Page 48 - IEC Insights May-June21_PAGES

FEATURE
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Missing and/or Inadequate
Misunderstanding (or Forgetting)
Machine-Specific Procedures
Employers must also conduct periodic inspections
The most frequently cited violation of the LOTO Periodic Inspections
standard is missing and/or inadequate machine- of each energy control procedure to avoid a citation
specific LOTO procedures (MSPs) under 1910.147(c) under 1910.147(c)(6). These inspections must be
(4). To pass muster, MSPs must be written in performed at least annually.
sufficient detail for servicing employees to be able to:
• shut down, isolate, block, secure, or relieve energy; To satisfy the standard, a periodic inspection must:
• identify specific steps for placement and removal of • Be performed by an authorized employee,
lockout devices; and but not by the employee using the procedure
being inspected.
• understand the specific steps he or she must take
to test and verify that the equipment is in a zero- • Include a review, between the inspector and the
energy state. authorized employee, of the responsibilities under
the procedure.
The real challenge seems to be ensuring LOTO • Be certified in a record that identifies the machine
procedures are machine-specific. Employers may, for which the procedure was reviewed, the date of
however, develop a single MSP for a group of similar the inspection, the employees included, and the
machines that have the same hazardous energy person performing the inspection.
source(s) and the same or very similar methods for • Ensure any deficiencies or deviations are corrected.
controlling that energy. If employers are using one
procedure for a group of machines, they should The individual conducting the inspection must
consider an inset or note in the MSP that highlights observe a representative number of employees’
any unique aspects for each piece of equipment. implementation of the energy control procedures
and discuss the procedures with the employees
If a contractor performs tasks covered by LOTO, implementing them. The designated inspector must
both the contractor and host must inform each other also talk with each LOTO authorized employee—even
of their respective LOTO procedures. But if a host those not implementing the procedure during the
employer never services its equipment in-house, the inspection. Relying on a group meeting where energy
host need not develop its own machine-specific LOTO control procedures are reviewed will not suffice
procedures. The host employer must, however, ensure unless actual implementation of the procedure is
its employees understand and comply with the inspected in real time. Employers can inspect groups
restrictions of a third party’s LOTO program. of procedures provided the employer performs a
case-by-case assessment to determine whether the
procedures can be effectively inspected as a group.

Employers should keep in mind that if they have
procedures that are used less than once per year,
those should be inspected each time they are used.

Relying on a group meeting where energy
control procedures are reviewed will not

suffice unless actual implementation of the
procedure is inspected in real time.

46 Insights Magazine | May/June 2021 | www.ieci.org