Running the Annual Lockout Inspection

Every energy control procedure has to be inspected at least once a year under 29 CFR 1910.147(c)(6). This is the one part of the lockout program that catches slow drift: steps that got skipped, a machine that changed, a crew that learned a shortcut. Many plants treat it as a signature on a form. That misses the point, and it also fails the rule, because the inspection has to happen while real work is going on. This is for authorized employees, leads and safety staff who are asked to do these inspections. The details come from the standard and from OSHA's enforcement directive, CPL 02-00-147. State plans may be stricter, and your employer's program sets the form you use.

What You Will Be Able to Do

• Say who can inspect, and what makes an inspection valid.
• Group similar procedures and plan a year of inspections.
• Watch a lockout and ask the questions that show whether it is working.
• Carry out the review of each worker's responsibilities.
• Act on what you find, and fill out the certification.

What the Inspection Has to Do

It has two parts, and both are required.

1. Inspect the procedure. Is it being followed? Is it good enough to protect people?
2. Review responsibilities. Do the workers using it know their duties under it?

The inspector needs to answer three questions by the end:

• Are the steps in the procedure being followed?
• Do the employees involved know their responsibilities?
• Is the procedure adequate, and if not, what has to change?

Who Can Inspect

The inspector must be an authorized employee who is not using the procedure being inspected. They can be someone who has used that procedure in the past, or who uses it at other times. They just cannot do any part of it during the inspection. A supervisor counts only if they are an authorized employee for this work.

You cannot inspect yourself, even if you are the most experienced person in the building. You also need to know the work. Someone who has never run a lockout on that kind of equipment will not spot what is missing.

When It Happens

At least once a year means within each 12-month period. The date counts. If the last inspection of a procedure was March 3, the next is due by March 3, not "sometime next year."

Three details that people miss:

• Procedures used less than once a year need to be inspected only when they are used, such as a lockout for a major overhaul done every few years.
• Machines under the written procedure exception still get inspected. The exception covers the writing, not the inspection.
• Live work is required. OSHA says the inspection must include a demonstration of the procedure, and must take place while authorized employees are really doing servicing or maintenance. A desk review does not count. Neither does asking someone to describe what they would do.

The inspection can happen as a planned observation, a random audit or part of a plant safety tour.

Grouping Procedures

If each machine has its own procedure, the workload can look huge. OSHA lets employers group procedures for inspection, if the machines in the group have the same or similar types of control measures. The group then counts as one procedure for inspection.

You can then inspect a representative number of workers using one procedure in each group, as long as the sample fairly reflects how the plant really does this work. Two rules go with that:

• Rotate. OSHA says employers should consider picking different procedures from the group each year, so that each one eventually gets inspected.
• Go where the risk is. It may be justified to look more often at procedures that have had problems, or at jobs with a lot of workers.

If a sample turns up a problem with a procedure, you have to fix it for every procedure in the group, not just the one you watched.

Worked example: A food plant has 46 machine-specific procedures and 38 authorized employees. It sorts the procedures into 7 groups by energy type and control steps.

1. Total inspections: 2 + 2 + 2 + 2 + 1 + 1 + 1 = 11 a year, about one a month.
2. At 2 a year, the 14 conveyor procedures take 7 years to get through. If that feels too long, or the group has a history of problems, raise it to 3 or 4.
3. Spread them across crews and shifts, so that night shift is in the sample too.

The rule sets no fixed sample size. The number has to be enough to show how the work is really being done, so be ready to explain your choice. Your employer's program may set a minimum.

Watch the Work

Schedule the inspection around a real job. Bring the current written procedure, and do not coach. Your job is to see what happens when you are only an observer.

Compare what you see against the paper line by line. The gap can run in either direction. The crew may be skipping a step. Or the crew may be doing something smart that the procedure does not say, because the machine has changed. Both are findings.

Warning: If you see someone in danger, stop the work. Finishing a clean observation is never worth it. Fix the hazard first, then record it.

Review Each Worker's Responsibilities

The second part of the inspection is a review between the inspector and the workers.

Tagout needs the wider review because a tag only works if people read it and obey it.

The inspector does not have to watch every single authorized employee. Watching and talking with a representative number is acceptable. But the review still has to reach all the authorized employees reasonably expected to use that procedure during the year. Group meetings are often the best way to do this.

Maintenance staff who work all over a plant are a special case. You may not know in advance which procedures they will use. Before they service a machine, they must have reviewed the inspection results for it, or for its group. An annual safety meeting or a pre-shutdown briefing can do that.

When an inspection finds nothing wrong, a short review is fine. When it finds a problem, the review has to go deeper, and the fix has to reach everyone affected.

Acting on What You Find

The rule requires that deviations and inadequacies be corrected. Sort each finding.

Under 1910.147(c)(7)(iii), retraining is required whenever an inspection shows gaps in a worker's knowledge or use of the procedure, or shows that the procedure itself has a problem.

Ask why before you write someone up. If a whole crew skips a step, the step may be impossible, unclear or badly placed. You will learn more by asking "Why did you do it that way?" than by quoting the rule. The aim is safe machines, and workers tell you more when they do not expect to be punished for being honest.

Set a date and an owner for each fix, and check that it happened. A finding that stays on a list protects nobody.

Certifying It

The employer has to certify that the inspection was done. The certification must show:

1. The machine or equipment the procedure was used on.
2. The date of the inspection.
3. The employees included in the inspection.
4. The person who did the inspection.

Worked example:

Add your findings and fixes to your own records. They are not on the required list, but they are the most useful part. Keep this separate from training records, which must show each worker's name and the dates of training.

Records that raise questions include a form with no employee names, a signature from someone who was using the procedure, a date more than 12 months after the last inspection, and identical forms for every machine, which suggest nobody watched anything.

Common Mistakes

Check Your Understanding

1. A lead mechanic used a procedure last month. Can she inspect a coworker using the same procedure today?

Yes, if she is an authorized employee and takes no part in carrying out the procedure during the inspection.

2. A plant has 10 near-identical packaging lines with the same control steps. Must it inspect all 10 each year?

Not necessarily. They can be grouped and sampled, if the sample fairly reflects the work. It should rotate which lines it picks. If it finds a problem, it fixes the problem for all 10.

3. A safety manager reads each procedure at his desk in January and signs a form. Has he done the inspection?

No. The inspection has to involve watching the procedure being used on real work, and reviewing duties with the workers.

4. A machine uses tagout because its old valve cannot take a lock. Who must be part of the review?

Each authorized employee and each affected employee who works with it.

5. You watch a crew use a valve that is not in the written procedure, because a new line went in last year. What are the next steps?

The procedure is inadequate. Revise it, then retrain the workers who use it, and check the other procedures in the group for the same gap.

Key Takeaways

• Each procedure is inspected at least every 12 months, by an authorized employee who is not using it.
• It has to be done on live work, not at a desk.
• Similar procedures can be grouped and sampled if the sample is fair, and the picks should rotate.
• The review covers authorized employees for lockout, and adds affected employees for tagout.
• Fix what you find, for the whole group, and retrain anyone with a gap.
• The certification shows the machine, the date, the employees and the inspector.