Lockout/Tagout Periodic Inspections

OSHA’s Top 10 most cited violations has been recently published. Lockout/Tagout (LOTO) made the list as Number 6. Of the top 5 section cited, 1910.147(c)(6) periodic inspections was number 3 with 336 violations.

The specific section of the LOTO standard we are referring to in this letter is paragraph 1910.147(c)(6)(i), which requires employers to “conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed”.

Many people misinterpret the meaning of this paragraph and perform their periodic inspections in ways that don’t meet the intent. For clarification, reference should be made to OSHA’s compliance directive (CPL 02-00-147, effective 2/11/08) that explains their enforcement policy and inspection procedures used by compliance officers to evaluate an employer’s Control of Hazardous Energy (LOTO) program.

In section XVII of this compliance directive, the first periodic inspection component, states that each energy control procedure required by §1910.147(c)(4) must be separately inspected annually to ensure that the energy control procedure is adequate and is being properly implemented by the authorized employee in accordance with the LOTO standard.

For a company that has hundreds of machines and equipment, this can be an overwhelming task to complete annually. However, in OSHA compliance directive, the employer may group together machine and equipment that have the same or similar types of control measures. For purposes of procedure grouping, machines and equipment may be grouped together as one procedure if they all are listed or identified in the scope of the energy control procedure and if they all have the same or similar:

1. Procedural steps for shutting down, isolating, blocking, securing, and dissipating stored energy in machines or equipment;

2. Procedural steps for the placement, removal, and transfer of the lockout or tagout devices and the responsibility for them; and

3. Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures.

A review of each employee’s responsibilities under the procedure, in accordance with §§ 1910.147(c)(6)(i)(C) and (D), is the second periodic inspection component. When lockout is used, the employer’s inspection must include a review of the responsibilities of each authorized employee implementing the procedure with that employee. When tagout is used, the employer must conduct this review with each affected and authorized employee.

Periodic inspection must be certified as complete in accordance with §1910.147(c)(6)(ii). The certification must specify:

1. the machine or equipment on which the energy control procedure was used;

2. the date of the inspection;

3. the names of the employee(s) included in the inspection;

4. the name(s) of the person(s) who performed the inspection.

Hygieneering can assist in performing and documenting lockout/tagout periodic inspections on an annual basis for your company. If you are interesting in learning more about the lockout / tagout services we provide, please click on this link: Lockout/Tagout or contact Kevin Konkey at kkonkey@hygieneering.com or 630-706-6681.