This is a fascinating case, as the OSHRC has upheld this citation, although they significantly reduced the $ and made it “other-than-serious.” But again, I disagree with this case, as the workers appeared to have been protected during the belt change; they did not follow the LOTO procedure, which I believe was “lazily written.”
This case boils down to a sprawling multi-component machine with numerous energy isolation devices (EIDs) for electrical energy. The LOTO procedure for this large machine, which occupies about 75% of the Center’s floor space, required that the entire machine be locked out for work on just one of the many conveyor belts associated with the machine. Management decided that only the belt that would be worked on had to be LOTO’ed, thus allowing the rest of the machine to run.
We should all pay attention to this case, as many workplaces will have large and complex machinery that could allow certain pieces to be locked out so that the rest of the machine could continue running. PLEASE KNOW this REQUIRES a detailed hazard assessment, and many LOTO programs are too immature to manage this decision-making, but there are certain situations where a machine will have 20 EIDs to get the entire machine to a ZES, but the servicing task being performed will only need 2-3 of the EIDs utilized. However, if these “tasks” do not specifically indicate which EIDs need to be utilized, it appears OSHA will expect the main LOTO procedure to be executed.
Here is the case file: