In 2009, OSHA’s regulation 1910.147 made the top 10 most cited list for the 15th year in a row.

It’s currently the number one most cited regulation in the manufacturing industry, but when manufacturers are cited, they often times are surprised. They thought they were compliant.

According to OSHA, in 2009 one of the most common areas of citations was lack of machine specific procedures. It’s been 20 years since the regulation was implemented in 1989, so why is it still such a big issue?

When we talk to companies in our LOTO training seminars, we often times hear the same response: “We didn’t fully understand what it took to comply with lockout-tagout.”

Too often, companies over-simplify their approach and create only LOTO procedures for their main production equipment and think that all the other equipment is exempt for some reason. Some equipment may be exempt from requiring a machine specific LOTO procedure, but not as many as you might think.

Here’s the foundation for the one area in the lockout-tagout regulation that causes so much confusion and as such leads to many cases of non-compliance:

The reason this part of the regulation is misunderstood so often is that companies see this as a list of possibilities, when really it’s a list of limitations. A piece of equipment doesn’t just have to meet one of the criteria to be exempt, it must meet all eight. Many times, I hear: “If it’s cord and plug, it doesn’t need a procedure, right?” Wrong. It must meet all eight criteria, not just number two.

What Equipment Needs a Procedure?

Most companies know that their large, complex production equipment needs a machine specific lockout-tagout procedure, but fail to recognize the outlying equipment. Here’s a list of commonly overlooked equipment that OSHA can and will issue citations for if they do not have a machine specific procedure readily available: The above are only a few of the commonly overlooked items, and they do need procedures. Without them, exposure can be up to $70,000 per piece of equipment that doesn’t have a procedure. That can quickly add up when you look around your facility.

How Do You Fix It?

The best way to fix this problem is to first understand how big your problem is. Take each piece of equipment and run it through all eight criteria. If it doesn’t meet just one of the criteria then assume it needs a machine specific lockout-tagout procedure.

The easier way to do this is to assume that all your equipment needs a LOTO procedure. Take that list and prioritize it by most complex and most serviced equipment to least complex and least serviced. In our experience, over 95 percent of the equipment in a facility will need a LOTO procedure.

By just creating procedures for everything you will save yourself the hassle of trying to locate that rare 5 percent and know that it’s easier to maintain your program because you can easily see deficiencies: If it doesn’t have a procedure, it needs one.

General Verses Specific

Don’t fall into the trap of writing a generic LOTO procedure to cover many pieces of equipment. OSHA does not like to see this used because it can easily lead to confusion, which can easily lead to accidents. Make each procedure unique for each piece of equipment. That way when the equipment changes or gets replaced you’ll just have to update its individual procedure and not worry about how you’re going to adapt a generic procedure to accommodate the new changes.

The good news is that there is help. Using an outside company to implement your program makes the most sense for many companies because they don’t have the resources to implement it, but they might have the resources to maintain it. When you look for a company to outsource to, make sure they give you all the source files (not just .pdf) so you can make changes in house when you need to.

Also, make sure you receive the files in a format that is guaranteed to be accessible for years in the future. Using any sort of proprietary software can leave you stranded should that software ever become incompatible in the future. We recommend using a MS Excel based format because it’s proven, stable, free, easy to use, and pretty much guaranteed to be future proof. FSM Jimi Michalscheck is VP project management for ESC Services, Inc. www.esc services.com, jrm@escservices.com.“Your Safety, Our Passion!”