors working on-site under a Group Lockout.  There are many things in this document that are NOT required by OSHA; however, they are in the program to ensure compliance with OSHA’s minimum expectations.  We did it this…...

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What it means to have EXCLUSIVE CONTROL and case in point what happens when we share a lockout/tagout

If we had a dime for each time we get pushback on the most fundamental aspect of Lockout/Tagout (LOTO), we could all retire!  NEVER is an authorized employee allowed to work under someone else lock – PERIOD!  When servicing and maintenance that requires LOTO is performed, then EACH authorized worker MUST HAVE EXCLUSIVE CONTROL of…...

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What it means to have EXCLUSIVE CONTROL and case in point what happens when we share a lockout/tagout Read More »

The tale of two LOTOs – worlds apart (Compressed Air)

If you have equipment that uses compressed air (CA) as an energy source, you will understand my frustrations with how poorly we manage this hazardous energy source.  Typically, compressed air is provided via a plant-wide header system with drops for machine/equipment.  These drops will then use a hose to deliver the compressed air to the…...

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Warped Wednesday… safety is “just common sense” excuse #121 – Lockout

LOTO locks can be keyed alike.  For example, equipment/field locks can all be keyed to a SINGLE key; however, personal/individual locks MUST BE individually keyed (e.g., 1 key – 1 lock).  Before starting work ask yourself this simple but very important question: Do I have EXCLUSIVE/SOLE control of each and every isolation device protecting ME? …...

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Warped Wednesday… safety is “just common sense” excuse #121 – Lockout Read More »

Verification of Zero Energy State (ZES) and Specific Procedures

One of the more popular findings in our LOTO assessments/audits involves the lack of specific procedures for verifying a zero energy state (ZES) for EACH energy source.  The LOTO standard, 1910.147, makes it clear that the energy control procedure must be “specific.”…… Membership Required You must be a member to access this content.View Membership LevelsAlready...

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Lockout with cable/shark leader and identifying the isolation device is under LOTO control

The client has approved this posting as they want to make sure others can learn from their incident.  PLEASE discuss this incident with your teams if your LOTO practice(s) resemble theirs –  what they did was VERY COMMON and I teach this method in all my LOTO courses at process plants.  I have revised my…...

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Lockout with cable/shark leader and identifying the isolation device is under LOTO control Read More »

Isolating pneumatic energy sources and verifying a ZES

Earlier today I posted a recent OSHA citation where a facility was cited for not having procedures regarding the means to isolate and verify ZES for pneumatic energy sources (i.e. plant air).  For some reason, on nearly all of my LOTO projects I find that air sources are a bastardized source of energy when it…...

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Isolating pneumatic energy sources and verifying a ZES Read More »

OSHA cites employer for LOTO issues (Magnitudes, Means to verify ZES)

This OSHA citation involves items other than LOTO. Still, the LOTO citations caught my eye precisely because the equipment-specific procedures did NOT state how pneumatic sources (e.g., air) were to be verified at a Zero Energy State (ZES).  The means to verify a ZES is a critical step in LOTO, and far too often, the…...

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OSHA cites employer for LOTO issues (Magnitudes, Means to verify ZES) Read More »

Does magnitude matter in LOTO? (Blinds and Blanks with PRCS)

In 2014, the Occupational Safety and Health Review Commission (OSHRC) issued a judgment on an OSHA case, and in the case, they made it clear that “magnitude” matters in lockout/tagout (LOTO).  But for some reason, this piece of data is absent from many machine-specific LOTO procedures and OSHA always takes issue with this oversight.  So…...

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Does magnitude matter in LOTO? (Blinds and Blanks with PRCS) Read More »

Does a manufacturer’s maintenance instruction over-ride OSHA’s “minor servicing” exception?

We have a machine and this machine has a couple of tasks that have been deemed “minor servicing”.  As we walk by we see a worker in the machine and no LOTO in place so of course we stop and ask about the situation.  We are told the task being done, “XXXXXXXX”, is indeed a…...

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Does a manufacturer’s maintenance instruction over-ride OSHA’s “minor servicing” exception? Read More »

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