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March 2018 | VehicleServicePros.com 29
J.J. Keller & Associates (jjkeller.com) is a
source for workplace safety, transportation,
construction and human resources products
and services.
It is essential that the training program help
to ensure that employees understand all applicable
energy sources, methods of isolating and/
or controlling those energy sources and methods
to verify eff ective energy control.
“Employee retraining may
be necessary from time to
time,” Smithers points out.
Examples are when a fl eet
identifi es defi ciencies in existing
procedures and makes a
change, or when technicians
take on new tasks or begin
working on new machinery,
as would be the case if a
new vehicle type were added
to a fl eet or brought in to be
serviced.
Procedural defi ciencies are
normally identifi ed during
annual inspection.
“You have to visually
observe an employee
performing the lockout/
tagout procedures,” Smithers
explains. “Th en you discuss
the fi ndings with all employees
who would be following
that procedure.”
Get it in writing
As is the case with most
rules and regulations, there
are provisions with respect
to OSHA’s hazardous energy
control standard. Other
things fl eets may need to
consider are shift /personnel
changes and the use of outside
contractors. A workplace is a
unique environment, so an
energy control program will
be unique to each company’s
operations.
It is important for a company’s
procedures to be in writing.
It is also important to note
there should be several procedures
documented. Individual
procedures should be developed
for each type of “job”
a technician might do. Th is
could result in several written
LOTO procedures for a single
vehicle or piece of equipment.
Minimum elements of a
written energy control procedure
include:
A specifi c statement of
the intended use of the
procedures
Specifi c steps for shutting
down, isolating, blocking
and securing vehicles and
equipment
Specifi c steps for the placement, removal and
transfer of LOTO devices
Specifi c requirements for testing a vehicle or
piece of equipment to verify the eff ectiveness
of LOTO devices and other control measures.
OSHA says a written procedure doesn’t need to
be overly complicated. It just needs to be specifi c
and thorough. OSHA off ers various publications
and tools to help managers develop a sound LOTO
program for their organization, including free
on-site consultations.
On that note, an insurance company may also
be willing to send a representative out to assess
hazards in your shop. Additionally, organizations
such as J.J. Keller provide consultative services.
In other words, fl eets have help if needed. When
it comes to something as important as LOTO, do
not be afraid to ask.
For more information on our Gold Line Quality Parts®
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