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Case Study 4:
Multiple Energy Control Procedures
Incorrect. Not in this case.
The periodic inspection must be conducted by an authorized
employee other than the one who implements the procedure. This authorized
employee is designated by the employer as an inspector. He or she must observe
the procedure being implemented by a representative number of authorized
employees and must talk with all other authorized employees, even though they
may not be implementing the energy control procedure.
Of the 130 energy control procedures, the employer is only
required to perform a periodic inspection on each of the unique energy control
procedures. The inspector or inspectors performing the periodic inspection must
observe the implementation of each of the 51 energy control procedures by
a representative number of authorized employees. For each procedure, the
inspector must also conduct a review with all other authorized employees
involved in implementing the energy control procedure to review the procedure
and their responsibilities under it. Because the employer's inspection protocol
does not include a review of each separate procedure with all authorized
employees who may have responsibilities under it, the protocol fails to comply
with section
1910.147(c)(6)(i). Observing only a single authorized employee implementing
each lockout procedure, rather than a representative number of employees, also
does not meet the intent of the standard.
Moreover, the employer's use of group meetings to review the
energy control procedures where implementation is not actually inspected also
falls short. This is because the implementation of each separate lockout
procedure may be observed by a representative number of employees.
For more information: Refer to the part
1910.147(c)(6)(i) of the Lockout/Tagout standard.
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