When Can a Company Be OSHA §3362 Compliant Yet Still Experience Injuries?

Even with strict adherence to OSHA §3362, which mandates that all machinery and equipment be properly locked out and tagged out during maintenance, companies can still face workplace injuries. Why? Because compliance is just the baseline; it's the starting point, not the finish line.

Human Error: Despite having robust Lockout/Tagout (LOTO) procedures in place, human error remains a significant factor. Employees might forget to follow the LOTO steps correctly or might rush the process, leading to accidents. I've seen firsthand how even well-trained staff can overlook a critical step when under pressure.

Insufficient Training

Compliance with §3362 requires training, but the depth and frequency of that training can vary widely. A company might meet the bare minimum requirements but fail to provide ongoing or in-depth training. This gap can leave employees unprepared for real-world scenarios, where machinery and situations can be unpredictable.

Equipment and Environmental Factors

Even with perfect LOTO procedures, unexpected equipment failures or environmental hazards can still pose risks. For instance, a sudden power surge could bypass a lockout, or an unnoticed spill could create a slippery surface. These are factors that compliance alone cannot fully mitigate.

Culture and Communication

A safety culture that encourages open communication and continuous improvement is crucial. If employees feel hesitant to report near-misses or safety concerns, issues that could lead to injuries might go unaddressed. We've worked with companies where fostering a more proactive safety dialogue significantly reduced injury rates, even though their compliance levels remained unchanged.

Based on available research, individual results may vary, but integrating a strong safety culture with compliance can enhance safety outcomes. For those looking to deepen their understanding, the OSHA website offers extensive resources on LOTO and other safety standards.