ESC Compliance in California – Lockout/Tagout in California (CA)

ESC services all locations in California. California has a state run OSHA program and ESC specializes in customizing your lockout/tagout procedures to not only exceed California lockout/tagout regulations, but also to meet your satisfaction as the most efficient and easy to follow procedure possible. We will bring your company into compliance with our lockout/tagout services in California.

Contact ESC today for a quote to help your workplace become compliant and visually instructive.

About the California State Plan

The State of California, under an agreement with OSHA, operates an occupational safety and health program in accordance with Section 18 of the Occupational Safety and Health Act of 1970. Initial approval of the California State Plan was published on May 1, 1973, and certification for completing all developmental steps was received on August 19, 1977.

The Department of Industrial Relations administers the California Occupational Safety and Health Program, commonly referred to as Cal/OSHA. The Division of Occupational Safety and Health (DOSH) is the principal executor of the plan which oversees enforcement and consultation.

In addition, the program has an independent Standards Board responsible for the promulgation of state safety and health standards and the review of variances, an Appeals Board to adjudicate contested citations, and the Division of Labor Standards Enforcement to investigate complaints alleging discriminatory retaliation in the workplace.

Cal-OSHA versus Federal OSHA

Other states, like California, have managed their programs very well. Cal- OSHA has spent years developing lockout/tagout regulations and applied changes to their state program requiring elements that only are mentioned in letters of interpretation and federal directives, not the federal regulation itself. The most recent changes to California’s lockout/tagout regulation came Jan. 6, 2005, when Cal-OSHA simplified its ability to issue citations and instituted changes that helped employers fully understand the requirements.

A good way to understand the differences between federal and state OSHA is to look at how California has adapted and changed their version of the lockout/ tagout regulation. Cal-OSHA Title 8 Section 3314 (Cal-OSHA reference to lockout/tagout) differs from the federal standard in these ways:

  • Cal-OSHA clearly states that employers must have written, machine specific lockout/tagout procedures. (Reference Title 8 Section 3314(g).)The stated intent is to disallow “generic or boiler-plate” programs and procedures. The federal regulation 1910.147 doesn’t mention machine-specific procedures (although it’s the intent), so some companies have been led to believe that they are not required. Federal OSHA released a directive in February 2008 that addresses machine-specific as the minimum requirement and allows federal OSHA agents to more easily issue citations when machine-specific procedures are not present or adequate.
  • Cal-OSHA clarifies that you cannot use interlocks as lockout. The federal standard doesn’t allow interlocks as equivalent lockout protection either, but isn’t as clear, which leads to some companies trying to utilized a “softlock” or PLC lockout for convenience. This is not in compliance with federal OSHA or any state-run OSHA.
  • Cal-OSHA more clearly defines the exception for use of lockout/tagout when performing “minor, routine and repetitive maintenance” in parts T8 S3314 3-(f). The federal standard offers vague definitions of what is minor, routine and repetitive, which some say does not give employers enough guidance, causing them to inadvertently break the law.

Cal-OSHA allows for personally identifiable locks to be used alone, rather than with a lock and a tag. The federal standard allows for this through letters of interpretation, but this is not as clearly defined and can lead to confusion during a federal OSHA audit.

Click here to learn about Cal OSHA’s lockout/tagout program called: Title 8 Section 3314.