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Course 710 - Energy Control Program (Lockout/Tagout)

Safety guides and audits to make your job as a safety professional easier

Periodic Inspection

Evaluating Written Energy-Control Procedures

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An authorized employee who does not perform LOTO on the equipment, should inspect and evaluate the LOTO procedure.

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.

Either the employer or the inspector must document each inspection with the information listed below.

  • equipment on which the procedure is used
  • date of the inspection
  • workers included in the inspection
  • 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.

1. If your authorized employee(s) perform all of the lockout/tagout procedures, who may perform the lockout/tagout procedure inspections?

a. A supervisor who is also an authorized employee and does not perform the procedures
b. Any supervisor in operations who is not performing lockout/tagout procedures
c. Only the lockout/tagout leader performing the specific procedures
d. Any member of the group of authorized employees performing the procedures

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The Purpose of Periodic Inspections

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Inspect lockout/tagout procedures to make sure they work.

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

  1. workers are following the written procedure and
  2. the procedure is correct.

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.

2. What is listed as one of the purposes of periodic inspections?

a. Keep workers safe
b. Workers are following procedures
c. Reduce OSHA fines
d. Keep upper management happy

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Periodic Inspection Requirements

loto1
An authorized employee who does not perform LOTO on the equipment, should inspect and evaluate the LOTO procedure.

As we mentioned earlier, an authorized employee who is not involved in the energy control procedure should inspect the area on an annual basis. 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.

3. How often should an employee who is not involved in the energy control procedure inspect the area?

a. Annually
b. Weekly
c. Monthly
d. Daily

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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 OSHA violations listed below:

  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

Video

First Day on the Job was the Last

Ninety minutes into his first day on the first job of his life, Day Davis was called over to help at Palletizer No. 4 at the Bacardi bottling plant in Jacksonville, FL. What happened next is an all-too-common story for temp workers working in blue-collar industries. Watch this ProPublica video.

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