The annual inspection is the single most cited sub-requirement under 1910.147. Not the written procedures. Not training. The annual inspection under (c)(6). 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.
The Requirement
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.
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. 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.
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
Pick what works for your team. Both paths result in compliant, audit-ready documentation.
Our team runs the entire review for you
Best for facilities that want no internal resource burden and the confidence of an independent certified review.
Our auditing platform, your team drives the review
Best for facilities with capable internal EHS teams that want to own the process but need a structured, compliant system to do it right.
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
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.
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 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
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 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.
Physical placards are inspected for legibility, placement, and continued accuracy. Any placards that have been damaged, removed, or become outdated are flagged 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. Stored in LockStep and available immediately if requested during an audit.
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
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.
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 OSHA asks for the records to find out they are missing or incomplete.
Schedule Your Annual Auditor call (847) 232-6067