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Last Updated: November 2026
At least annually. 29 CFR 1910.147(c)(6)(i) requires the employer to conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of the standard are being followed. The inspection must be performed by an authorized employee other than the one or ones using the procedure being inspected, and it must be conducted to correct any deviations or inadequacies identified. Where lockout is used it must include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the procedure being inspected. The employer then certifies the inspection, identifying the machine or equipment, the date, the employees included, and the person who performed it.
The exact requirement
1910.147(c)(6)(i) reads: “The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.” Four subparagraphs then say how:
| Paragraph | Requirement |
|---|---|
| (c)(6)(i)(A) | The inspection “shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.” An employee cannot inspect their own lockout. |
| (c)(6)(i)(B) | The inspection “shall be conducted to correct any deviations or inadequacies identified.” Observation alone does not discharge it; the finding has to be fixed. |
| (c)(6)(i)(C) | Where lockout is used, the inspection must include a review between the inspector and each authorized employee of that employee’s responsibilities under the procedure being inspected. |
| (c)(6)(i)(D) | Where tagout is used, the review covers each authorized and affected employee, and must also cover the elements set out in (c)(7)(ii) — the additional training limitations that apply to tagout systems. |
The tagout case is the stricter one, and that catches people out. Tagout pulls affected employees into the review as well as authorized employees, because a tag is an information device and its effectiveness depends on everyone who sees it understanding what it means.
The inspection is per procedure, not per facility
The obligation attaches to “the energy control procedure”, and the certification under (c)(6)(ii) has to identify “the machine or equipment on which the energy control procedure was being utilized”. A plant that has written twelve machine-specific energy control procedures owes twelve inspections, not one plant-level audit with twelve lines in it.
This is the single most common gap we see in LOTO program files. The annual audit exists, it is dated, it names an inspector, and it covers the program rather than the procedures, so there is no record tying an inspection to the press, the conveyor or the mixer. A compliance officer asking for the periodic inspection of a specific machine’s procedure has nothing to read.
There is a narrowing in the other direction worth knowing: (c)(4)(i) carries an exception that lets an employer skip documenting a procedure for a particular machine, but only where all eight listed elements exist, including a single readily identifiable energy source, no potential for stored or residual energy, a single lockout device achieving the locked-out condition under the exclusive control of the authorized employee doing the work, no hazard created for other employees, and no prior accident involving unexpected activation during servicing. Eight conditions is a high bar, and most equipment fails at the stored-energy element.
What the certification has to contain
1910.147(c)(6)(ii) names four data elements: the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection. “Employees included” is plural and it is not the same list as the employees who use the procedure. If you have five authorized employees on a procedure and the inspector reviewed responsibilities with three of them, the certification should say three, and you owe the other two.
Three annual-looking things that are not the same obligation
| Obligation | Paragraph | Interval |
|---|---|---|
| Periodic inspection of the energy control procedure | (c)(6)(i) | At least annually. A real calendar interval. |
| Employee retraining | (c)(7)(iii)(A)–(B) | No interval. Triggered by a change in job assignments, a change in machines, equipment or processes presenting a new hazard, a change in the energy control procedures, or when a periodic inspection reveals (or the employer has reason to believe there are) deviations from or inadequacies in an employee’s knowledge or use of the procedures. |
| Documented energy control procedure | (c)(4)(i) | No interval. A standing requirement to develop, document and use the procedure, with the eight-element exception noted above. |
Note the link between rows one and two: (c)(7)(iii)(B) makes retraining a consequence of the periodic inspection. An inspection that finds a deviation and does not produce retraining has not finished.
There is no three-year interval in 1910.147
Several training sites state that the LOTO program review must happen at intervals of three years or less. No such interval appears anywhere in 1910.147. The three-year figure belongs to a different standard: 29 CFR 1910.178(l)(4)(iii), which requires an evaluation of each powered industrial truck operator’s performance at least once every three years. If a source gives you three years for lockout/tagout, it has crossed the forklift standard into the LOTO answer.
Where VR fits, and where it does not
Humulo’s position: the periodic inspection is an observation duty, and you cannot simulate your way out of it. Somebody has to watch a specific procedure being used on specific equipment and sit down with the authorized employees who use it. No software discharges (c)(6).
Where a simulation earns its place is the retraining the inspection triggers. When an inspection finds an authorized employee who verified isolation incorrectly or missed a stored-energy step, (c)(7)(iii)(B) requires retraining that reestablishes proficiency. Taking that employee through the isolation sequence in VR, repeatedly, on the energy types your equipment actually has, produces more repetitions in an afternoon than a year of real servicing events will. It also generates a dated record pointing back at the inspection finding, which is the connection most program files are missing.
Frequently asked questions
How often must employers review their energy control procedures?
At least annually, under 29 CFR 1910.147(c)(6)(i).
Who is allowed to perform the periodic inspection?
An authorized employee other than the one or ones using the energy control procedure being inspected, per (c)(6)(i)(A). It can be an internal employee; the standard does not require a third party.
Is one annual program audit enough for the whole facility?
No. The inspection is of the energy control procedure, and the certification under (c)(6)(ii) must identify the machine or equipment the procedure was used on. Multiple machine-specific procedures mean multiple inspections.
What is the difference between the periodic inspection and retraining?
The periodic inspection at (c)(6) is annual. Retraining at (c)(7)(iii) has no interval and is triggered by changes in assignments, machines, processes or procedures, or by deviations and inadequacies, including those the inspection itself reveals.
Does the review have to include talking to employees?
Yes. Where lockout is used, (c)(6)(i)(C) requires a review between the inspector and each authorized employee of that employee’s responsibilities. Where tagout is used, (c)(6)(i)(D) extends that to each authorized and affected employee and adds the (c)(7)(ii) elements.
Does 1910.147 require a review every three years?
No. The standard says at least annually. The three-year interval belongs to the powered industrial truck standard at 1910.178(l)(4)(iii).
Related answers and pages
Source: 29 CFR 1910.147, The control of hazardous energy (lockout/tagout), paragraphs (c)(4), (c)(6) and (c)(7), as published by OSHA. Paragraph text verified against osha.gov on 4 November 2026.
