What you Need to Know
In order to maintain compliance with OSHA’s Lockout Tagout standard, it is required to perform annual inspections of both the lockout tagout procedures and the authorized employees. The annual audits are important to a lockout tagout program, because audits reveal inconsistencies and problems. When it comes to annual lockout tagout audits, there are three main aspects to complete: procedure review, employee review, and what to do if deficiencies are found. If these three components are followed, a compliant, up-to-date program will ensue.
The first step in an annual audit is to perform a review of all of the machine-specific procedures. The purpose of the procedure audit is to identify any deviations or inadequacies in the current procedure. Therefore, to review a procedure ask these three questions:
- Is the procedure present and legible?
- Are all the energy sources accounted for in in the procedure?
- Does the procedure accurately represent the machinery?
First, ensure that the procedure exists for the machine; make sure it is present and legible at the piece of equipment. If not, create or reprint the procedure. Second, confirm that all of the energy sources are still accounted for in the procedure and that no new energy sources have been added. Finally, make sure that the procedure is still accurate, the description, location and location of energy sources are still the same; check that the equipment hasn’t been relocated or removed.
The second component to a complete annual inspection is to review the authorized employees. This review process is to ensure that the employee knows how to correctly follow a lockout tagout procedure and lockout a piece of equipment. While performing this review, the inspector should ensure that the employee can follow the shutdown sequence of the equipment, place the locks and tags on the energy source disconnects, and follow the restore to service sequence. Also check that employees understand when to lockout equipment and how to handle special circumstances such as group lockout. Once the inspector is satisfied with the results of the review of the employee, the review is complete. This shall be completed for a sample size of the authorized employees.
When performing the lockout tagout audit of the procedure, if inadequacies are found it is essential to make note of the change and update the procedure accordingly. If a machine has been relocated but all of the energy sources are the same, the location of the unit must still be updated and the updated procedure shall be printed off for use. Once updates are made to the procedures, the original procedures become obsolete, and shall be replaced in all of their locations.
If new sources of energy are present or if existing sources are relocated, this needs to be updated as well. Even a new valve type or location of electrical disconnect should be noted. Finally, check for mistakes and typos, anything that may affect the integrity of the procedure.
If deficiencies are found during an employee audit, retraining will be necessary. The retraining only needs to be provided to those employees that did not pass the employee audit and only needs to cover the sections they are deficient in. The retraining shall reestablish the employee’s proficiency to use the energy control procedures. Be sure to make note of the retraining, as OSHA requires this to be recorded.
If the vast majority of employees are found to lack the proper knowledge of lockout tagout, a more detailed investigation must occur. The training module may need to be overhauled and all employees may need retraining. Enforcement of what is taught is crucial for program success.
Summary of Lockout Tagout Audit Process
Lockout tagout audits are pivotal to the success of the program; without the annual reviews, equipment changes and employee deficiencies may never be caught. Therefore, reviewing the procedures, employees and fixing any inadequacies & deficiencies will allow for a complete and accurate lockout tagout program. Not only will completing the audits keep a company compliant, it will also help guarantee the health and safety of all employees when they are performing lockouts.
ESC Services has helped numerous companies across the US complete their annual lockout tagout audit. For more information on our services, contact us.
You might also be interested in this page that shows details of how to make an audit more efficient with modern technology.
If you want to learn more about lockout tagout, visit our learning center to review the 5 components, or check out our lockout tagout NEWS section that has expert tips and links to valuable resources such as audit forms and training files.