SAFETY SOLUTIONS: Have You Conducted Your Periodic Lockout & Tagout Audit?
A periodic inspection of each energy control procedure must be performed at least annually to ensure that the energy control procedures continue to be implemented properly and that employees are familiar with their responsibilities under those procedures. The inspection must also ensure that the procedure is adequate to provide effective protection to the authorized employee during servicing and maintenance operations covered by this standard.

The employer is required to correct any deficiencies observed during the periodic inspection. Inadequacies in the energy control procedure could be the result of using a general procedure that does not effectively handle a specific application. They also may arise from changes made to equipment or processes without modifying the existing energy control procedure.

The periodic inspection must be performed by an authorized employee other than the one(s) who is using the energy control procedures. This individual will be referred to as the "inspector." The inspector must be able to determine:

• Whether the steps in the energy control procedure are being followed.
• Whether the employees involved know their responsibilities under the procedure.
• Whether the procedure provides the necessary protection, and what changes, if any, are needed.

The periodic inspection consists of two requirements. First, the inspector must observe a representative sample of authorized employees performing the servicing and maintenance operation using the lockout/tagout procedure. Second, the inspector must perform a review with each authorized employee of that employee's responsibilities under the energy control procedure being inspected. When the periodic inspection involves a tagout procedure, the inspector's review of responsibilities extends to the affected employees as well, because of the increased importance of their role in avoiding accidental or inadvertent activation of the equipment or machinery being serviced or maintained.

The employee performing the periodic inspection does not have to observe every authorized employee implementing the energy control procedure on the machine or equipment on which he or she is authorized to perform servicing and maintenance to meet the requirements of 29 CFR 1910.147 (c )(6)(i)(C) and 29 CFR 1910.147 (c)(6)(i)(D). The inspector participating in the review when lockout is used needs to:

• Observe a representative number of such employees while implementing the procedure, and
• Talk with all other authorized employee even though they may not be implementing the energy control procedure.

It is not required that the periodic inspection be conducted in separate one-on-one meetings; it can involve the inspector meeting simultaneously with a group of authorized employees. Group meetings can be one of the most effective methods to conduct the inspection and make clear to the employees that they need to follow the procedure carefully.

The employer must certify that a periodic inspection has been performed at least annually. The certification must include information on each of the following:

• The machine or equipment on which the energy control procedure was used.
• The date of the inspection.
• The employees included in the inspection.
• The name of the inspector who performed the inspection.

So as we near the end of this year, it is important that you review your lockout, tagout & tryout program and ensure that everyone has been educated in your procedures.

If you have any questions or concerns regarding your lockout & tagout procedures, contact me at jpodojil@podojilconsulting.com. I will be happy to help.

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