Tips for Conducting an Annual Lockout/Tagout Audit

By Jonathan Roskopf, Safety Services Team Lead, Rockwell Automation

Companies required to follow lockout/tagout (LOTO) procedures outlined by OSHA standard 1910.147 must also perform an annual inspection of their established procedures and authorized employees.

The primary goal of the annual LOTO audit is to confirm that existing LOTO procedures still are adequate and accurate.

The audit also will confirm whether authorized employees understand the LOTO procedures in place and that they’re using those procedures every time a machine is being serviced or undergoing maintenance.

Here are some considerations as you prepare for an upcoming LOTO audit.

Why should you conduct an audit?

Conducting regular audits of your procedures and the employees authorized to perform them will confirm that your safety program is running smoothly. You can catch inconsistencies or errors before they cause injuries.

You also can make sure your employees fully understand their role in the LOTO process.

When should you audit?

While the minimum expectation is to perform an annual audit, you can regularly audit your procedures and employees. OSHA's standard states that employers "shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed." (1910.147(c)(6)(i))

Who should do the auditing?

Someone not directly involved in performing the LOTO procedure being audited should conduct the audit. The OSHA standard states that periodic inspections should be "performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected." (1910.147(c)(6)(i)(A))

You can select someone from your company to perform the audit, such as a supervisor. You also can bring in a third party to complete the audit.

As an observer who isn’t directly involved in the inspection, the auditor can identify and correct any deviations from the employee's process. The auditor can also make suggestions for improved training that verifies all authorized employees understand and perform the procedures adequately.

How to Certify the Audit

Once the audit is complete, the auditor must certify that an audit took place. This is outlined in OSHA standard 1910.147(c)(6)(ii). The certification should identify the inspection date, all employees included in the inspection, and the person who inspected the specific piece of equipment or machine utilizing the energy control procedure.

You need to check these three components during an annual inspection:

• Your LOTO procedure.
• Your employees' usage of the procedure.
• Compliance with the overall LOTO program within your organization.

1. LOTO procedure and accuracy per machine. Review these items to verify the accuracy of your LOTO procedures on equipment:

• All necessary equipment has a documented procedure.
• Every procedure is accurate and includes current equipment configuration.

If procedures are lacking, take these steps:

• Revise inaccurate procedures.
• Create new procedures for any equipment that does not already have documented procedures.

2. Authorized employees' knowledge and usage of procedures. When auditing employees, look for these considerations:

• Employees can correctly follow the proper sequence of procedures to lock out the equipment and restore it to service.
• Employees can place the logs, tags and devices on the energy source disconnects.
• Employees demonstrate understanding of when to lock out equipment and how to handle particular situations, such as group lockout or troubleshooting.

If employees do not pass inspection, more training is required to verify that all authorized employees understand and can safely perform the LOTO procedures.

3. Overall program and policy compliance. After inspecting individual machines and employees, the audit concludes by reviewing the overall program.

• Review the overall program for effectiveness.
• Review program enforcement criteria.
• Determine if enforcement criteria are being followed.

Creating procedures for LOTO is just one part of the process. If the LOTO procedures aren’t being enforced, changes must be made to verify safety.

Like this article? Sign up for the digital magazine from The Journal From Rockwell Automation and Our PartnerNetwork and get articles like this delivered right to your inbox.

^{The Journal From Rockwell Automation and Our PartnerNetwork™ is published by Endeavor Business Media.}