In OSHA’s LOTO standard, they incorporated a requirement that required businesses to have forethought about the means used to isolate energy. Specifically, the standard requires:
| 1910.147(c)(2)(iii) After January 2, 1990, whenever replacement or major repair, renovation or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machine or equipment shall be designed to accept a lockout device. |
This was in response to OSHA knowing that this new standard would require design changes on a lot of equipment in use in the USA. Having started my career in Industrial safety in 1993, I can still remember having discussions on capital spending to modify existing equipment so lockout devices could be used to isolate them and the battles we had with equipment manufacturers from who we were buying new equipment.
