Lockout/tagout annual periodic inspection: how to do it and certify it
1910.147(c)(6) requires an employer to inspect each energy control procedure at least once a year to make sure the procedure and the standard are being followed. It's one of the easiest requirements to miss, because nothing breaks when it doesn't happen. Then an inspector asks for the certifications.
Who can perform it
An authorized employee other than the ones using the procedure being inspected. A maintenance tech who doesn't normally service the packaging line can inspect the packaging-line procedure, for example. The inspector must know the procedure well enough to spot deviations.
What the inspection involves
- Pick the procedure and the machine.
- Watch authorized employees carry out the procedure, or walk through it with them at the machine.
- Check the written procedure against the real equipment: every energy source listed, isolation points where the procedure says, devices still the same.
- For lockout, review each authorized employee's responsibilities under the procedure with them. Where tagout is used, the review also covers affected employees and the limitations of tags.
- Correct any deviations or inadequacies, and update the procedure or retrain as needed.
What the certification must include
The standard requires a certification that the periodic inspection was done. It must identify:
- the machine or equipment the procedure was used on,
- the date of the inspection,
- the employees included in the inspection, and
- the person performing the inspection.
A practical form adds a short observation checklist (notification, shutdown, isolation, lock application, stored energy, verification, lock removal) and a space for deviations and corrective action. LotoSmith pre-fills one of these per procedure, with the machine, procedure number, revision and energy sources.
Making it routine
- Put each procedure's next review date on the placard and in an equipment register so the yearly cycle is visible.
- Spread inspections across the year instead of cramming them into one week.
- Use the inspection to re-issue any placard whose machine has changed, with a new revision number.
- File the certifications with the written program so they're in one place when someone asks.
Frequently asked questions
How often is a lockout/tagout periodic inspection required?
At least annually for each energy control procedure, under 29 CFR 1910.147(c)(6)(i).
Can the person who uses the procedure inspect it?
No. The inspection must be performed by an authorized employee other than the ones utilizing the energy control procedure being inspected.
What records do I need to keep?
A certification for each inspection identifying the machine or equipment, the date, the employees included and the person who performed it.
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This guide summarizes 29 CFR 1910.147 for general information. It is not legal advice. Read the standard itself, and check any state-plan or provincial rules that apply to you.