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Now that you have considered whether you are covered under the LOTO standard, it is time to consider whether you actually meet the basic requirements of the standards and have proper energy control procedures for each piece of equipment. 

Do We Meet the Basic Requirements under the LOTO Standard?

If employees are exposed to hazardous energy during servicing and maintenance activities and one of the exceptions above do not apply, then employers must establish, at a minimum, a program consisting of detailed energy control procedures for each piece of equipment, employee training, and periodic inspections.  29 C.F.R. § 1910.147(c)(1).

Do We Need and Have Detailed Energy Control Procedures?

Energy control procedures for each piece of equipment must be developed, documented, and utilized when employees are engaged in servicing and maintenance activities unless all of the following elements exist:Continue Reading Part 2: Will Your LOTO Program Stand Up to an OSHA Inspection?

It seems that just about every week the Occupational Safety and Health Administration (“OSHA”) issues citations to another employer for its alleged failure to implement the requirements under the Control of Hazardous Energy standard, 29 C.F.R. § 1910.147 (better known as the Lockout/Tagout (“LOTO”) standard).  In fact, the LOTO standard has consistently been one of the top ten frequently cited standards issued by OSHA over the last several years.  Small or unsophisticated employers are not the only ones at risk for receiving citations for LOTO issues.  So, as spring approaches (eventually), it is a good time to do a little bit of “spring cleaning” with respect to your LOTO Program to ensure that if OSHA shows up at your worksite, you can feel confident that your program meets the necessary requirements and you have significantly reduced your risk for receiving a citation. 

Over the next few days, we will address some of the key questions you can be asking while evaluating your LOTO program.   
Continue Reading Part 1: Will Your LOTO Program Stand Up to an OSHA Inspection?

On February 11, 2014, OSHA issued a long awaited Shipyard Employment “Tool Bag” Directive (CPL 02-00-156).  While the Directive provides compliance guidance to Compliance Safety & Health Officers (CSHO) for inspections of shipyard employers, it also provides guidance to covered employers.  The Directive is a source of information on how OSHA interprets various requirements and…

The comment period ends on March 10, 2014, for OSHA’s request for information (“RFI”) on the potential revisions to its Process Safety Management (“PSM”) standard, Explosives and Blasting Agents standard, the Flammable Liquids standard, and Spray Finishing standard.  This RFI fulfills one of the Agency’s requirements under President Obama’s Executive Order 13650, entitled Improving Chemical Facility Safety and Security. 

OSHA identified the following topics as potential candidates for rulemaking or enforcement policy changes and included a list of questions specific to each:

1.  Clarifying the PSM exemption for atmospheric storage tanks.  OSHA seeks comments on whether it should clarify that the PSM standard covers all stored flammables when connected to, or in close proximity to, a process.

2.  Oil- and Gas-Well Drilling and Servicing Exemption.  OSHA requests public comment on whether it should retain or remove the current Oil and Gas Well Drilling and Servicing exemption from the PSM standard.Continue Reading OSHA’s Comment Period Ends Soon for PSM RFI

Over the last several years, Federal OSHA has become increasingly active with “policing” state approved plans – states that develop and operate their own job safety and health programs.  Recently, Cal/OSHA has come under fire for how it classifies a repeat citation.

Currently, Cal/OSHA classifies a repeat violation as

a violation where the employer has…

In addition to proposing a three-year extension to the operator certification requirements under the final cranes and derricks in construction standard, 1926 – Subpart CC, OSHA further extended the temporary enforcement policy memorandum regarding the use of proximity alarms and insulating links on cranes and derricks operating near power lines.

OSHA’s final standard for cranes…

The latest issue of our weekly Workplace Safety and Health newsletter is available for viewing and contains the following articles:

  • OSHA Issues Guidance for Inspectors on Combustible Dust. OSHA inspectors must consider a manufacturer’s or importer’s use of information gained from actual explosion events, lab testing, published data on similar materials or particle size to

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The latest issue of our weekly Workplace Safety and Health newsletter is available for viewing and contains the following articles:

  • Federal Agencies Report Progress on Chemical Safety.  Agencies responsible for tightening chemical safety rules and procedures following a deadly explosion at a fertilizer plant last year say they are making headway.
  • OSHA Claims Trucking Firm

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