In 2026, cutting and pasting OSHA standards and revising a few words does NOT make for a safety program/safe work practice. Yet already this year, I have seen two LOTO programs that state
Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized.
Of course, the facility has NOT identified their LO locks by color, shape, or size, and man, do they get mad when they find out this is a finding in their audit. Even lawyers will argue after the business realizes how much it’s going to cost to do LOTO the correct way.
Our programs/practices need to DEFINE the WHO, WHAT, WHEN, WHERE, and HOW the business will manage the hazard(s) that the program/practice is intended to CONTROL.
We should be calling out official management and front-line supervision positions (as stated in the Org Chart) for responsibilities within these programs, as they are the ones the programs were written for. Safety will always have a role in the program, as we are the owners of the SMS, but for these programs to work in the workplace, we need to ensure everyone knows everyone’s role in each program and then ensure those roles within the organization are provided the knowledge, time, and tools to make it happen.
Safety’s primary role is to DEVELOP and IMPLEMENT a program/practice that has been thoroughly vetted by management and by those with roles within the program/practice. Any deviation from said program/practice: Safety will facilitate the Risk Analysis, develop a plan to compensate for the deviation, and review whether the program needs to be revised to address said deviation.
We all play a role in developing and implementing programs and practices that manage the risks within our workplace; however, we need to define these roles so everyone is singing from the same sheet music, at the same rhythm, and with the same tone! This is Safety Management System 101 – having well written programs/plans/practices.