Lawrence Halprin Authored the VPPPA Leader Magazine Article on Policies to Minimize the Potential for Adverse Incidents in a Site’s Hazardous Energy Control Program

Keller and Heckman Partner Lawrence Halprin authored the Voluntary Protection Programs Participants' Association’s (VPPPA) Autumn 2022 issue of the Leader Magazine article, “Going Beyond Traditional LOTO (Control of Hazardous Energy): Policies and Training to Minimize the Potential for Adverse Incidents,” published on November 22, 2022. The article examines how “despite many years of employer experience, and OSHA enforcement and outreach under these standards, the General Industry Machine Guarding and Lockout-Tagout (LOTO) Standards continue to be, year after year, two of the top ten most frequently cited OSHA standards.” Lawrence explains that many elements must be in place in order to run an effective program for the control of hazardous energy, including properly designed equipment, hiring employees committed to working safely, providing effective training and supervision, and providing employees with the necessary tools. Lawrence writes, “My experience is that most significant shortcomings in a site’s hazardous energy control program generally stem from inadequate personnel management practices and inadequate policies in the written energy control program, which fail to account for human behavior by both management and line personnel.” Lawrence outlines fundamental rules that should be followed in order to avoid injury and/or any other adverse incidents associate with hazardous energy sources.

This article is particularly timely in light of OSHA’s initiative to amend its LOTO Standard to formally recognize the expanded use of automated safety control systems to control hazardous energy sources[1] and the new OSHA Region V Local Emphasis Program for the Food Manufacturing Industry (10/3/2022),[2] which focuses on LOTO and Machine Guarding and directs OSHA CSHOs to consider 15 other potential hazards often associated with the food industry.

To read the full article, please click here.
 

[1] DOL/OSHA Lock-Out/Tag-Out Update. https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202204&RIN=1218-AD00
[2] https://www.osha.gov/sites/default/files/enforcement/directives/CPL_04-05-2202.pdf