Hello Everyone-

 I am writing a new policy and I have a few Lockout/Tagout questions I would like your opinions on;

1. Do I need to write a procedure for each 110V corded item or can I just do a blanket policy for all corded items? (ie corded drills, dremels)
2. Does the procedure have to be posted on a wall by the machinery or can I store them in a department binder?
3. Our forklifts are serviced by an outside contractor. Do I need to have a procedure in place?
4. OSHA says "Name(s)/Job Title(s) of affected employees and how to notify" must be called out. Do I really need to call out affected personnel by name or is title sufficient? 

Thanks in advance for help you can offer. Updating our LOTO program is turning into quite a project!

 

J,

1. The standard does not require LOTO procedures for cord and plug electric equipment. See 1910.147(a)(2)(iii).

2. As long as the procedure is accessible to the employee you're fine. However, I like to have the procedure with the equipment. It cuts down on the "I forgot" events.

3. Yes, but your procedure can state that you'll fall under the contractor's procedure for that particular task. See 1910.147(f)(2). Generally, work with contractors requires informing each other of the other procedures.

4. I'm not sure whether the Appendix is mandatory or non-mandatoy. You probably could get away with just titles or use the broad based "Area management and employees will be informed." I prefer the use signs, barrier tapes, and announcements. That way any affected or other personnel in the area or entering the area is automatically informed.

The good news is that if you do it thoroughly and correctly on the front end, the annual periodic reviews and procedure updates become a breeze.

MikeCJ

Thank you for your input. I tend to read a little too far into OSHA regs at times. The program hasn't been touched since 2001 so once I get everything cleaned up and updated, like you said, it should nice and easy ;) Thanks again!