It is a legal requirement placed upon the employer to ensure that regular inspections are in place that comprehensively cover an energy control program and ensure it is effective and being correctly enforced.
OSHA states under section (c)(6) of the Control of Hazardous Energy (lockout/tagout) – 1910.147 section (c)(6) that:
“The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”
In order to minimise the changes of negligence being skipped over, it is also a requirement for the procedure to be completed by a qualified third party outside of the people who use the energy source regularly.
OSHA states in section (c)(6)(i)(a):
“The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected.”
Section B also outlines how the periodic inspection is used to:
“Correct any deviations or inadequacies identified.”
Review
Under the periodic inspection a form of review is also used where the inspector talks to each employee, checks their responsibilities and references this against the current procedure and ensures that all responsibilities are being correctly enforced.
Under section (c)(6)(I)(C-D) this procedure is outlined for lockout:
“Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.”
And tagout:
“Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.
Certification
The employer also has the legal responsibility to ensure that certification is created that the periodic inspection has been performed, and this is defined by OSHA as:
“The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.”
In other words, it is important to make the review and inspection as rigorous as possible and to collect and maintain extensive documentation about the process in case of investigation by a group such as OSHA.
