Due to the significant risks associated with inadequate energy control procedures and the failure to properly implement effective energy control procedures, section 1910.147(c)(6)(i) REQUIRES that periodic inspections be performed AT LEAST ANNUALLY (based on twelve-month intervals) to VERIFY that
- the procedures are adequate and
- they are being properly applied
OSHA believes that these periodic inspections will, in part, ensure that the employees involved with LOTO are familiar with their responsibilities and that they maintain proficiency in the energy control procedures they implement.
NOTE: OSHA allows energy control procedures that are used less frequently than once a year (based on a twelve-month interval) to be inspected only when used.
These periodic inspections MUST contain at least two (2) components:
- an inspection of EACH energy control procedure, and
- a review of EACH employee’s responsibilities under the energy control procedure being inspected.
EACH energy control procedure required by §1910.147(c)(4) MUST be separately inspected to ensure that the energy control procedure is adequate and is PROPERLY implemented by the authorized employee(s) in accordance with the LOTO standard.