Recently, I spent some time with a new (and unlisted) client who experienced a severe LOTO accident, resulting in a severe injury to an employee. I was asked to review their programs and practices related to the control of hazardous energy (e.g., LOTO). Everything looked good until we got to the “periodic inspection” requirement. As is the case most of the time, the employer had training records for all their employees – but there is a catch!
The employer was using computer-based training modules consisting of PowerPoint presentations that students read and progressed through at their own pace. There was no voice-over in the training, so it was 100% read on your own, and you could progress at your own pace. They had annual training records for their employees for the past 12 years, and the CBT started 11 years ago. So the last time this employee received any face-to-face training was 11 years ago.
However, the facility had no records of any “periodic inspections” for any authorized employees! The company attorney was adamant that periodic inspections would be unnecessary if the facility had annual training. This is a MISUNDERSTANDING by many attorneys and safety professionals. It is the EXACT OPPOSITE…
Training is NOT required annually, but periodic inspections ARE REQUIRED ANNUALLY.
There continues to be a debate within OSHA about whether every authorized employee must be inspected yearly. Still, there is unanimous agreement that some form of periodic inspection must be conducted annually.
It is my position that EACH authorized employee must be “inspected” annually, and the rest of this article will be my attempt to convince others to adopt this position.