Last week, in Part 1 of this article, Hal explained how to inspect energy control procedures under the OSHA Control of Hazardous Energy (lockout/tagout) Standard. Hal will now tell you how to document your inspection.

As far as liability is concerned, documenting the steps you take to comply with an OSHA standard is just as important as taking those steps in the first place. As lawyers like to say, if it isn't documented, it never happened.

This principle is especially true in the realm of lockout/tagout. I've seen cases where employers who did perform required inspections got cited because they couldn't prove it. Let me explain how to document your periodic energy control procedure inspections in case an OSHA inspector shows up. There's also a model form you can use for this purpose. [Editor's Note: The form is available to SafetyXChange members in the Tools section.]

What the LOTO Standard Requires

The lockout/tagout (LOTO) standard requires you to set out procedures to control energy to shut down equipment and inspect those procedures at least once a year. The standard also requires you to certify that you've done an inspection and describe what the inspection covered.

How to Certify the Inspection

The Model Form in the Tools section is an example of how to properly certify an inspection. Although there's no such thing as a one-size-fits-all form, there are standard kinds of information that all forms should include. Make sure that whatever certification you use lists the following items:

1. Inspection Date

The LOTO standard specifically requires listing the date the inspection was performed. One year from that date is your deadline for conducting your next inspection.

2. Location of Equipment

List the area or department of the facility in which the equipment or machinery covered by the inspected lockout/tagout procedures is located. Make sure you do a separate inspection and complete a separate certification form for each area of the workplace you inspect, even if the area contains the same machinery or equipment as an area you've already inspected. Keep in mind that the point of the inspection is to ensure that workers in each area understand the LOTO procedures.

3. Description of Equipment

Describe and provide specific identifying information of the equipment or machinery covered by the inspection, such as a model or serial number.

4. Description of Procedures

Use a check box to indicate what kind of procedures were inspected - lockout or tagout.

5. Workers Spoken To

List the name of each worker the inspector spoke to and the department in which they work. This is critical information to document because it enables you to show that you went over the procedures with all the workers the LOTO standard requires you to talk to.

6. Inspector's Name

OSHA requires you to list the name of the inspector. It's also a good idea to include the person's extension and other contact information so you can easily follow-up with the inspector.

The Canadian Perspective

New CSA Lockout Standard

This article is relevant to Canadians.

Explanation: On April 26, the Canadian Standards Association (CSA) published a new lockout standard. CSA Z460 Control of Hazardous Energy - Lockout & Other Methods sets out requirements for controlling hazardous energy associated with potentially dangerous machines, equipment and processes. Clause 7.6 of CSA Z460 requires management review to ensure that the hazardous energy control process is functioning properly. This is essentially the same thing required by the OSHA LOTO standard - although the review procedures to be used aren't identical.

The Upshot: Hal's recommendations and forms (in both articles) can be adapted for CSA Z460. And, while CSA standards aren't legally required (unless the OHS law specifically says they are), they're relevant to compliance because they represent a consensus standard regarding safety.

Glenn Demby

Editor-in-Chief

SafetyXChange

POP QUIZ

VOLUNTARY COMPLIANCE vs. TRADITIONAL ENFORCEMENT

OSHA enforces the law in two ways:

Traditional methods such as inspections and fines; and

Voluntary programs like the Voluntary Protection Program.

Voluntarism has been the vogue, especially under the Bush Administration. Some have even claimed that traditional enforcement is a thing of the past.

Question: Which does OSHA spend more money on - traditional enforcement or voluntary programs?

Answer: Traditional enforcement. And it's not even close. The Bush Administration is proposing to spend $174.3 in inspections in FY 2006. The proposed voluntary compliance budget: $73.3 million, or about 50 percent of that amount.

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