Luckily, these kinds of encounters are dwindling, but even mentioning this in 2019 says a lot for the “State of Safety” in the USA. Have you ever encountered a management group where you hoped Dr. Suess would re-write the OSHA LOTO Std? I mean, they hire us to explain and assist in implementing the basic safety programs – LOTO being one of the top three CORE PROGRAMS (IMPO!). So I am attempting to explain how LOTO will apply to their workplace and one of the team ask me to show them in the standard where it says that when an energy isolation requires more than a single lock, or tag, that the LOTO must have a written “machine/equipment specific” procedure. Unfortunately, OSHA does not write its standards such that they come out and state this verbatim. Still, as I said in my article covering the LOTO Exception for written procedures, it is rare when a written isolation plan is NOT required to meet the OSHA minimums. So, where in the standard does OSHA require written procedures?