The requirement in one paragraph
29 CFR 1910.147(c)(6)(i) says the employer shall conduct a periodic inspection of the energy control procedure at least annually to make sure the procedure and the requirements of the standard are being followed. Paragraph (c)(6)(ii) says the employer shall certify that the periodic inspections have been performed.
Who may inspect
An authorized employee other than the ones using the procedure being inspected ((c)(6)(i)(A)). In a small shop that usually means a maintenance technician from another area, a lead or a supervisor who is trained as an authorized employee, inspecting a procedure they do not use themselves.
What the inspection covers
- Deviations or inadequacies in the procedure or in how it is used are identified and corrected ((c)(6)(i)(B)).
- Where lockout is used: the inspector reviews with each authorized employee that employee's responsibilities under the procedure ((c)(6)(i)(C)).
- Where tagout is used: the review includes each authorized and affected employee, and the limitations of tags listed in (c)(7)(ii) ((c)(6)(i)(D)).
What the certification must record
| Field | Source |
|---|---|
| Machine or equipment on which the procedure was used | (c)(6)(ii) |
| Date of the inspection | (c)(6)(ii) |
| Employees included in the inspection | (c)(6)(ii) |
| Person performing the inspection | (c)(6)(ii) |
Those four items are the minimum. Most plants also record what was observed, any deviations found, the corrective action and whether retraining is needed: under (c)(7)(iii)(B), retraining is required when an inspection reveals deviations from, or inadequacies in, an employee's knowledge or use of the procedures.
A practical inspection checklist
- Pick the procedure and the machine. Check the procedure lists every energy source actually on the machine (electrical, hydraulic, pneumatic, gravity, springs, thermal, chemical).
- Watch an authorized employee apply the procedure, or walk through it with them on the machine.
- Check each step against the (d) sequence: preparation, shutdown, isolation, device application, stored energy, verification.
- Check the devices: singularly identified, used only for energy control ((c)(5)(ii)).
- Review responsibilities with each employee included (and, for tagout, affected employees and tag limitations).
- Record findings and corrective actions; update the procedure if the machine has changed.
- Certify: machine, date, employees included, inspector. Set the next due date.
Where plants usually lose track
The rule is per procedure, so a plant with 40 machine-specific procedures owes 40 inspections a year. A simple register with "last inspection" and "next due" for each machine, and a flag for anything overdue, is what stops a procedure from slipping past its year.
Free procedure generator, $49 program kit
Write a machine-specific procedure for free, or get the kit: a workbook that flags overdue inspections, the inspection certification form, and procedure and program templates.
Questions
Is "at least annually" a calendar year or 12 months?
The standard says "at least annually". Tracking a due date 12 months after each inspection is the simplest way to make sure no procedure goes more than a year.
Can one inspection cover several machines?
The inspection is of the energy control procedure. Where several identical machines share one procedure, the certification still has to identify the machine or equipment on which the procedure was being used.
Do we need a written procedure for every machine?
Generally yes. The note to (c)(4)(i) allows an employer not to document the procedure for a particular machine only when all eight listed conditions are met.
General information based on the text of 29 CFR 1910.147 on eCFR.gov; not legal advice. Check whether an OSHA-approved state plan applies to your workplace.