36 PalletCentral • May-June 2019 palletcentral.com
standard." OSHA's response was based on the
fact that if a control circuit device such as a
motor starter fails, the failure could cause
the actual three-phase wires feeding
electricity to the motor, coils, armature,
and other related circuits to become
energized.
Similarly, in a January 25, 2008
LOI, OSHA stated that reliance on a
"programmable logic controller" (PLC) as a
means to isolate hazardous energy "is prohibited
by the LOTO standard and, as a result, is presumed
to be ineffective employee protection from injuries
resulting from hazards such as component failure, program errors,
magnetic field interference, electrical surges, and improper use or
maintenance."
However, both OSHA's preamble and its various pertinent LOI's
recognize the role that circuit control devices play in safeguarding
employees performing routine adjustments to, and clearing of,
equipment. More specifically, OSHA stated in a July 23, 2003 LOI:
SAFETY
What is Lockout/Tagout
Lockout-tagout (LOTO) is a
safety procedure used in industry
settings to ensure that equipment
is properly shut off and not able to
be started up again prior to the
completion of maintenance or repair
work. The LOTO standard requires
employers to develop and use
standardized procedures for the control of
potentially hazardous energy (e.g. electrical,
pneumatic, steam, chemical, gravity, etc.) during
servicing and maintenance of machines or equipment.
A sample LOTO program may be downloaded from
OSHA's website: http://bit.ly/2WG1BfU.
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