Case Study 4: Multiple Energy Control Procedures

Incorrect.  Not in this case.

The periodic inspection must be conducted by an authorized employee other than the one who implements the procedure. This authorized employee is designated by the employer as an inspector. He or she must observe the procedure being implemented by a representative number of authorized employees and must talk with all other authorized employees, even though they may not be implementing the energy control procedure.

Of the 130 energy control procedures, the employer is only required to perform a periodic inspection on each of the unique energy control procedures. The inspector or inspectors performing the periodic inspection must observe the implementation of each of the 51 energy control procedures by a representative number of authorized employees. For each procedure, the inspector must also conduct a review with all other authorized employees involved in implementing the energy control procedure to review the procedure and their responsibilities under it. Because the employer's inspection protocol does not include a review of each separate procedure with all authorized employees who may have responsibilities under it, the protocol fails to comply with section 1910.147(c)(6)(i). Observing only a single authorized employee implementing each lockout procedure, rather than a representative number of employees, also does not meet the intent of the standard.

Moreover, the employer's use of group meetings to review the energy control procedures where implementation is not actually inspected also falls short. This is because the implementation of each separate lockout procedure may be observed by a representative number of employees.

For more information: Refer to the part 1910.147(c)(6)(i) of the Lockout/Tagout standard.

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