What does it mean to comply with 1910.147 vs. having a “management system” for Energy Control

Last month, I discussed what a “management system” would look like should we manage our Permit-Required Confined Space entry operations as a “management system” versus a standalone OSHA compliance program.  (CLICK HERE for that post)

Today, I want to discuss the same approach but in respect to how we manage another life safety critical practice… The Control of Hazardous Energy is better known as Lockout/Tagout (LOTO).  As of this writing, I have written about LOTO 187 times, most of which are on the technical side of developing, implementing, managing, and auditing LOTO programs and procedures.  In this article, I want to take a 35,000-foot view of how a an Energy Control Program should be managed by those closest to the action.  So here is the outline of what I will be discussing:

1) Written Program

2) Machine/Equipment specific energy control procedures

3) Training

4) Periodic Inspections

5) Auditing

And, of course, I will again use the PLAN→DO→CHECK→ACT model to wrap our heads around this topic.

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