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OSHA Regulation CFR1910.147(c)(6) states that "The employer 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".
The regulations specifically state that the LOTO procedures must be audited at least annually by someone "other" than who utilizes the procedure to perform work on the machine.
Scope Safety Services performs this task for our clients and we also update the procedure if any changes have been made or any deficiencies have been found on the procedure. If any of our energy isolation tags are missing, they are replaced as shown on the procedure.
When an employer knowingly disregards OSHA regulations or is aware of a safety issue and does not take corrective action, it is called a Willful Violation. Not having a lockout/tagout procedure or not correcting audit findings are some examples.
When Scope Safety Services audits the procedures and finds that the procedure is accurate and all tags are in place, we adhere our Audit Completed label to the procedure to show that the auditing is complete for that procedure and that process is now compliant.
The employer 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.
The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.
The periodic inspection shall be conducted to correct any deviations or inadequacies identified.
Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected.
Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.
The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.
The minimum fine is $5,000 and $70,000 if no deaths occur. Criminal charges and a fine of $250,000-$500,000 will be issued for loss of life situations.