April 8, 2006
Since the inception of the Control of Hazardous Energy standard in 1990, complying with the periodic inspection requirements has been a challenge for many employers â€” especially those large-scale operations with hundreds of assets to manage. To help employers implement and successfully manage a periodic inspection program, letâ€™s take an overview look at the periodic inspection process.
Energy control proceduresThe standard (29 CFR1910.147(c)(4)(i)) requires the employer to develop, document and utilize energy control procedures for potentially hazardous energy when employees are engaged in servicing and maintaining machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could cause injury to employees. While procedures must be documented, separate energy control procedures for each individual machine or piece of equipment are not required per the standard.(1)
Periodic inspectionThe employer is required to conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of the standard are being followed.
While not implicit in the regulation, OSHA has issued guidance to stress that the expectation is that â€œeach energy control procedure must be separately inspected annually.â€ This can be a daunting task, especially for employers who have large-scale operations and choose to implement individual equipment procedures. OSHA has recognized these situations and will allow employers to group machines/equipment with the â€œsame type and magnitude of hazardous energy and which have the same or similar type of controls.(2)â€
This approach would be considered a single procedure for the requirements of periodic inspection provided the aforementioned conditions are met and that all machines/equipment in group have the same intended use. Additionally, the written procedures must have the same or similar procedural steps to ensure the equipment is in a zero energy state (ZES).
OSHA also recognizes that not all equipment will be shut down annually for service or maintenance. The employer is not required to shut down equipment solely for the purpose of periodic inspection. The affected energy control procedures (i.e. used less frequently than once a year) need be inspected only when used.(3) It would be prudent for the employer to track the frequency that the equipment is shut down.
Who inspects?OSHA requires that an authorized employee other than the one utilizing the procedure conduct the periodic inspection. The inspector assesses not only if the procedure is adequate, but also that the authorized employee understands and follows the procedural requirements.
Purpose of inspection1) Is the procedure adequate? The inspector must determine if the identified steps effectively render the equipment in a ZES.
2) Is the procedure understood? The inspector must determine if the employees involved know their responsibilities per the procedure.
3) Is the procedure being followed? The inspector must watch the authorized employees perform the entire procedure and determine if each step was correctly executed.
The employer must certify, in writing, that the periodic inspections have been performed per 1910.147(c)(6)(ii) for each procedure. The standard contains specific requirements of what must be included on the certification.
Periodic inspection reviewThe final piece of the periodic inspection process is a review between the inspector(s) and all authorized employees (affected employees, too, if tagout is used for energy control purposes) who are expected to utilize the procedure. Reviews occur annually (or in conjunction with the periodic inspection cycle). Inspector(s) may make program/procedure changes based on feedback and observations during the periodic inspection process.
The periodic inspection review may best be accomplished with group meetings. At these meetings, the inspector would review the machine(s)/equipment inspected, any program/procedural changes that were made, and the employeesâ€™ responsibilities under the procedures. OSHA is clear to note that the periodic inspection meetings are not the same as lockout/tagout retraining.