OSHA 1910.147 mandates that lockout tagout procedures be reviewed at least once a year. We perform the audit for you, or give your team access to LockStep auditing software to complete it internally with full compliance documentation.
The Requirement
OSHA 1910.147(c)(6) requires employers to conduct a periodic inspection of the energy control procedure at least annually. The purpose of the inspection is to confirm that the procedure is current, accurate, and being followed correctly.
The inspection must be performed by an authorized employee other than the one using the procedure. It must include a review of the procedure with each employee who uses it. And it must be certified in writing with the machine name, date of inspection, employees involved, and name of the inspector.
Most facilities that perform annual reviews do so informally with no documentation. When OSHA asks for your annual inspection records, informal reviews do not satisfy the requirement.
What OSHA Looks For: Written certification that the periodic inspection was performed, the date it was conducted, the machines or equipment covered, the names of the employees included, and the name of the authorized employee who performed the inspection.
Beyond the direct OSHA citation for missing records, an undocumented annual review also removes your defense in the event of an incident. If a worker is injured during a maintenance task, the absence of annual inspection records signals systemic non-compliance, which escalates the severity of enforcement action significantly.
How We Deliver It
Choose what works best for your team. Both options result in compliant, audit-ready documentation.
Our team conducts the entire review for you
Best for facilities that want no internal resource burden and the confidence of an independent certified review.
Access our exclusive auditing platform to complete the review internally
Best for facilities with capable internal EHS teams who want to own the process but need a structured, compliant system to do it right.
LockStep Software
LockStep is our exclusive compliance management platform built specifically for lockout tagout programs. It replaces spreadsheets, shared drives, and paper binders with a centralized system that keeps your program accurate, current, and audit-ready at all times.
Centralized system for all LOTO docs
Spreadsheets or binders required
Audit workflow built in
Audit-ready documentation
Common Problem We Solve: EHS managers at multi-facility organizations often have no idea if every facility is current on annual reviews. LockStep gives corporate EHS teams visibility into the compliance status of every location from a single dashboard.
Scope of Review
The review goes beyond checking a box. Every machine procedure is validated against current equipment conditions and workforce changes.
Each documented energy control procedure is compared against the actual current state of the equipment. Modifications, repairs, or additions since the last review are identified and procedures are updated accordingly.
OSHA requires that the annual inspection include a review of the procedure with each authorized employee who uses it. We facilitate these sessions and document participation to satisfy the certification requirement.
Physical placards are inspected for legibility, proper placement, and continued accuracy. Any placards that have been damaged, removed, or become outdated are identified for replacement.
Equipment added since the last review that does not yet have documented LOTO procedures is flagged. Getting new machines into the program before the next inspection is a critical outcome of every annual review.
Every annual inspection is documented with the required OSHA certification elements: machine name, inspection date, employee names, and inspector identity. This documentation is stored in LockStep and available immediately if requested during an audit.
The audit concludes with a summary of findings, noting any procedures that were updated, any equipment added to the program, and any items requiring follow-up action before the next review cycle.
Full-Service Option
The annual audit is one component of a complete lockout tagout program. For facilities that want to offload the entire compliance burden, we offer a full-service program that covers everything from initial setup through ongoing management.
Machine-specific placards built to exact equipment specifications on industrial-grade aluminum.
On-site assessment identifying every deficiency in your current program before your next inspection.
Do not wait until you receive an OSHA citation to discover your annual review records are missing or incomplete.
Schedule Your Annual Audit