OSHA 1910.147 requires an inspection of each energy control procedure at least annually. The inspector must be an authorized employee who does not use the procedure being checked, deviations must be corrected, and the employer must certify the result with the machine, date, employees and inspector named.
Before you start
Gather the written procedure for each machine, the list of authorized and affected employees, and the training records. Pick an inspector who is not a regular user of that procedure. The standard demands that independence, because people who follow a procedure daily tend to see what they expect.
The checklist
Procedure is current.
- It names the machine and the energy sources, including stored energy.
- It lists shutdown, isolation, device placement, removal and transfer steps.
- It includes a step that tests the isolation to confirm the machine cannot start.
- It matches the machine as it is now, after any modification.
Hardware is present and fit.
- Locks, tags and related hardware are available at the point of use.
- Devices are standardised and identify the person who applied them.
- Devices are used only for energy control.
- Tags are legible, durable and attached with a suitable non reusable fastener.
Review with people.
- For lockout, the inspector reviews the procedure with each authorized employee.
- For tagout, the inspector reviews it with each authorized and affected employee, including the limits of tags.
Training is on record.
- Each authorized employee has recorded training with name and dates.
- Retraining has happened after job changes, new hazards from machine or process changes, procedure changes, or inspection findings.
Findings closed.
- Every deviation or gap has an owner and a fix date.
What to record
The certification identifies the machine or equipment, the date of inspection, the employees included and the person who did it. Keep it where an inspector can find it.
Beyond the paperwork
A walk through the plant often finds more than the form does. Look for old padlocks left on equipment, shared keys, tags tied on with reusable ties, and machines whose controls were changed without updating the procedure.
If a machine now has a remote start, a networked controller or a scheduled routine, check that the procedure lists that as an energy path and that someone who understands the control system was consulted. That is where safety and IT meet, and it is a good place to find gaps before an incident does.
After the inspection
Fix findings in order of risk. A missing isolation test step or a lock that can be removed with ordinary tools is more urgent than a faded tag. Tell the people who were interviewed what was found and what changed, because a procedure that nobody hears about again gets ignored. If a machine or process has changed enough to create a new hazard, retrain the affected people, and record it with names and dates.
Schedule the next inspection while you still remember what this one turned up, and give it to a different inspector where you can. A fresh pair of eyes catches the habits the last one stopped noticing.
Quick check
Can the person who writes the procedure inspect it?
The standard says the inspector must be an authorized employee other than the one using the procedure under inspection. Check your own arrangement against the text.
How often must it be done?
At least annually, according to the standard.
Sources
This is general information, not legal advice.
Last reviewed: 19 October 2026.
