Part 411 min

4.3 The annual periodic inspection

The periodic inspection is the third leg of the program defined in 1910.147(c)(1), and it is the one plants forget. It is also the one that finds everything else: the procedure that no longer matches the machine, the technician who has been skipping the verification step for two years, the tag limitation nobody was ever taught. It takes an hour per procedure and it is required at least annually.

1 What is being inspected

1910.147(c)(6)(i): "The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed."

Read the object of the sentence: the inspection is of the energy control procedure. Not of the machine, not of the lock inventory, not of the training records — of the procedure, and of whether it and the standard are being followed. That means it is done where the procedure is used, on a real or realistically simulated job, watching a real authorized employee.

"At least annually" applies to each procedure, not to the program as a whole. A plant with forty procedures does forty inspections a year — which is one every six working days, and is exactly why programs that treat this as an annual event rather than a rolling schedule fall behind by March.

2 Who performs it

1910.147(c)(6)(i)(A): "The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected."

Three conditions in one line. The inspector must be an authorized employee — someone trained to (c)(7)(i)(A), who understands what they are looking at. They must be other than the person or people using the procedure being inspected, which rules out self-inspection. And they are inspecting this procedure, so an authorized employee from another area or another shift is an ideal choice.

Common mistake: having the safety manager do all the inspections. If the safety manager is not an authorized employee under the plant's own program, they do not meet (c)(6)(i)(A). Cross-inspection between shifts or areas satisfies both the "authorized" and the "other than" conditions, and has the side benefit of spreading good practice.

3 The review that has to happen

The inspection is not only an observation. Two subparagraphs require a conversation.

The review requirement, and how it differs for lockout and tagout
Where lockout is used — (c)(6)(i)(C)	Where tagout is used — (c)(6)(i)(D)
A review, between the inspector and each authorized employee, of that employee's responsibilities under the procedure being inspected	A review, between the inspector and each authorized and affected employee, of that employee's responsibilities under the procedure — and of the tag limitations set out in (c)(7)(ii)

The tagout column is materially more work: more people to talk to, and an extra syllabus to cover. That difference is one of the quiet reasons the standard prefers lockout — tagout is not only less protective in the moment, it is more expensive to maintain properly year after year.

1910.147(c)(6)(i)(B) adds the point of the whole exercise: "The periodic inspection shall be conducted to correct any deviations or inadequacies identified." Finding a gap and writing it in a report is half a job; the paragraph requires correction. And if the gap is a knowledge gap, (c)(7)(iii)(B) turns it into retraining.

4 Certifying it: four required fields

1910.147(c)(6)(ii): "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."

The machine

Which machine or equipment the procedure was used on

The date

When the inspection was performed

The employees

Who was included in the inspection

The inspector

Who performed it

Four fields, all of them concrete. A certification that says "LOTO inspections completed, Q3" identifies no machine, no employees and no inspector, and satisfies none of them. Most plants add two more columns that cost nothing and are worth a great deal at the next inspection: what deviations were found, and what was done about each one.

5 What to actually look at

The standard sets the requirement, not the checklist. A useful inspection watches an authorized employee perform the procedure and asks whether each element of 1910.147(d) and (e) happened in order and as written.

1
Were affected employees notified before the controls were applied? (c)(9)
2
Did the employee know the type and magnitude of the energy before shutting down? (d)(1)
3
Was the shutdown the machine's normal, orderly stopping procedure? (d)(2)
4
Was every isolation point on the procedure located and operated — and is the list still complete? (d)(3)
5
Was a device applied to each point, by the person exposed, holding it in the safe position? (d)(4), (c)(8)
6
Was stored energy relieved, blocked or restrained after the locks went on? (d)(5)
7
Was isolation verified — with people clear first, and controls returned to neutral afterwards? (d)(6), App. A step 7
8
On release: area cleared, guards back on, people clear, devices removed by their owners, affected employees notified? (e)(1)-(e)(3)

On the job: inspect the procedure against the machine at the same time. Stand at each isolation point and check that the identifier on the paper matches the label on the device. That single habit catches most of the drift that accumulates between one inspection and the next.

6 Building a schedule that survives the year

Three practices turn the annual requirement into something that actually happens.

Put the due date on the procedure. The document that gets picked up before every job is the best possible place to carry "last inspected 03/14/2026, next due 03/14/2027." Anyone who reads it sees when it is going stale.

Spread the inspections across the year and pair them with real work. Inspecting a procedure during a planned job costs almost nothing beyond the inspector's time; setting up a simulated lockout costs a machine's availability. A rolling schedule keyed to the maintenance plan gets both cheaper and more realistic.

Close the loop on findings. (c)(6)(i)(B) requires correction, and (c)(7)(iii)(B) requires retraining where the finding is a knowledge or usage gap. A findings column with a date and an owner is what turns an inspection into an improvement, and it is the evidence that the third leg of your program is holding weight.

Key takeaways

1910.147(c)(6)(i) requires a periodic inspection of the energy control procedure at least annually — per procedure, not once for the whole program.
It must be performed by an authorized employee other than the one(s) using the procedure being inspected (c)(6)(i)(A)).
Where lockout is used, the inspection includes a review with each authorized employee of their responsibilities; where tagout is used, it also covers each affected employee and the six tag limitations of (c)(7)(ii) (c)(6)(i)(C)-(D)).
Deviations and inadequacies must be corrected, not just recorded (c)(6)(i)(B)), and knowledge gaps trigger retraining under (c)(7)(iii)(B).
The certification must identify the machine, the date, the employees included and the person performing the inspection (c)(6)(ii)).
Put the next-due date on the procedure itself, spread inspections across the year on real jobs, and track findings to closure.

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.