Answer Library / Lockout/Tagout

What does the annual lockout/tagout 'periodic inspection' actually have to include?

Quick answer

At least once a year, an inspection of each energy control procedure to ensure the procedure and the standard are being followed (29 CFR 1910.147(c)(6)(i)). It must be done by an authorized employee other than the ones using the procedure being inspected ((c)(6)(i)(A)), must correct any deviations found ((c)(6)(i)(B)), and must include a review with each authorized employee of their responsibilities under that procedure — and with affected employees too where tagout is used ((c)(6)(i)(C)–(D)). The employer certifies it: machine, date, employees included, inspector (29 CFR 1910.147(c)(6)(ii)).

"We do annual LOTO training" is the most common answer to this question, and it is an answer to a different question. The periodic inspection is an audit of each procedure in use, not a classroom session.

The requirement. The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of the standard are being followed (29 CFR 1910.147(c)(6)(i)). The unit of inspection is the procedure — so a plant with forty machine-specific procedures has forty inspections to document, though procedures that are the same can be grouped.

Who and how. The inspection must be performed by an authorized employee other than the one(s) utilizing the procedure being inspected (29 CFR 1910.147(c)(6)(i)(A)), and must be conducted to correct any deviations or inadequacies identified ((c)(6)(i)(B)). Where lockout is used, it must include a review, between the inspector and each authorized employee, of that employee's responsibilities under the procedure ((c)(6)(i)(C)); where tagout is used, the review extends to each authorized and affected employee and to the tagout limitations in (c)(7)(ii) ((c)(6)(i)(D)).

The paper. The employer must certify that the periodic inspections have been performed; the certification identifies the machine or equipment, the date, the employees included, and the person performing the inspection (29 CFR 1910.147(c)(6)(ii)). Training certification is a separate record with each employee's name and training dates (29 CFR 1910.147(c)(7)(iv)); the two are routinely confused.

An inspector who asks for "your LOTO periodic inspections" wants a stack of certifications naming machines. A training sign-in sheet will not satisfy the request.

29 CFR 1910.147(c)(6)(i)29 CFR 1910.147(c)(6)(i)(A)29 CFR 1910.147(c)(6)(i)(B)29 CFR 1910.147(c)(6)(i)(C)29 CFR 1910.147(c)(6)(i)(D)29 CFR 1910.147(c)(6)(ii)29 CFR 1910.147(c)(7)(iv)
Source: An analysis from the control of hazardous energy standard, 29 CFR 1910.147. Primary reference: read it on osha.gov →

Federal rule shown. If the workplace is in one of the 29 State Plan states and territories, the state standard governs and may differ — see Known Limitations.

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