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Workplace inspections

How can I perform effective periodic inspections to ensure compliance with OSHA’s standard on lockout/tagout (1910.147)?


Responding is Andy Phelan, CSP, senior safety consultant – lockout/tagout, Rockford Systems, Rockford, IL.

Performing periodic inspections, per 1910.147, is essential for maintaining workplace safety and compliance with OSHA regulations. These inspections serve as a proactive measure to identify and address potential hazards associated with the control of hazardous energy (lockout/tagout) systems. By conducting regular inspections, employers can ensure LOTO procedures are properly implemented, equipment is effectively maintained and employees are effectively trained.

Periodic inspections help to verify the integrity of energy control devices, assess the accuracy of written procedures and monitor compliance with regulatory requirements. Moreover, these inspections enable employers to identify and correct any deficiencies or noncompliance issues promptly, mitigating the risk of workplace incidents and any subsequent injuries and fatalities caused by the unexpected release of hazardous energy. Overall, periodic inspections are a core element of an effective energy control program, promoting a culture of continuous improvement and safeguarding the well-being of employees.

Establish inspection frequency. Determine the frequency of inspections based on the complexity of equipment, previous incidents, number of procedures and regulatory requirements. Typically, periodic inspections should be conducted at least annually, but high-risk equipment might require more frequent checks. Add periodic inspections to the preventive maintenance schedule for pieces of equipment.
Create detailed inspection checklists. Develop an inspection checklist tailored to the requirements of the standard on LOTO. The checklist should encompass all relevant aspects of LOTO procedures, including the proper application of LOTO devices, verification of energy isolation and employee knowledge of LOTO practices.
Train inspectors. Periodic inspections must be performed by authorized employees other than the ones using the procedure being inspected. Ensure your inspectors are effectively trained to conduct inspections. They should understand LOTO procedures, relevant regulations and internal company requirements, as well as have an understanding of the specific equipment being inspected. The information gathered from an inspection is only as good as the inspector who gathered it.
Document inspection findings. Document all inspection findings, including observations, deficiencies, corrective actions taken and recommendations for improvement. Maintain organized records to demonstrate compliance and facilitate follow-up actions.
Address identified issues promptly. Take prompt action to address any deficiencies or noncompliance identified during periodic inspections. This may involve revising procedures, providing additional training, or implementing corrective measures to mitigate risks and ensure employee safety.
Conduct a follow-up inspection. Follow-up to verify corrective actions have been implemented effectively and that compliance has been restored.

Periodic inspections serve as a proactive measure to identify and correct potential deficiencies in your LOTO program. By implementing a systematic approach to periodic inspections, you can effectively ensure compliance with OSHA’s standard on LOTO and enhance workplace safety for your employees.

Editor's note: This article represents the independent views of the author and should not be considered a National Safety Council endorsement.

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