Annual Lockout Tagout Audit: OSHA Requires It. We Make It Easy.

The annual inspection under (c)(6) is one of the three most-cited requirements in the LOTO standard, alongside written procedures and training. It is the one OSHA asks for first, and the one facilities most often cannot produce on the day of the visit. We run the audit for you, or your team runs it inside LockStep with the written certification generated automatically.

Quick answer: OSHA 1910.147(c)(6) requires a periodic inspection of each energy control procedure at least annually, performed by an authorized employee not using the procedure being inspected. An annual LOTO audit satisfies that requirement, confirms the written procedures still match the equipment, and documents the inspection the way an inspector expects to see it.

Set Up Your Annual Audit Start with a Gap Analysis

The Requirement

The Annual LOTO Review Is Not Optional

1910.147(c)(6) requires employers to conduct a periodic inspection of each energy control procedure at least annually. The purpose: confirm the procedure is current, accurate, and being followed correctly.

An authorized employee other than the one using the procedure must perform the inspection. 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. That written certification is the specific requirement under (c)(6)(ii).

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.

Machine-specific lockout tagout procedure document with primary and associate stations marked, the format the (c)(6)(ii) annual certification reviews against current equipment state

What Can Change Between Reviews

Equipment is modified or repaired, changing energy sources or isolation points
New machines are added without corresponding LOTO procedures
Employees change roles, thinning trained headcount on specific procedures
Placards are damaged, removed, or become illegible
Work tasks evolve and the documented procedure no longer matches actual practice
Regulatory standards are updated, triggering procedure revisions

The Risk of Skipping or Under-Documenting the Annual Review

Beyond the direct OSHA citation for missing records, an undocumented annual review 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 enforcement action significantly.

How We Deliver It

Two Ways to Complete Your Annual LOTO Audit

Pick what works for your team. Both paths result in compliant, audit-ready documentation.

Full-Service Audit (We Do It)

Our team runs the entire review for you

Certified specialists perform the on-site procedure review
Every machine procedure checked against current equipment state
Employee review sessions conducted with authorized employees
Gaps and discrepancies identified and documented
Placards and documentation updated where needed
Written certification provided meeting all OSHA requirements under (c)(6)(ii)
Results stored in LockStep for future reference and audit access

Best for facilities that want no internal resource burden and the confidence of an independent certified review.

Schedule Full-Service Audit

LockStep Software (Your Team Does It)

Our offline-first audit application, your team drives the review

Works offline on the plant floor, syncs when back online
Mobile and tablet capture at the point of use, no clipboard transcribing
All procedures and equipment data loaded into LockStep
Step-by-step audit workflow walks your team through the review
Automated change tracking flags what has shifted since the last review
Gap identification surfaces procedures that no longer match current equipment
Compliant 1910.147(c)(6)(ii) certification generated automatically
Multi-site compliance dashboard for corporate EHS visibility
Historical audit trail accessible for any OSHA inspection

Best for facilities with capable internal EHS teams that want to own the process but need a structured, compliant system to do it right. See the full LockStep overview.

Get LockStep Access

Access placard procedure document for a robotic ring gear temper cell, the kind of equipment-specific record annual audits review for currency and accuracy

One pattern we see repeatedly: On a recent audit at an automotive supplier in southeast Michigan, the facility had every procedure written, every operator trained, and a binder of annual inspection records going back four years. The problem: the inspections had been signed off by the same person who wrote the procedures, which is a (c)(6)(ii)(C) violation in itself. We caught it before their next OSHA inspection did. This is one of the most common under-the-radar failures on otherwise well-run programs.

LockStep Software

One System for Your LOTO Documentation and Audit History

LockStep is our compliance management platform built for lockout tagout programs. It replaces spreadsheets, shared drives, and paper binders with one system that keeps your program accurate, current, and audit-ready at all times.

Every LOTO procedure stored in a single searchable system
Equipment profiles link each procedure to the physical machine
Change log tracks every update to every procedure over time
Annual audit workflow with built-in certification documentation
Gap identification flags procedures needing review or update
Compliance dashboard showing real-time program status by machine, area, and facility
Multi-facility support for organizations with multiple locations
Access controls so the right people see the right procedures

1

Centralized system for all LOTO docs

0

Spreadsheets or binders required

Annual

Audit workflow built in

Always

Audit-ready documentation

Common problem we solve: EHS managers at multi-facility organizations often have no idea if every plant 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

What the Annual LOTO Audit Covers

The review goes beyond checking a box. Every machine procedure is validated against current equipment conditions and workforce changes.

Procedure Accuracy Review

We compare each documented energy control procedure against the actual current state of the equipment. We identify modifications, repairs, or additions since the last review and update the procedures to match.

Employee Review Sessions

OSHA requires the annual inspection to include a review of the procedure with each authorized employee who uses it. We run these sessions and document participation to satisfy the certification requirement.

Placard and Sign Condition Check

We inspect physical placards for legibility, placement, and continued accuracy. We flag damaged, removed, or outdated placards for replacement.

New Equipment Identification

We flag equipment added since the last review that does not yet have documented LOTO procedures. Getting new machines into the program before the next inspection is a critical outcome of every annual review.

Written Certification

Every annual inspection is documented with the required OSHA certification elements: machine name, inspection date, employee names, and inspector identity. Stored in LockStep and available immediately if requested during an audit.

Compliance Gap Summary

The audit closes with a summary of findings. Which procedures were updated. Which equipment was added to the program. Any items requiring follow-up action before the next review cycle.

Full-Service Option

Want Us to Own the Entire LOTO Program?

The annual audit is one component of a complete lockout tagout program. For facilities that want to offload the whole compliance burden, we offer a full-service program covering everything from initial setup through ongoing management.

Initial gap analysis to establish baseline compliance status
Custom placards designed, produced, and installed for every machine
Written energy control program developed and documented
LockStep software set up with all procedures and equipment data
Employee training on current procedures
Annual audit conducted each year with full documentation under (c)(6)(ii)
Placard and documentation updates when equipment changes
Ongoing support for new equipment integration

Ask About the Full Program

Related Services

Custom LOTO Placards

Machine-specific placards built to exact equipment specifications on industrial-grade aluminum.

LOTO Gap Analysis

On-site assessment identifying every deficiency in your current program before your next inspection.

Frequently Asked Questions

Annual LOTO Audit Questions, Answered

What does OSHA 1910.147(c)(6) require every year?

A periodic inspection of each energy control procedure at least annually, performed by an authorized employee other than the one using the procedure, including a review with each employee who uses it, and certified in writing.

What must the written certification include?

Under (c)(6)(ii): the machine or equipment inspected, the date of the inspection, the employees included in the inspection, and the name of the authorized employee who performed it.

Do informal annual reviews satisfy OSHA?

No. An undocumented review does not meet the standard. When OSHA asks for annual inspection records, only the written certification satisfies (c)(6)(ii), and its absence after an incident signals systemic non-compliance.

How can we complete the annual LOTO audit?

Two ways: our specialists run the full-service audit on site, or your team runs it inside LockStep audit software, which generates the written certification automatically. Both paths produce compliant, audit-ready documentation.