We often encounter an organization that conducts LOTO training annually. They do this because they believe OSHA requires annual LOTO training. However, the standard, 1910.147, does NOT require annual training! The standard requires each authorized employee to be “inspected” annually. If they fail that inspection, the standard requires the authorized employee to be re-trained.
OSHA does not accept annual training over annual inspections. We can do both, but we must do the inspections annually.
1910.147(c)(6) Periodic inspection.
1910.147(c)(6)(i) 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.
1910.147(c)(6)(i)(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.
1910.147(c)(6)(i)(B) The periodic inspection shall be conducted to correct any deviations or inadequacies identified.
1910.147(c)(6)(i)(C) 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.
1910.147(c)(6)(i)(D) 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.
1910.147(c)(6)(ii) 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.
1910.147(c)(7)(iii) Employee retraining.
1910.147(c)(7)(iii)(A) Retraining shall be provided for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.
1910.147(c)(7)(iii)(B) Additional retraining shall also be conducted whenever a periodic inspection under paragraph (c)(6) of this section reveals, or whenever the employer has reason to believe, that there are deviations from or inadequacies in the employee's knowledge or use of the energy control procedures.
1910.147(c)(7)(iii)(C) The retraining shall reestablish employee proficiency and introduce new or revised control methods and procedures, as necessary.
1910.147(c)(7)(iv) The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training.