OSHA LOTO Inspection Checklist: What Auditors Look For
An OSHA auditor walking your floor for a 1910.147 inspection is not reading your safety manual cover-to-cover — they are spot-checking the five things almost every LOTO citation is built on. This checklist is the auditor's view, not an editorial summary: it is the work you have to be able to point to, on the spot, with the document behind it.
Use the boxes below as a self-audit before an inspection. Each row is something an auditor expects to see immediately when they ask — not after a half-day of file retrieval. Where a citation is keyed to a specific 1910.147 paragraph, it is noted in the section heading.
Auditor Checklist — Five Things 1910.147 Inspections Check
1. Energy source identification — every source, every isolation point, every machine
The auditor picks a machine and asks: show me every energy source on this asset and every isolation point for each one. If the list is generic, partial, or stored only in someone's head, it is a citation.
✓Every energy source enumerated. Electrical, mechanical, hydraulic, pneumatic, thermal, chemical, and gravitational — the auditor checks that the procedure covers every source a technician would actually encounter, not only the obvious mains disconnect.
✓Isolation points individually listed. Each source has its own named isolation device and location (breaker number, valve tag, disconnect handle), not a blanket "lock the main."
✓Multi-source equipment has each source mapped. A line with both a 480V disconnect and a 90 psi pneumatic feed gets two isolations, two locks, two verification steps — the auditor expects to see every one of them.
✓Asset numbering matches the physical machine. The procedure references an asset number that is also physically on the machine; auditors cross-check this against the maintenance system.
2. Written energy-control procedure — §1910.147(c)(4)
Auditors do not accept generic templates. They want a procedure written for the specific machine it covers, with the four required pieces clearly visible — scope, purpose, step-by-step procedure, and the authorized-employee list.
✓Procedure is machine-specific. Not a copy-paste of a generic template — it names the asset, the energy sources, and the exact isolation devices for that machine.
✓Scope statement and purpose. A short statement of which equipment the procedure covers and what authorized employees are expected to accomplish.
✓Specific procedural steps. The procedure lists the sequential steps for shutdown, isolation, stored-energy dissipation or restraint, verification, and re-energization — not a single paragraph summarizing all four.
✓Authorized-employee list attached. A current list of employees authorized to perform the procedure, with names or role-based group identifiers.
✓Current revision date and revision history. The auditor checks the document was updated when the machine was modified — a procedure dated 2019 for a line retooled in 2024 is a deficiency.
✓Matches the actual machine configuration today. Procedure, asset, and machine line up on the day of the audit, not on paper from years prior.
3. Employee training records — §1910.147(c)(7)
The auditor will ask: who is authorized to lock this machine out, when were they trained, and what retraining have they had? Without training records traceable to the actual person, the procedure's authorized-employee list is unsupported.
✓Authorized-employee training documented. Each person on the authorized list has a training record showing the date, the procedure or procedure group they were certified on, and the trainer.
✓Affected-employee awareness training. Employees who work in the area but do not perform the lockout have a separate awareness training record covering what they must and must not do during a lockout.
✓Supervisor competency documented. Supervisors with overall responsibility for the lockout program have a record showing they understand the program requirements, not just the procedures.
✓Retraining triggered by changes. Training records show retraining events dated to job changes, procedure revisions, or deviations — not a single one-and-done training class.
4. Periodic inspection records — §1910.147(c)(6)
The auditor asks for the most recent periodic inspection on a one-year-old procedure. If the last inspection on file is older than 12 months, or missing one of the four required data points, the program is out of compliance on its face.
✓At least one inspection per procedure per year. Each written procedure has an inspection dated within the last 12 months.
✓Inspection on file for the prior 12 months. Auditors look back a full year — not just the most recent cycle.
✓Four required data points present. Per 1910.147(c)(6)(i)(D), the record certifies the machine, the date, the employees involved, and the person performing the inspection.
✓Inspector is not the sole user. Per the standard, the inspection is performed by an authorized employee other than the person(s) using the energy-control procedure being inspected — the auditor checks that the inspector and the user are distinct.
✓Deficiencies and corrective actions logged. Any deviation observed during the inspection is recorded with the corrective action taken and the date it was completed.
5. Residual energy verification — §1910.147(d)(6)
Stored and residual energy is the auditor's favorite place to find a gap — a written procedure that walks through isolation but never names how each stored source is bled, blocked, dissipated, or restrained. The auditor also watches for whether the verification is actually performed, not just written down.
✓Procedure names a verification method per energy source. Meter test, mechanical block, gravity-restraint, or dissipation sequence — written into the procedure for every stored / residual energy source, not as a universal "verify zero energy."
✓Verification step is in the procedure itself. Auditors reject an "unwritten expectation" that operators check energy; the step must appear in the procedure as a discrete, named action.
✓Verification is performed before work begins. The auditor watches the authorized employee's behavior during the lockout cycle and confirms the verification step is performed before any work on the machine.
✓Verification is recorded for the audit trail. Where local practice records it (permit, log book, in-product capture), the audit trail shows verification happened, with timestamp and authorized-employee identifier.
If you can point to all five sections above — energy sources, written procedure, training records, periodic inspection record, and the verification step actually being performed — your 1910.147 inspection likely closes clean. If any one of them is shaky on a spot-check, the citation is already in motion. Process IQ can run this checklist against your own energy-control procedures and surface what's missing before an inspector does it for you.
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Bring your energy-control procedures, training records, and most-recent inspection record into Process IQ. The in-product AI walks through the five sections above and flags what an auditor would flag.
OSHA 1910.147(c)(6) requires periodic inspection at least annually for each energy-control procedure. An inspection must be performed more frequently whenever there is a deviation observed, a procedure revision, a machine change, or a job-change that affects authorized employees. A "we do it once a year on a spreadsheet" cadence satisfies the minimum; missing the trigger for an extra inspection is a citation.
Per 29 CFR 1910.147(c)(6)(i)(D), each periodic inspection record must certify four data points: the machine inspected, the date of inspection, the employees involved in the inspection (the inspector and the operator using the procedure), and the person performing the inspection. Missing any one of those is treated as an incomplete record and the deficiency must be logged with a corrective action.
Yes — 1910.147(c)(4)(ii)(A)(2) permits a single written procedure to cover a group of identical machines when the equipment, the energy sources, and the procedural steps are the same and the machines are serviced under the same conditions. As soon as one machine in the group has a different isolation point, energy source, or procedural step, a separate written procedure is required for that machine.
Two things, both required. First, the written procedure must name a verification method (meter test, mechanical block, gravity-restraint, dissipation sequence) per 1910.147(d)(6) for every stored / residual energy source — not a blanket "verify zero energy." Second, the verification must be observable: an authorized employee performs the verification step before work begins, and the result is captured in the audit trail with a timestamp. Unwritten expectations fail the inspection.