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Understand the basics on LOTO and injury prevention, best practices, and the pain points for OSHA compliance.Electrical, crushing and amputation injuries are often fatal and are classified as severe events that generally trigger an on-site OSHA inspection. Often the root cause of such incidents is a failure in the lockout/tagout (LOTO) process or training deficiencies. Violations of OSHA's general industry LOTO standard, 29 CFR 1910.147, are always among the Top 10 Cited Standards because of the numerous requirements and documentation mandates. In addition, for several categories of work, a LOTO permit to work (PTW) is required. This topic will address the basics on LOTO and injury prevention, best practices, and the pain points for OSHA compliance. The speaker will also address best practices for documenting the PTW and relevant national consensus standards, as well as provide a forecast of LOTO changes in enforcement or regulations that may be coming in the new administration.
AuthorsAdele L. Abrams, Esq., CMSP, Law Office of Adele L. Abrams P.C.
Overview of OSHA Lockout/Tagout (LOTO) Requirements
• Which Standards Apply (Construction Versus General Industry) and Why That Matters
• Why 29 CFR 1910.147 Is Always One of OSHA's Top 10 Cited Standards
• Differences Between Lockout and Tagout
• Eight Steps for Safe LOTO Programs
LOTO Permit to Work Programs
• Four Types of Permits to Work
• When Required
• Documentation: Electronic and Checklists
• Who Must Be Trained?
• What Must Be Covered?
• How Often Must Workers Be Trained, and What Documentation Is Required?
OSHA Enforcement Pain Points
• National Emphasis Program on Amputation Prevention
• What Aspects of the LOTO Rules Are Most Often Cited, and Why?
• Anticipated Changes in Rulemaking and Policy Under Biden Administration
Best Practices to Avoid Injuries and Citations
• Going Beyond Minimum Compliance
• Contractor Coordination
• Role of National Consensus Standards