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What to Do When LOTO is Not Feasible

FDR Safety

I’m finding clients who have excellent lockout/tagout programs but who have not taken the necessary step of identifying tasks where LOTO is not feasible. Your only recourse is to prove LOTO is not feasible. Document why power is needed and LOTO is not feasible. These are tasks that call for further analysis and action.

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Assessing Feasibility

FDR Safety

The answers can be determined but only after documented due diligence using Task Based Risk Assessment (past blogs) and assessing feasibility of hazard controls. You must have a documented risk assessment, documentation of why LOTO is not feasible and validation that the controls in lieu of LOTO achieve acceptable risk.

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Feasibility For Machine Guarding Is A Big Deal For Employers and Employees

FDR Safety

Finding safeguards for a specific task is challenging because a physical guard may not be feasible. OSHA AND FEASIBILITY The OSH Act is the relevant law, and OSHA standards are the relevant regulations for most employers and employees in the United States. A feasibility assessment usually takes less than an hour.

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Auto Draft

FDR Safety

Finding safeguards for a specific task is challenging because a physical guard may not be feasible. OSHA AND FEASIBILITY The OSH Act is the relevant law, and OSHA standards are the relevant regulations for most employers and employees in the United States. A feasibility assessment usually takes less than an hour.

Drafting 156
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Are You Ready For An OSHA Audit?

FDR Safety

We use risk assessment and feasible risk reduction methodology that is part of the ANSI B11 family of general industry machine safety standards. Without risk assessment and documentation of why the guard must be bypassed and a documented alternative method that achieves acceptable risk, you are ripe for OSHA citations.

OSHA 149
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The Complexity Of OSHA’s PSM Standard

FDR Safety

Using accepted ANSI standards, we are able to make use risk assessment, feasible risk reduction using the hazard control hierarchy and acceptable risk to solve real-world problems. When deciding that risk mitigation is needed, the concept of feasibility comes into play to demonstrate due diligence in complying with the OSH Act.

Risk 223
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OSHA citing maintenance equipment violations despite low risk

FDR Safety

A properly documented risk assessment may not prevent OSHA violations, but should, and will, help mitigate the violation classification and attendant penalty. Document your findings. If not, estimate weight and stability and document your findings. For things like anchoring machines, try to move or tip them.

OSHA 153