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Information on LOTO

March 15, 2021

Wayne asks: Is there any site online where I can get any further information on LOTO as it pertains to clearing jam ups in the corrugated box industry?

Doug answers:

The “clearing of jam ups” in the corrugated industry will forever be a debated topic, as there are many variables.  As a rule of thumb, JKJ’s Risk Control Consultants send the message that the clearing of jam ups requires lockout/tagout, as it is required by OSHA more often than not.  See the first link below for OSHA’s overall stance.  For the corrugated and printing industries, jam ups are non-stop and a part of everyday business.  Handling these situations need to be thought of from a safety standpoint first and then from a compliance standpoint.

Too many companies make a blanket statement that the clearing of jam ups is considered minor servicing (see 3rd link below) and is excluded from LOTO.  While some clearing tasks may be considered minor servicing, others may involve significant danger (see 2nd link below).

If jam ups routinely occur at a particular piece of equipment or on a specific line, the task of clearing the jam should be fully analyzed to determine if it meets the minor servicing exemption.  If so, it is essential that an alternate means of protection be determined, as stated in the interpretation letter (4th link below).  Although not required, it is recommended that that the assessment and alternate means be documented.

https://www.osha.gov/dts/osta/lototraining/hottopics/ht-relche-1-4.html (Normal Production vs. Minor Servicing)

https://www.osha.gov/news/newsreleases/region5/05042016-0 (Clearing Jam Accident)

https://www.osha.gov/dts/osta/lototraining/hottopics/ht-relche-1-2.html (LOTO Minor Servicing Exemption)

https://www.osha.gov/laws-regs/standardinterpretations/2003-06-11 (OSHA Interpretation Letter)

https://jkj.com/blog/risk-control-quick-tips-volume-2/(JKJ Risk Control Quick Tip)

 

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