We are all familiar with OSHA’s LOTO Periodic Inspection requirements (1910.147(c)(6)). It is a topic of great debate, still in the Year 2023. But there is a serious, I say it is a fatal flaw in the periodic inspection process. It is common for this activity to be performed by managers/supervisors who are authorized in the LOTO program and have direct supervision of the employees they are responsible for. Most of our programs have a form we use to document these inspections, so managers and supervisors are conditioned to go out and find active LOTOs so they can conduct their “inspections.” This simplification of the process is how this flaw is created.
So what is this fatal flaw in the OSHA inspection process?
The inspection process conditions managers to identify active LOTO’s so they can perform their inspection(s). What they are NOT looking for is the PROPER APPLICATION of the LOTO when it is needed.
A safety pro should not be able to take a “side-walk tour” of a VPP Star facility and come across four (4) different activities involving over a dozen host employees and contractors where the work undoubtedly required LOTO, and yet no LOTO was in place. When we got back to the office area, management was really frustrated by what we found, and they immediately went to see if these workers had gotten their periodic inspection in the past 12 months. They all had been inspected within the 12 months, so I could see the confusion and frustration on their faces, and I just asked… do you all ever go out and audit/inspect the APPLICATION of LOTO? The looks on the safety team (a very young team) was like they won the lottery.
They were so focused on the “periodic inspections” and making sure they were all done that they had created blinders for managers to look for active LOTOs to perform their inspections and get “credit” towards their safety goals. What they were missing was an effort to identify what we found in a 3-hour side-walk tour.
They were doing their inspections PROPERLY, as 100% compliant with 1910.147 and there lies the flaw with the OSHA process. We need to be looking for DEVIATIONS in our application of LOTO as well as the PROPER EXECUTION when LOTO is utilized. OSHA’s inspection requirement does the latter, but NOT the proper application.