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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