It may seem confusing because there are three different elements that need to be considered.

First, the program itself is supposed to be reviewed to make sure it is up to date and effective.  This includes things like the names of the right people, equipment designations are correct, etc.  The program should also be reviewed for effectiveness, but how this is accomplished can vary based on how the program is set up (review retained lockout documentation, observe lock out, etc)

Then we have the requirement that all equipment-specific procedures be reviewed annually for accuracy and completeness.  OSHA has been across the board on this one, but, in general, you have to take your equipment-specific procedures and check that they are still accurate and effective.  Things like changes of isolation devices, piping changes, new sources of energy or movement, should all be checked.  If the procedure hasn't been used for some time, you may want to conduct an actual lockout to confirm the effectiveness.  OSHA has also issued some alternatives for very large facilities, or facilities with highly complex unit (assembly lines) where individual review is impractical.

Third, you have employee training.  After the initial training has been provided, OSHA requires that authorized and affected employees be provided refresher training "whenever there is a change in job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.  Retraining is also required whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures."  OSHA has also provided guidance that training should be provided at least annually in order to meet the above requirements for authorized employees.

Call if you have questions.

Steven L Curtis  PE, CSP, CHMM
President
Curtis Management Resources, LLC
937-767-2117

----- Original Message ----- 
  From: Debra Kaelin 
  To: [log in to unmask] 
  Sent: Thursday, October 24, 2013 8:25 AM
  Subject: [SCCSC-L] Question


  Hello Everyone,

   

  This is so easy to use after I realized it is simply an e-mail to the address above.

   

  Another Question:

   

  I would like to know how other companies handle the requirement to annually evaluate the Lockout/Tagout programs at their companies. Do you re-authorize operators to LOTO for each specific piece of equipment or simply evaluate the LOTO instructions for each and consider them reviewed at that point? I have received conflicting information and as usual OSHA is very vague - deliberately so I think!

   

   

   

  Debra A. Kaelin

  Safety & Quality Systems Manager

  Ever-Roll Specialties Company

  3988 Lawrenceville Dr.

  Springfield, OH 45504

  937-964-1302

   



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