709  A Critique of the Federal Lockout/Tagout Compliance Directive

Year after year, the federal Lockout/Tagout (LOTO) standard, 29 C.F.R. § 1910.147, is one of the top-ten most frequently cited standards. On February 11, 2008, the Occupational Safety and Health Administration finally issued the long-awaited LOTO compliance directive, CPL 02-00-147. The LOTO compliance directive is over one hundred pages in length and instructs OSHA enforcement personnel on the agency’s interpretation of the LOTO standard and the agency’s procedures for enforcing the LOTO standard. This session will critique the OSHA interpretations and the procedures for enforcing the LOTO standard.

Instructors: Michael T. Taylor, J.D., Arent Fox LLP, Washington, DC

Level: I A