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?