OSHA says employers must conduct periodic inspections of LOTO procedures but what does that really mean? What kind of inspections are good enough and what are the best practices?
OSHA General Industry Standard 1910.147(c)(6) covers period inspections of energy control procedures for organizations and companies that require lockout/tagout procedures for their operations. This standard says the following:
The employer must conduct inspections of the LOTO procedures at least once a year.
The inspection must be performed by an authorized employee OTHER THAN the ones using the LOTO procedure being inspected.
The purpose of the inspection is to correct any deficiencies with the LOTO procedure.
When LOTO is used for energy control, the authorized inspector must also review every employee who uses the LOTO procedure. This review is to cover the employee’s LOTO responsibilities. This review should also extend to “affected employees” to cover their responsibilities as well.
The employer must confirm that periodic inspections have been performed by identifying and documenting, at minimum, for every inspection: 1) the machine or equipment, 2) the date of the inspection, 3) the employees included in the inspection, and 4) the inspector.
While this standard seems pretty straightforward, if your organization has more than a few LOTO procedures in place, then putting together a LOTO inspection process can seem daunting.
OSHA has put together compliance directive CPL 02-00-147 to help provide direction to organizations regarding the standards that apply to control of hazardous energy, but the document is 136 pages long and no light reading.
A compliance directive is a document written by OSHA to inform their OSHA Compliance Officers on what to look for during an inspection of a workplace. Consultants and employers can review these documents to gain insight into what OSHA looks for so that they can better interpret how to comply with the regulation.
To read the full Compliance Directive on The Control of Hazardous Energy – Enforcement Policy & Inspection Procedures, click here: CPL 02-00-147.
Periodic Inspection is covered in section XVII on page 3-65 of the document (page 115 out of 136). To help organizations and companies understand exactly what is required for annual LOTO inspections, please see the highlights below.
Disclaimer: Refer to OSHA standards for further clarification on hazardous energy requirements. Weeklysafety.com will not be held liable for any incident. This article is meant to provide information only, and is not a substitute for safety consultation. Read Weeklysafety.com’s full disclaimer.
LOTO = Lockout/Tagout Procedure = Energy Control Procedure
If your company or organization has LOTO procedures in place, or if any LOTO is ever used, then OSHA requires inspections on your procedure at least once every 12 months.
The purpose of the inspection(s) is to ensure that the LOTO procedures in place are adequate, and if they are not, then corrections must be made.
Note: If you have any LOTO procedures that are used less than once a year, then you only need to inspect that procedure when used. For example, if maintenance is required every 3 years on a machine and LOTO is required to perform the maintenance, then perform the inspection at the same time as the maintenance and document the inspection.
Every LOTO inspection must include:
An inspection of the procedure
A review of every employee’s responsibilities as it pertains to the procedure
Each procedure that the organization has in place must be inspected separately, but they do not all need to be inspected at the same time.
CLARIFICATION: A single procedure may include more than one machine or equipment. For example, if a plant has several machines that are similar and utilize the same or similar types of control measures, then one inspection on one LOTO procedure on one machine may be adequate for the annual inspection. For more clarification on this approach and how best to inspect a representative number of employees implementing one procedure within each group, please review page 3-66 of CPL 02-00-147 (page 116 of 136). There is quite a lot of detail provided on this issue to help organizations ensure they are providing adequate inspections without having to inspect every single machine.
The person who is tasked with completing the LOTO procedure review inspections must be a competent person authorized to complete such inspections. This person must be someone who has previously used the LOTO procedure being inspected or currently uses the LOTO procedure being inspected.
IMPORTANT: The inspector can NOT be the same person using the LOTO procedure during the inspection. Clarification: There must be at least two competent, authorized persons present during any LOTO inspection. One is the inspector and the second is the authorized person following the LOTO procedure.
There are many ways to complete the LOTO inspections including scheduled audits, unplanned surprise audits, plant safety tours, planned visual observations, etc.
The goal of every LOTO inspection is to determine these three things:
The steps of the current LOTO procedure are being followed
The employees involved know their responsibilities as they pertain to the procedure
The procedure is adequate to provide necessary protection OR what modifications are required if the procedure is deemed inadequate
IMPORTANT: For step 2, it is important to also review the employees who are not directly responsible for conducting the LOTO procedure but may be in the vicinity. All employees must know what LOTO means and what they should do if they encounter LOTO devices or signs while on the job.
If no deficiencies are found during the inspection (meaning the LOTO procedure is being followed, the employees demonstrate they are aware of their responsibilities, and the procedure provides necessary protection) then no employee re-training is required as a result of the inspection. However, if the inspection did reveal any deficiencies, then re-training is required as part of the corrective action.
Finally, these LOTO inspections must be documented. The inspection records must include the unique identifier of the machine or equipment, the date of the inspection, the name(s) of any employees included in the inspection, and the name of the inspector.
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