What to Do When LOTO is Not Feasible

I’m finding clients who have excellent lockout/tagout programs but who have not taken the necessary step of identifying tasks where LOTO is not feasible. When you ask the right questions, you will typically find some number of service and maintenance tasks where the task must be done with power.  These are tasks that call for further analysis and action.

Most employers recognize that tasks which are routine, repetitive and integral to production qualify for the Minor Servicing Exemption to 29 CFR 1910.147, Control of Hazardous Energy, commonly referred to as LOTO.  These tasks, along with testing and positioning, are not topics of this blog.

The OSH Review Commission has ruled that tasks like set-up of a machine are not part of production; hence LOTO is required. During my career in engineering and safety, I have observed thousands of machine setups and other tasks where LOTO is simply not possible. In the case of set-up, if you argue the Minor Servicing Exemption, you will lose the compliance argument. It matters not that your procedure meets the test for acceptable risk and that power is essential. From a compliance standpoint, OSHA can cite you.

Your only recourse is to prove LOTO is not feasible. If you ignore set-up, cleaning, adjusting, or other service and maintenance jobs that require power believing that workers are magically complying with LOTO, you are waiting for a potentially serious injury to occur with resulting OSHA citation.

I recommend the following:

• Meet with experienced operators and mechanics and explain that you recognize that LOTO may be impossible for certain tasks.  Ask non-traditional questions such as:
  • “What job is your biggest pain?”
  • “Which jobs have to be done with guards off and power on for some part of the task?”
  • “If you owned the factory and money wasn’t an object, which job would you redesign?”
• Review the tasks and perform Task Based Risk Assessment.
• Document why power is needed and LOTO is not feasible
• Determine if guarding per CFR 1910.212 is feasible to prevent exposure to the hazard. If not, then,
  • Gain input from workers to improve use of the lower order of controls from the Hazard Control Hierarchy. Improving awareness, administrative controls (procedures, training, point of use instruction, etc.) and PPE will typically reduce the probability of occurrence and reduce the risk level.
• Develop appropriate alternative methods to LOTO that provide acceptable risk for the task and validate that method with experienced employees. Assure that instruction is near the point of use and clearly visible for anyone performing the task

Don’t ignore the real world of risk facing your workers — proactively identify the issues they encounter when lockout is not feasible.