Lockout tagout periodic inspection: the annual check OSHA 1910.147 requires
OSHA 1910.147(c)(6) requires an inspection of each energy control procedure at least annually, performed by an authorized employee other than the one using the procedure, with a certification recording the machine, date, employees included, and inspector. What the inspection covers and how to keep the certification defensible.
By Hovermarks team
Quick answer. Under OSHA 29 CFR 1910.147(c)(6), every energy control procedure must be inspected at least annually. The inspection is performed by an authorized employee who is not using the procedure being inspected, includes a review with each authorized employee of their responsibilities (and affected employees too, for tagout), and must be certified: the machine or equipment, the date, the employees included, and the person performing the inspection. A missing certification is one of the most-cited LOTO failures.
Most facilities get the hardware right: locks, tags, hasps, and a written program. The periodic inspection is where programs quietly lapse, because it is an annual, per-procedure obligation that lives in nobody's calendar, and because the rule has a detail teams miss: the inspector cannot be the person using the procedure under review.
What 1910.147(c)(6) requires
Per energy control procedure, at least annually:
- An authorized employee other than the one utilizing the procedure inspects it in use, or walks it through, to verify the procedure steps still match the machine and are being followed.
- A review with every authorized employee of their responsibilities under that procedure. Where tagout is used instead of lockout, the review extends to affected employees, covering the limitations of tags.
- Deviations and inadequacies corrected: if the machine changed, the procedure changes with it.
- Certification recorded: the machine or equipment on which the procedure was used, the inspection date, the employees included, and the name of the inspector.
The certification is the audit artifact. "We inspect our LOTO annually" with nothing per procedure fails the standard on its face.
Why per-procedure tracking breaks spreadsheets
A mid-sized plant runs dozens to hundreds of machine-specific energy control procedures. Each carries its own annual clock, its own list of authorized employees to review, and its own certification. Staff turnover resets the review lists; new equipment adds procedures mid-year. The failure mode is always the same: the spreadsheet says compliant, three procedures have no certification newer than two years, and the OSHA citation writes itself.
Where Hovermarks fits
Hovermarks ships a lockout/tagout inspection template out of the box: each machine's energy control procedure lives against its QR-tagged asset, the annual inspection is scheduled per procedure with reminders, the inspector runs the certification checklist on a phone (machine, date, employees included, inspector captured as structured fields with a signature), and the complete certification history answers an OSHA visit by scan. The manufacturing solution shows where LOTO sits in the wider machine-safety routine.