In the last installment of this LOTO series, we address the periodic inspections and training requirements.   

Are We Performing Periodic Inspections?

Employers are required to conduct periodic inspections of their energy control procedures at least annually to ensure that they are being effectively implemented and to correct any deviations or inadequacies. 29 C.F.R. § 1910.147(c)(6). The periodic inspection must be performed by an “authorized employee” other than the one(s) utilizing the procedures being inspected.

The periodic inspection shall include a review between the inspector and each authorized employee of that employee’s responsibilities under the energy control procedures and of the limitations of the tagout systems, if used, as provided for in 29 C.F.R. § 1910.147(c)(7)(ii).

The employer is required to certify that that the periodic inspections were performed. The certification shall identify (1) the machine or equipment on which the energy control procedure was being utilized; (2) the date of the inspection; (3) the employees included in the inspection; and (4)the person performing the inspection.

Are We Performing Required Training?

Employers are required to provide training to all employees on the LOTO Program and certify that employee training has been accomplished. 29 C.F.R. § 1910.147(c)(7). The type of necessary training will depend upon the employee’s relationship to the Program:

  • Each authorized employee must receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. 29 C.F.R. § 1910.147(c)(7)(i)(A).
  • Each affected employee must receive training in the purpose and use of the energy control procedure. 29 C.F.R. § 1910.147(c)(7)(i)(B).
  • All other employees whose work operations are or may be in an area where energy control procedures may be utilized, must receiving training about the LOTO procedure and the prohibition relating to attempts to restart or reenergize machines or equipment which are locked out or tagged out. 29 C.F.R. § 1910.147(c)(7)(i)(C).

If a tagout system is being used, all employees must be trained on the following limitations of tags: (1) Tags are essentially warning devices affixed to energy isolating devices, and do not provide the physical restraint on those devices that is provided by a lock; (2) When a tag is attached to an energy isolating means, it is not to be removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated; (3) Tags must be legible and understandable by all authorized employees, affected employees, and all other employees whose work operations are or may be in the area, in order to be effective; (4) Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace; (5) Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall energy control program; and (6) Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use. 29 C.F.R. § 1910.147(c)(7)(ii).

Are We Performing Retraining When Necessary?

All authorized and affected employees must receiving retraining whenever there is a change in their job assignments, a change in the machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures. 29 C.F.R. § 1910.147(c)(7)(iii)(A). 

Additional retraining must be conducted whenever a periodic inspection reveals, or whenever the employer has reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures. 29 C.F.R. § 1910.147(c)(7)(iii)(B).

Are Only Authorized Employees Performing Servicing or Maintenance Activities?

Employers must ensure that LOTO procedures are performed only by the authorized employees who may perform servicing or maintenance activities. 29 C.F.R. § 1910.147(c)(8).

Are Affected Employees Notified of the Application and Removal of LOTO devices?

Employers must ensure that all affected employees are notified of the application and removal of lockout devices or tagout devices. 29 C.F.R. § 1910.147(c)(9). Notification must be given before the controls are applied, and after they are removed from the machine or equipment.

By asking and answering these questions about your LOTO program, you can evaluate the effectiveness of the program and address any deficiencies before OSHA shows up at your door.