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OSHA answers the Question... Do we HAVE TO perform an ANNUAL LOTO Inspection on ALL our "Machine Specific" LOTO procedures?
Here is OSHA's latest on the requirement 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". I have removed all the chit-chat and posted the nuts and bolts of the letter.
The question was "Does 1910.147(c)(6) require that an annual inspection be conducted of each written procedure?" OSHA responded by saying "Section 1910.147(c)(6)(i) requires periodic inspection of the energy control procedure [required by §1910.147(c)(4)] to ensure that the procedure and the requirements of this standard are being followed.
The periodic inspections must contain at least two components:
1) an inspection of each energy control procedure, and
2) a review of each employee's responsibilities under the energy control procedure being inspected.
Each energy control procedure must be separately inspected at least annually to ensure that the energy control program is being properly utilized. At a minimum, these inspections must provide for the demonstration of the procedures and must be performed while authorized employees perform servicing and/or maintenance activities on machines or equipment.
Specifically, the inspector must be able to determine whether:
1) the inspected procedures are adequate;
2) they are understood; and
3) being followed by employees.
Following the inspection, there must be a review of each employee's responsibilities under the energy control procedure that was inspected. In your scenario, the individual standard operating procedures, which include energy control measures, are used because they provide a high level of detail and enhance safety. While not required by the standard, employers may elect to develop, document, and utilize separate energy control procedures for individual machines or pieces of equipment when the standard would permit a single procedure to apply to a group of similar machines or equipment.
OSHA agrees that, if an employer voluntarily develops such individual procedures, the standard's performance oriented inspection requirements cannot be construed to create more comprehensive inspection obligations than would be incumbent on another employer who chose not to develop such individual procedures.
Therefore, as described below, if an employer chooses to develop individual detailed procedures, the employer still may group related procedures that are applicable to similar types of machines or equipment (e.g., furnaces/ovens; cold and hot mill operations; coating lines; machine shop machinery; cranes; and gas systems) for inspection purposes.
In short, machines and/or equipment with the same type and magnitude of hazardous energy and which have the same or similar type of controls can be grouped and inspected by the type of procedure. A grouping of detailed individual procedures would be considered a single procedure for periodic inspection purposes, if all of the procedures in the grouping have the same or similar:
Intended machine/equipment use;
Procedural steps for shutting down, isolating, blocking, and securing machines or equipment;
Procedural steps for the placement, removal, and transfer of the lockout or tagout devices and the responsibility for them, and
Requirements for testing a machine or equipment to determine and verify the effectiveness of lockout/tagout devices and other control measures.
Thus, an employer may elect to first categorize the machines and pieces of equipment, as described above, and then inspect a representative number of authorized employees implementing a procedure within each category. This approach is acceptable, as long as the sampling reasonably reflects plant servicing and/or maintenance operations and hazardous energy control practices for the procedure being inspected.
If an employer groups procedures for inspection purposes, the employer should consider selecting different individual procedures (from the group of same or similar procedures) each year for evaluation, so that, over time, each individual procedure eventually would be inspected as part of an inspection program.
However, within a group of procedures, an employer may be justified in focusing more regularly on a subset of procedures that are more likely to be deficient or incorrectly implemented by employees, if institutional experience (e.g., incident rates associated with certain machinery) or other factors (e.g., the unusually large number of employees required to accomplish the repair turn or major outage activity) support such a strategy. Regardless of the approach, these representative procedure inspections must reasonably reflect plant servicing and/or maintenance operations and energy control practices.
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