Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for “specific equipment/machines” and what they must contain. This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in “complex” situations. I like to explain to clients that LOTO in a chemical process is managed differently than how it is managed at a traditional manufacturing facility. I put LOTO into three (3) buckets:
1) Simple LOTO
2) Traditional LOTO
3) Complex LOTO
Using 29 CFR 1910.147 as our road-map we can clearly see how these three (3) buckets play out.
1) Simple LOTO