OSHA Citation Case Study
Date First Published on SafetySmart Compliance: March 6th, 2012
What this employer did wrong and how to avoid making the same LOTO mistakes yourself.
Who Got Cited: A snack food plant in Cold Water, Ohio was fined $112,000, including $70,000 for 2 willful LOTO violations.
What Triggered the Inspection: OSHA got a complaint that a worker was hurt while servicing a machine because his clothes got snagged in a conveyor belt.
What the Employer Did Wrong: It committed 2 violations of Sec. 1910.147(c)(4)(i) of the LOTO standard by letting employees perform 2 operations without a machine-specific LOTO procedure for controlling hazardous energy during maintenance and servicing of dangerous machines and equipment:
- Servicing of the conveyor system in the plant packaging area; and
- Cleaning of the topical auger in the seasoning area.
Basic Grain Products Inc., No. 12-70-CHI, (Reg. 5), Feb. 22, 2012
How You Can Avoid the Same Violations: There are 2 things you must do to avoid LOTO violations like the ones to Basic Grain:
- 1. Determine which machine/equipment service or maintenance operations at your workplace are covered by the LOTO standard (click here for an overview of the standard you can use to do your assessment); and
- For each covered operation, establish an Energy Control Plan(click on the link for a Model Plan you can adapt) that includes:
- Energy control procedures; (click on the link for model procedures you can adapt)
- Appropriate LOTO devices; (click on the link for a tagout devices checklist)
- Periodic inspections of energy control procedures; (click on the link to find out how to conduct appropriate inspections; click here for a Model Energy Control Inspection form you can adapt)
- Train employees on your energy control procedures (click on the link to access LOTO Safety Talks you can use to provide training to your employees; click here to find out how to document and verify the effectiveness of LOTO training)