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SAFETY SOLUTIONS: Have You Conducted Your Periodic Lockout & Tagout Audit?
A periodic inspection of each energy control procedure
must be performed at least annually to
ensure that the energy control procedures continue
to be implemented properly and that employees are
familiar with their
responsibilities
under
those procedures.
The
inspection
must also
ensure
that the
procedure is adequate to provide effective protection to
the authorized employee during servicing and maintenance
operations covered by this standard.
The employer is required to correct any deficiencies
observed during the periodic inspection. Inadequacies in
the energy control procedure could be the result of using
a general procedure that does not effectively handle a
specific application. They also may arise from changes
made to equipment or processes without modifying the
existing energy control procedure.
The periodic inspection must be performed by an
authorized employee other than the one(s) who is using
the energy control procedures. This individual will be
referred to as the "inspector." The inspector must be able
to determine:
- Whether the steps in the energy control procedure are
being followed.
- Whether the employees involved know their responsibilities
under the procedure.
- Whether the procedure provides the necessary protection,
and what changes, if any, are needed.
The periodic inspection consists of two requirements.
First, the inspector must observe a representative sample
of authorized employees performing the servicing and
maintenance operation using the lockout/tagout procedure.
Second, the inspector must perform a review with
each authorized employee of that employee's responsibilities
under the energy control procedure being inspected.
When the periodic inspection involves a tagout procedure,
the inspector's review of responsibilities extends to the
affected employees as well, because of the increased
importance of their role in avoiding accidental or inadvertent
activation of the equipment or machinery being serviced
or maintained.
The employee performing the periodic inspection does
not have to observe every authorized employee implementing
the energy control procedure on the machine or
equipment on which he or she is authorized to perform
servicing and maintenance to meet the requirements of
29 CFR 1910.147 (c )(6)(i)(C) and 29 CFR 1910.147
(c)(6)(i)(D). The inspector participating in the review when
lockout is used needs to:
- Observe a representative number of such employees
while implementing the procedure, and
- Talk with all other authorized employee even though
they may not be implementing the energy control procedure.
It is not required that the periodic inspection be conducted
in separate one-on-one meetings; it can involve the
inspector meeting simultaneously with a group of authorized
employees. Group meetings can be one of the most
effective methods to conduct the inspection and make
clear to the employees that they need to follow the procedure
carefully.
The employer must certify that a periodic inspection has
been performed at least annually. The certification must
include information on each of the following:
- The machine or equipment on which the energy control
procedure was used.
- The date of the inspection.
- The employees included in the inspection.
- The name of the inspector who performed the
inspection.
So as we near the end of this year, it is important that
you review your lockout, tagout & tryout program and
ensure that everyone has been educated in your procedures.
If you have any questions or concerns regarding your
lockout & tagout procedures, contact me at
jpodojil@podojilconsulting.com. I will be happy to help.
For more information, click on the author biography at the top of the page.
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