OSHA 30/30 - April 30, 2014

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The U.S. Court of Appeals held hearings recently on an OSHA citation issued against a contractor for failure to exchange lockout/tagout information with the host employer.  This case is particularly interesting because the inspection arose out of an injury incurred by the contractor’s employee – and because none of the host employees had access to the alleged.  In this program, we will cover:

• The basic LOTO requirements that were the subject of this citation;
• The contractor’s arguments in defending against this citation;
• OSHA’s enforcement position involving the duty to exchange LOTO information;
• OSHA’s enforcement position on whether employee exposure to a hazard is a necessary element in alleging a violation of a standard.

Case: Otis Elevator Co. v. Secretary of Labor