Both 1910.178 and 1910.147 have requirements that we periodically evaluate employees’ performance in their ability to perform LOTO and drive PITs in the manner in which they were trained. As I have discussed many times, just doing annual LOTO training without some type of “field verification” that the authorized employees are functioning within the program’s confines is NOT acceptable. Heck, we are NOT even required to do annual LOTO training – but most businesses do because the program is so critical; however, this annual training does NOT absolve the facility from doing their “periodic inspections”. The same goes with the 3-year “Evaluation” found in 1910.178- just doing the training every three (3) years does NOT absolve the facility from doing an actual evaluation on trained PIT operators. Let’s discuss…