Chemical Processes, LOTO, and three (3) program buckets (Simple, Traditional, Complex)
Way back in April 2016, the OSHRC published a decision that settled the argument about LOTO procedures for "specific equipment/machines" and what they must contain. This important decision helped settle a lot of scuttlebutt about how LOTO gets managed in "complex" situations. I like to explain to clients that LOTO in a chemical process is managed differently than how it is managed at a traditional manufacturing facility. I put LOTO into three (3) buckets: 1) Simple LOTO 2) Traditional LOTO 3) Complex LOTO Using 29 CFR 1910.147 as our road-map we can clearly see how these three (3) buckets play out. 1) Simple LOTO |
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