Under OSHA 1910.147(c)(6), every energy control procedure in your program must be inspected at least once a year. This "periodic inspection" is the audit trail that proves your LOTO program works in practice, not just on paper, and skipping it is one of the most frequently cited violations of the standard.
What gets inspected
The inspection reviews each energy control procedure for the equipment it covers: are all energy sources identified, are isolation points correct, do the steps match what employees actually do, and are stored-energy and verification steps adequate? The inspector also reviews with each authorized employee their responsibilities under the procedure, and with affected employees the prohibitions against operating locked-out equipment.
Periodic inspection vs. audit: what to call it
OSHA calls the annual review a "periodic inspection", the term in the standard is 1910.147(c)(6)(i). "Annual audit" is the common industry shorthand, and the two mean the same thing in practice: the once-a-year, documented review of each energy control procedure. Knowing the official term matters because it is the phrase inspectors and the standard itself use.
Whichever name you use, the substance is what counts: a review of the procedure against the equipment, performed by an authorized employee who does not use that procedure, with the results certified. Use our lockout/tagout compliance checklist to run the review systematically.
Who can perform the inspection
It must be performed by an authorized employee, someone trained in LOTO, other than the employees who use the procedure being inspected. In practice this means a supervisor, safety manager, or peer from another shift or site. You cannot self-audit your own procedure.
The certification you must keep
The employer must certify that the inspections were performed. The certification must identify the machine or equipment, the date of the inspection, the employees included, and the person performing the inspection. If your site has 40 LOTO procedures, you need 40 certified inspections every year. These records are among the first things an OSHA inspector asks for.
What happens when deviations are found
If the inspection finds that employees are deviating from the procedure, or the procedure itself is wrong, corrections must be made before work continues under it. The affected employees must be retrained where needed. Findings and corrections are part of your program record.
Audit due? Recommend Tegis Safety on Google if the certification checklist helped.
How digital tools make annual audits manageable
Tracking 40 or 400 annual inspections with spreadsheets invites missed deadlines. Digital LOTO platforms can track inspection due dates per procedure, record who reviewed what and when, store the certification automatically, and surface deviations to fix, turning the annual audit from an annual scramble into a routine report.
Key takeaways
- Every procedure, every year, no exceptions or grace periods.
- The inspector must be authorized but not a user of that procedure.
- Certification must name the equipment, date, employees, and inspector.
- Deviations require correction and possible retraining before continued use.
Frequently asked questions
Does the annual inspection cover tagout procedures too?
Yes. Tagout procedures get the same annual inspection, plus a required additional review with each authorized employee of the extra safety measures used in place of a lock.
How long should we keep inspection records?
OSHA does not set a fixed retention period for the certification itself, but the current certification is what must be available on request, and most auditors expect multi-year records as evidence of a consistent program.
Can two procedures be inspected at the same time?
Each energy control procedure needs its own inspection, and the certification must identify the machine or equipment, the date, the employees included, and the inspector, for every procedure. Reviewing ten procedures in one session is fine, and one form may cover several machines only if each machine is individually identified with its own date and participants. A single blanket line certifying ten machines at once will not survive an audit.
What if we missed the annual deadline?
There is no grace period in the standard, but there is also no point in hiding the gap. Perform the missed inspections immediately, document the late completion, and correct any deviations found. Then adjust your scheduling so the next cycle lands on time. An inspector who finds a documented catch-up is far more likely to accept it than one who finds inspections missing entirely.
Do contractors need to be included in inspections?
Not in the periodic inspection itself. That covers your own authorized employees and procedures. But contractors who perform servicing at your site must be briefed on your lockout procedures under 1910.147(f)(2), and that coordination is a separate program obligation worth its own review. Tracking both in one digital LOTO program keeps them from falling through the cracks.