Ask the ExpertCategory: Questions1910-147c6-periodic-inpsections
Mary Prisby asked 5 months ago

As we continuously work on best practices, we are in the process of reviewing our LOTO procedures.  We are using Brady360 for our Equipment specific LOTO procedures, (ESL).  We have questions about the inspections and the authorized employees. I am requesting clarification on periodic inpsections on our Equipment specific LOTO procedures.  We have over 300 procedures.  Not all the procedures may be used within one year.  Q1:  Do all the procedures have to be inspected if they are not used in that year?                  I was on a webinar and the speaker said that if ESL procedures are not being used, they don’t have to be inspected.  Q2:  Do I inspect only the procedures that are used? Q3:  Does the inspections need to take place during an active LOTO? I am considering grouping the equipment, like for like when scheduling periodic inspections.  For example:  grouping all my agitators in one room.  Q3:  Would it be acceptable to group them together and periodically inspect one agitator in that group? 1910.147(c)(6)(i)(C) Is it acceptable to have the person performing the inspection be an authorized employee not involved in utilizing the procedure at the time of inspection?                 From the definition of authorized employee it appears that you have to use them to perform the audit.  For example, an administrator would not be an authorized employee if they do not perform the work.                Another example:  As an EHS Manager, I have been trained and train employees on the LOTO standard, however, I do not meet the definition of authorized employee because I do not actively repair equipment.  Hence, I would not be able to perform the inspections.  Please provide clarification.  1910.147(c)(6)(i)(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected. 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.   Thanks, Mary