donnelley's efforts didn't fall short, the employee failed to follow procedure. There is a difference.

Did Donnelley "ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative." The obvious answer is no, therefore they were not in compliance with the standard.

All operators of equipment are provided LO/TO training and the training records are available. That this person opted to either by-pass or omit, intentionally or otherwise, is not the fault of the company.

I'd be very surprised if RRD isn't fined. I've worked as a health and safety professional for years and have been through OSHA inspections. OSHA will not only be looking at paper work. They will also be looking at RRD's efforts to enforce lockout/tagout. If RRD can demonstrate that it has a zero tolerance policy for violations of lockout/tagout by providing examples of disciplinary action against employees, they might avoid a fine. OSHA is not blind to that fact that many companies develop procedures, provide training but don't enforce the use of lockout/tagout procedures. The goal of a lockout/tagout program is to "ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative." The goal is not to have a training document for each employee and written procedures.

The goal of a speed limit is to force people to drive at a safe speed. Everyone knows that driving faster than the limit is illegal, but few follow it knowing that the odds of being caught are slim. The same thinking is often used in manufacturing. They know that the LO/TO rules are in place and enforceable, but by-pass them for expedience until they're either caught or injured. As the other poster who also works for Donnelley has said, everyone needs to be responsible for their own safety. If you choose to ignore the rules and an accident occurs you have no one to blame but yourself.