OSHA’s Lock-out/Tag-out (LOTO) standard remains one of its most cited safety rules. The regulations require that the employers develop written policies and implement procedures to deenergize machinery before maintenance or repair. On May 20, OSHA published a notice of its intent to seek information for the purpose of possibly updating the LOTO standard to take into account advances in closed circuit devices and robotics.

Under the current standard which was implemented in 1989, employers are not permitted to use closed circuit devices to isolate internal machine energy sources. In its announcement, OSHA indicates that advances in closed circuit technology merit revisiting this ban. OSHA also wants to collect general information on robotics advances, and how this machinery could present issues not addressed by the current LOTO standard.

In our experience, OSHA safety inspectors take inconsistent positions with regard to the need for individualized written LOTO policies for each machine, as opposed to collective policies for similar equipment. The new OSHA notice does not seek information on this point, but employers could make the need for individual policies part of their comments with regards to robotics. OSHA will accept public comments for 90 days.