What Does the Standard Require?
Section 1910.147(c)(6)(i) states: "The employer shall conduct a periodic inspection of the energy control procedure at least annually." The purpose is to ensure the procedure is being followed correctly and is still adequate for the equipment and hazards involved.
The inspection must be performed by an authorized employee — not the same person who normally uses the procedure being inspected. This is an explicit requirement under 1910.147(c)(6)(ii).
Who Can Conduct the Inspection?
The inspector must be:
- → An authorized employee (trained and designated to perform lockout/tagout)
- → Someone other than the employee who normally uses the procedure being inspected
- → Knowledgeable about the equipment, energy sources, and the procedure being reviewed
On small crews where one person handles all service work, this can be the supervisor, owner, or a safety consultant — as long as they are trained as authorized employees.
What Must the Inspection Cover?
Per 1910.147(c)(6)(i), the inspection must include a review of the procedure with each authorized employee who uses it. Specifically:
Procedure Review
Walk through each step of the written procedure with the employees who use it. Verify the steps are still accurate and complete.
Equipment Verification
Confirm that isolation points, lock placements, and verification steps still match the current equipment configuration.
Tagout Adequacy
If tagout devices are used instead of lockout, the inspection must also review the limitations of tagout and whether lockout would provide greater safety.
Employee Review
Review the procedure with each authorized employee who uses it — not just a group review. Individual confirmation is required.
The Certification Requirement
1910.147(c)(6)(ii) requires written certification of the inspection. This is the piece most employers miss. A verbal review doesn't count. The certification must include:
- → The machine or equipment the procedure covers
- → The date of the inspection
- → The employees included in the review
- → The name of the inspector
A simple sign-off sheet attached to each machine-specific procedure template satisfies this requirement. The certification just has to exist and be on file.
What OSHA Cites Most Often
The most common citation under 1910.147(c)(6) is not that employers skipped the inspection — it's that they can't prove they did it. An inspector will ask for your certification records. If you can't produce them, it's the same as not doing it.
1910.147(c)(6)(i) violation is classified as Serious — meaning OSHA believes it could cause death or serious physical harm. That puts the fine at up to $16,131 per citation.
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