When it comes to workplace safety, Lockout/Tagout (LOTO) procedures play a crucial role in preventing hazardous energy accidents. But how often should employers inspect their equipment to ensure compliance with OSHA regulations?
According to OSHA’s 1910.147 standard, employers must conduct a periodic inspection of energy control procedures at least annually to ensure compliance and safety. However, there’s more to it than just checking a box once a year. Let’s break it down in a way that’s easy to understand and apply.
Annual Inspection: What OSHA Requires
OSHA’s regulation 1910.147(c)(6)(i) mandates that employers conduct at least one periodic inspection per year for each energy control procedure. This inspection ensures that the procedures are being followed correctly and that employees are using them effectively.
Here’s what the annual LOTO inspection must include:
✅ An independent review – The inspection must be performed by an authorized employee who is not currently using the procedure being inspected (1910.147(c)(6)(i)(A)).
✅ Correction of deficiencies – If any deviations or inadequacies are found in the process, they must be corrected immediately (1910.147(c)(6)(i)(B)).
✅ Employee review of responsibilities – When lockout procedures are used, each authorized employee must review their role in the process with the inspector (1910.147(c)(6)(i)(C)).
✅ Additional review for tagout systems – If tagout procedures are used instead of physical lockouts, both authorized and affected employees must be included in the review (1910.147(c)(6)(i)(D)).
✅ Certification of completion – The employer must document the inspection with details such as:
- The machine/equipment inspected
- The date of inspection
- The employees involved
- The inspector’s name (1910.147(c)(6)(ii))
Key Takeaway: If you’re managing workplace safety, you need to schedule at least one LOTO inspection per year for each machine with an energy control procedure.
What About Employee Training?
While OSHA does not require annual retraining, training must be conducted under specific circumstances. This ensures that employees remain proficient in LOTO procedures and understand any updates to safety protocols.
Retraining is required when:
🔹 A periodic inspection reveals deviations in how employees apply energy control procedures (1910.147(c)(7)(iii)).
🔹 An employer believes an employee lacks knowledge or is not following procedures correctly.
🔹 Changes occur in job assignments – If an employee takes on a new role that involves LOTO procedures, they must be retrained.
🔹 New energy control procedures are introduced – If the process for controlling hazardous energy changes, employees must be retrained.
🔹 New machinery, equipment, or processes introduce new hazards – Any updates to workplace equipment or processes that could affect LOTO procedures require updated training.
Key Takeaway: While OSHA doesn’t set a fixed retraining schedule, employees must be retrained when changes or deficiencies are identified. Proper training ensures the effectiveness of your energy control program.
Why Does This Matter?
Failing to properly inspect and enforce LOTO procedures can lead to serious injuries or fatalities. OSHA’s Control of Hazardous Energy (Lockout/Tagout) standard consistently ranks among the Top 10 most cited violations every year.
By conducting annual inspections, ensuring proper documentation, and training employees when needed, companies can reduce the risk of accidents, avoid costly fines, and maintain a safe working environment.
✅ One annual inspection isn’t just a requirement—it’s a safeguard for your team.
✅ Training should be ongoing to maintain proficiency and safety awareness.
✅ LOTO compliance isn’t just about rules; it’s about protecting lives.
If you’re responsible for workplace safety, make sure your LOTO inspections and training are up to OSHA standards. Don’t just do the bare minimum—create a culture of safety where employees understand the why behind energy control procedures.
Stay proactive, stay compliant, and most importantly—stay safe!
Call us at 303-537-5832 for Lockout/Tagout training!
