NWRA Comments on Proposed Lock-Out/Tag-Out Rule

NWRA Comments on Proposed Lock-Out/Tag-Out Rule

Proposed Rule Would Not Increase Workplace Safety and Existing Rules Should Remain

Arlington, VA – The National Waste & Recycling Association (NWRA) commented on the request for information from the Occupational Safety and Health Administration (OSHA) to understand the strengths and limitations of new technology.

“Our members believe that using existing LOTO methods are the safest and most effective tools to reduce this type of risk. Our facilities implement LOTO several times per day and the simple process of flipping the breaker for a machine, locking it out, tagging it out and the testing to ensure that it has been de-energized and depleted of stored energy is the best method. If complicated electronic devices are introduced into the system, it could cause confusion and additional risk, especially if the equipment has had serious maintenance or an overhaul,” said NWRA President and CEO Darrell Smith.

Safety is a top concern of NWRA and its member companies. The Association does not believe these devices would be beneficial or at least as effective as current devices.


The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and a variety of other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association