The 2008 revisions to the LOTO Compliance Directive (CPL 02-00-147) did a great service in advancing a 30+ year-old standard in an area that badly needed clarification: Periodic Inspections under 1910.147(c)(6). I am sure there will be folks who will dissect this, looking for every “out” they can find to not do these safety-critical audits, but it’s hard to argue this section of the CPL is very well written and makes it perfectly clear, for those seeking true guidance, on how to perform these “inspections”.