Energy Isolation in a chemical process is a “complex LOTO”

Under most circumstances, where servicing or maintenance is to be conducted during only one shift by a small number of persons, the installation of each individual’s LOTO device on each energy isolation device would not be a burdensome procedure. However, when complex equipment is being serviced or maintained, when there are many sources of energy, and/or when servicing/maintenance work extends over more than one work shift, OSHA permits employers to utilize an alternative procedure to each employee locking or tagging out each energy-isolating device. Consideration must be given to the procedure’s organizational structure in order to ensure the safety and control of EACH of the employees involved. For example…

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