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This material is for training purposes only. Its purpose is to inform employers and workers and workers of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.
MODULE 4: PERIODIC INSPECTIONS

Evaluating written energy-control procedures

An evaluation of lockout/tagout procedures is required annually and must be conducted by an authorized employee other than the person who performs the procedures. If your authorized employee(s) perform all of the lockout/tagout procedures, you might have to have a supervisor designated as an authorized employee. The supervisor can then conduct the evaluation of lockout/tagout procedures.

The purpose of the inspection is to determine that workers are following the written procedure and that the procedure is correct. Either the employer or the inspector must document each inspection with the following information:
  1. The equipment on which the procedure is used.
  2. The date of the inspection.
  3. The workers included in the inspection.
  4. The person who did the inspection.
If an inspector finds that workers are not following an energy-control procedure or that the procedure is not protecting them, those workers must be retrained and the procedural deficiencies corrected.

The authorized employee who does the inspection must understand the procedure and must not be among those following the procedure at the time of the inspection. Each procedure must be verified for its accuracy, completeness and effectiveness in energy control.

The purpose of periodic inspections

The purpose of periodic inspections is to ensure that the energy control procedures continue to be implemented properly, that the workers are familiar with their responsibilities, and that any deviations or procedural inadequacies that are observed are corrected.

Reviewing a lockout/tagout procedure

If the inspection covers a procedure for equipment with an energy-isolating device that can be locked out, the inspector should review the procedure with the workers who use it to service the equipment and affected employees who operate the equipment. The inspector can review the procedure with the workers individually or in a group.

How often must the inspection take place?

At least annually.

Who performs the periodic inspection?

An authorized employee not involved in the energy control procedure being inspected.

What does the periodic inspection entail?

The employer must identify any deficiencies or deviations and correct them.

Where lockout is used, the inspector must review each authorized employee's responsibilities under the procedure with that employee (group meetings are acceptable).

Where tagout is used, the inspector must review both the authorized and affected employee's responsibilities with those workers for the energy control procedure being inspected, and the additional training responsibilities.

Hazardous energy in the workplace: a recent accident

The son of the owner of a commercial drywall construction company, an employee of the company, was preparing an aerial lift for a job and had replaced two battery terminals. He had raised the aerial boom and was reaching toward the battery compartment across the metal enclosure that houses the lift's toggle controls when the boom dropped and pinned him to the control panel. His father discovered him and summoned emergency responders but he died at the site.

Investigation findings
  1. The lift's emergency valve, hydraulic hoses and fittings, and electrical wiring were inspected after the accident and were not defective; however, the on/off key switch had been bypassed so that the operator could use the toggle switches without using the key.
  2. The battery charging system was missing a fuse that would stop the system from charging and the spring-loaded toggle switches that controlled the boom did not have guards to prevent accidental contact.
  3. The employee did not use lockout procedures while he was working on the lift and did not block the boom to prevent it from dropping.
  4. The owner had not reviewed the lift's instruction manual with the victim or other company employees.
  5. Although the company had more than 10 employees, it did not have a safety committee.
The accident resulted in the following OSHA violations:

  1. The employer failed to ensure that employees did not remove or tamper with required safety devices.
  2. The employer did not develop, document, and require employees to use lockout procedures to control hazardous energy during maintenance work.
  3. The employer had more than 10 employees but did not have a safety committee.(Oregon requirement)
Source: Oregon OSHA

GO TO MODULE 4 QUIZ Remember to take each module quiz! The final exam questions are derived directly from the module quizzes.

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