OSHA 1910.147(c)(6) requires a documented annual LOTO audit on every machine-specific procedure. Most facilities still run that audit on paper. Clipboards on the floor. Notes transcribed into Excel back at the office. Rollups rebuilt every cycle. LockStep replaces that workflow with one mobile-first application that captures the audit at the point of use, works without wifi, and generates the written certification automatically.
The Problem
The annual audit under 1910.147(c)(6) is the most-cited sub-requirement in lockout tagout. Not because facilities ignore it. Because the workflow most facilities use makes it almost impossible to keep current.
A walkthrough starts with a clipboard. Findings get scribbled in pen. Photos live on someone's phone. At the end of the day everything has to be transcribed into a spreadsheet. The spreadsheet has to be rolled up across cells, areas, and facilities. The certifications have to be printed, signed, scanned, and filed. Somewhere in that process, half the audit gets lost.
The result OSHA sees: A facility that knows it ran the audit but cannot produce the certification for the specific cell the compliance officer just asked about. The certification is the citation point. (c)(6)(ii) requires the written record, not the memory of the inspection.
The Solution
Built specifically for the way LOTO audits actually run on a manufacturing floor. Offline-first because the floor rarely has wifi. Mobile-first because clipboards do not survive a wash-down line. Automatic certifications because the documentation is the point of the regulation.
Built offline-first. Download the audit package to the device before the walkthrough, capture every finding on the floor without a network connection, and sync when the device is back in coverage. No lost data when the wifi drops.
Phones, tablets, and rugged industrial handhelds. The auditor captures findings, photos, and authorized employee interviews at the cell, not transcribed back at a desk three hours later.
Every completed audit produces the written certification required by 1910.147(c)(6)(ii). Machine identifier, inspection date, employees included, inspector name, all populated from the audit record itself. Export as PDF on demand.
Every change to every procedure, every audit cycle, every certification, captured in a tamper-evident audit trail. If an inspector asks for the history on a specific cell, you produce it in seconds.
Corporate EHS teams see audit status across every facility from one dashboard. Which plants are current. Which are overdue. Which had findings that have not been closed. Real visibility, not a quarterly spreadsheet refresh.
When the inspector asks, you do not scramble. Generate the full certification packet for a specific cell, area, or facility on demand. PDF or CSV. Ready to hand over.
Inside LockStep
The application is built around the way the audit has to be performed under 1910.147(c)(6). Every step is captured. Every required field is enforced. Nothing gets skipped because the form would not let you skip it.
The audit opens with the cells assigned to today's walkthrough. Each cell loads the current procedure, the equipment registry, the last audit's findings, and any open corrective actions. The auditor works through the cell with the regulation in view.
1910.147(c)(6)(i)(C) requires the audit to include a review with each authorized employee who uses the procedure. LockStep enforces the interview step with a structured prompt set, captures the responses, and ties them to the cell's certification.
Tap the camera in the cell view, take the photo, the image is attached to the audit record with timestamp, geolocation, and cell ID. No personal phone roll. No transcription. No lost evidence.
Findings raised on the audit floor become tracked corrective actions in the system. Each one gets an owner, a due date, and a verification step. The next audit cycle opens with the prior findings already loaded for closure check.
Every cell, every procedure, every authorized employee, every energy source, in one searchable registry. When equipment is added or modified, the registry update flags the affected procedures and queues them for review.
Real-time view of program status. How many procedures are current, how many are overdue, how many cells have open findings. Filterable by site, area, or shift. Built for corporate EHS visibility without manual rollup work.
Why It Works
LockStep started as an internal tool we built for our own service engagements. We were running full-service annual audits at large multi-site manufacturers and the paper-and-Excel friction was eating half the engagement time. The auditors wanted a faster way to capture. The corporate EHS teams wanted a real rollup view. The plant managers wanted to know which cells were current without asking three people.
We built the application around what an OSHA compliance officer actually asks for during an inspection. The four required elements of (c)(6)(ii). The interview verification. The point-of-use photo evidence. The version history on procedures that changed mid-cycle. Every field in LockStep maps to an enforcement standard or a finding pattern we have seen during a real inspection.
Now we use LockStep on every engagement, and the same application is available to our clients to run their own audits in between our visits.
Most-cited LOTO sub-clause in OSHA enforcement: 1910.147(c)(6)
Required elements in every written certification under (c)(6)(ii)
Sheets of paper required to run an audit in LockStep
Plant floor capture, no network required
The friction point most facilities recognize: The annual audit is not skipped. It just does not get documented to the standard (c)(6)(ii) actually requires. LockStep enforces the documentation so the workflow itself is the compliance.
Who LockStep Is Built For
Corporate EHS teams managing audit cadence across multiple plants. The rollup dashboard is the difference between knowing your program status and assuming.
At fifty cells the paper-and-Excel workflow starts to crack. At a hundred it breaks. LockStep keeps the cadence even when the program scales.
Most industrial sites do not have plant-floor wifi worth trusting. Offline-first capture removes the network dependency entirely.
If your team has the bandwidth to run audits but needs a structured system to enforce the (c)(6)(ii) documentation, LockStep is the path most facilities prefer.
If an inspection just found gaps in your annual audit documentation, LockStep is the fastest way to demonstrate corrective action and re-establish the cadence.
Workers comp and liability carriers increasingly ask for audit evidence. LockStep produces inspector-ready packets on demand.
Frequently Asked Questions
An offline-first mobile and tablet application that replaces paper LOTO audit workflows. It walks an authorized employee through the OSHA 1910.147(c)(6) annual periodic inspection cell by cell, captures findings and photos at the point of use, and generates the written certification required under (c)(6)(ii) automatically. It works without wifi on the plant floor and syncs when the device is back online.
Yes. LockStep is built offline-first because manufacturing floors rarely have reliable wifi. The auditor downloads the audit package to the device before the walkthrough, captures every finding, photo, and signature on the floor without a network connection, then syncs the complete audit when the device returns to coverage. The certification is preserved either way.
Every audit completed in LockStep generates a written certification containing the machine identifier, the date of inspection, the names of the authorized employees included in the review, and the name of the authorized employee performing the inspection. Those are the four elements (c)(6)(ii) requires. The certification is exportable as a PDF and retained in the audit history for inspector access on demand.
LockStep replaces the paper-and-Excel workflow that most facilities still use for annual LOTO audits. That workflow typically involves a clipboard on the floor, handwritten notes, manual transcription into a spreadsheet, manual rollup of multiple cells or facilities into a master tracker, and a binder of signed certifications kept somewhere on a shared drive. LockStep collapses all of that into a single application with one auditable record per cell per year.
LockStep is included complimentary with most LOTO Compliance service engagements, including gap analysis, custom placard work, and full-service annual audits. Stand-alone licensing is available for facilities that already have their LOTO program built and want only the audit software. Pricing depends on number of cells and number of facilities. Quotes are provided after the free walkthrough.
Yes. Corporate EHS teams use the LockStep dashboard to see annual audit status across every facility in real time. Each plant runs its own audits in the field; corporate sees which plants are current, which are overdue, and which had findings that have not been closed. The multi-site rollup is one of the most common reasons large manufacturers choose LockStep.
No. LockStep can be licensed stand-alone for facilities that have their own placard provider or run their LOTO program internally. The audit software does not require the placards on your floor to be ours. It does require an equipment registry, which we help build during onboarding if you do not have one already.
Related Services
Full-service annual audits run by our certified specialists on your floor, or self-service audits run by your team inside LockStep. Either path produces the (c)(6)(ii) certification on file.
See Annual Audit service →On-site walkthrough that maps every gap in your current LOTO program to the sub-clause of 1910.147. The gap analysis is often the first engagement, and LockStep is the system that captures and tracks the fixes.
See Gap Analysis service →Machine-specific placards built to your exact equipment. Industrial coated aluminum. Each placard ties to a procedure record in LockStep with optional QR code linking to the digital procedure.
See Custom Placards service →Tell us a little about your facility and we reach out within one business day. If you want LockStep as part of a service engagement, mention that. If you want stand-alone licensing, mention that too. We will tell you which path fits.
The (c)(6)(ii) certification is the citation point. LockStep removes the friction that makes it the most-missed sub-requirement in 1910.147.
Start With a Free Walkthroughor call (847) 232-6067