Employers must develop and document procedures to control hazardous energy whenever employees perform activities covered by the lockout/tagout standard. These procedures give the authorized employee written instructions on how to eliminate the potential for the unexpected activation, start up, or the release of stored energy.
At least annually, a periodic inspection must be performed by an authorized employee other than the one who is using the procedures. This individual is referred to as the inspector. The inspector must be able to determine whether:
The employer must correct any problems identified during the periodic inspection. Problems might be the result of using a general procedure that does not handle a specific application, or from changes to equipment or processes that were not added to the procedure. (Note that if an energy control procedure is not used every year, it may be inspected each time it gets used.)
The inspector needs to observe a representative sample of authorized employees performing the servicing and maintenance using the lockout/tagout procedure. The inspector must also review each authorized employee’s responsibilities, and talk with all other authorized employees even though they may not be using the energy control procedure.
When the periodic inspection involves a tagout procedure, the inspector’s review must extend to affected employees as well, because of their role in avoiding accidental or inadvertent activation of the equipment or machinery.
The periodic inspection need not be conducted in one-on-one meetings; the inspector can meet with a group of authorized employees. Group meetings could be even more effective in communicating the need to follow the procedure carefully.
The employer must certify that a periodic inspection has been performed. The certification must include information on:
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 employees' knowledge or use of the energy control procedure.
In addition to the inspections required by OSHA, employers should consider regular inspections of other workplace areas and procedures. The Audits area of J. J. Keller® SAFETY MANAGEMENT SUITE has 100+ inspection checklists to help you evaluate your safety status. Topics cover everything from accident prevention to warehousing.