Unfolding Lockout/Tagout (LOTO)!
An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.
J.B. Titus
Hazardous energy must be controlled when employees are servicing and maintaining machines in order to prevent serious physical harm or even death. To address this hazardous issue OSHA created The Control of Hazardous Energy (Lockout/Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147. As a reference source, OSHA used ANSI Z244.1-1982 in the creation of this regulation and continues to reference Z244 on their web site. Since LOTO was created OSHA has issued several letters and Circulars of interpretations for application of the requirements and ANSI has also updated Z244.1 to the current 2003 issue. With all this said, why do you suppose levels of uncertainty seem to exist regarding “my requirements” vs the level of requirements simply laid out by OSHA, ANSI, and other consensus standards.
Do you think Richard E. Fairfax, Director, OSHA Directorate of Enforcement Programs, in his interpretation letter on this subject confused anyone when he brought the term “de minimis into the mix? Has anyone come across an OSHA regulation that describes the full legal interpretation of “de minimis”? How does industry properly and accountably apply this term to employee training and their company “Safety Policy” manual?
After further research I found an OSHA Fact Sheet. This two page summary on LOTO is a great summary. However, in my opinion it begins to get a little fuzzy in the section, What do employees need to know? See below:
“The training must cover at least three areas: aspects of the employer’s energy control program; elements of the energy control procedure relevant to the employee’s duties or assignment; and the various requirements of the OSHA standards related to lockout/tagout.”
Oh oh, this now begins to sound like a subject I’ve blogged on before titled, “Machine Safety and Your Safety Culture”. In my opinion, the last point in OSHA’s advice above unmistakably is about the LOTO regulation, 1910.147. Yet, the first two points sound more to me like parts of a company’s overall safety culture peppered with a little energy management to the chef’s taste. Does this begin to explain why there might be some traces of uncertainty regarding “my requirements”? What is measureable about these two points vs compliance to 1910.147?
An OSHA/legal definition of de minimis and a clearer understanding of – What do employees need to know? will certainly help all companies unfold LOTO for full compliance.
INTEGRATED SAFETY COULD BE YOUR OPPORTUNITY – CONSIDER IT!
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Related articles:
Machine Safety and Lockout/Tagout
Machine Safety And Your Safety Culture
Updating Minds About Machine Guarding
Contact: www.jbtitus.com for “Solutions for Machine Safety”.
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