OSHA: Response to Query Regarding Consultants Performing LOTO Periodic Inspections

Date First Published on SafetySmart Compliance: September 26th, 2011
Topics: Lockout Tagout | Machine Guarding |

Retrieved from: Occupational Safety & Health Administration


In your letter, you inquired whether it is the intent of OSHA by stating that “an authorized employee” shall conduct periodic inspections in the Lockout/Tagout Standard, to preclude consultants and other third parties from conducting required periodic inspections and audits of a company’s Energy Control Program. Pursuant to 1910.147(c)(6)(i)(A), a periodic inspection must be performed by an authorized employee. For the purpose of complying with the intent of this standard, authorized employee means a qualified person whom the authority and responsibility to perform a specific lockout or tagout inspection has been given by the employer. A qualified person is a person who has been trained and has demonstrated proficiency, in compliance with 1910.147(c)(7), to perform servicing and maintenance on the machine or equipment to be inspected.

Therefore, please note that the function of conducting periodic inspections by consultants would meet the above criteria for the purpose of complying with the lockout/tagout standard requirement.