ArticlesOSHRC decisions on Machine Specific LOTO Procedures, LOTO Periodic Inspections, and LOTO Training for Affected/Other employees
These LOTO decisions by the OSHRC are HUGE in establishing some "minimums" for LOTO procedures, periodic inspections, and training for "affected" and "other" employees. Readers should pay very close attention to the details that OSHA used in their arguments of how poorly "machine-specific procedures" were written (missing data, conflicting data, no magnitudes listed, etc.). The facility really wasted the court's time with their arguments (my professional opinion) as OSHA had their ducks in a row, AND the facility made it easy for OSHA... i.e., plenty of low-hanging fruit for OSHA to pick from within their LOTO program!!! Here are the LOTO decisions: NOTE: This case also involved a machine guarding decision that can be seen in the full decision. |
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