A program on paper does not protect anyone. The standard also requires training, regular inspections and an employer who keeps both up to date. This lesson ties the pieces together and shows what you can do.
Training
Under 29 CFR 1910.147(c)(7), the employer must train every employee covered by the program.
- Authorized employees must be trained to recognize hazardous energy sources, the type and magnitude of the energy at work, and the methods of isolating and controlling it.
- Affected employees must be instructed on the purpose and use of the energy control procedure.
- Other employees must be instructed about the procedure and the prohibition on restarting or re-energizing locked or tagged machines.
- When tagout is used, employees must also be trained on the limits of tags: a tag is a warning, not a physical restraint, it must not be removed without authorization, and it must never be bypassed or ignored.
The employer must certify that training was given and is kept current. The certificate records each employee's name and the dates of training.
Retraining
There is no fixed interval in the standard. Instead, the employer must retrain employees when:
- their job assignment changes;
- there is a change in machines, equipment or processes that creates a new hazard;
- the energy control procedure changes;
- an inspection shows deviations or gaps, or the employer has reason to believe the procedure is not being followed.
Retraining must re-establish proficiency and be certified too. Many employers also repeat training each year as good practice, but the standard sets no date.
Periodic inspection
At least once every year, the employer must inspect each energy control procedure.
- The inspection is done by an authorized employee other than the ones using the procedure being inspected.
- It checks that the procedure and the requirements of the standard are being followed. Any deviation or gap must be corrected.
- The inspector reviews responsibilities with each authorized employee. Where tagout is used, the review also includes each affected employee.
- The employer certifies the inspection: it records the machine, the date, the employees included and the person who did it.
What the employer must still do
This course teaches general awareness. The employer remains responsible for:
- machine-specific procedures for every piece of equipment covered;
- locks, tags and hardware for each worker who needs them;
- training and authorization of the employees who will lock out;
- practical, hands-on training at the actual machines;
- inspections and records.
What you can do
- Learn which group you are in: authorized, affected or other.
- Never start, move or work on a machine that has a lock or tag.
- Ask if you are not sure whether a task needs lockout.
- Report missing locks, damaged tags, unmarked switches, or a procedure that cannot be followed.
- Speak up if you are told to skip the procedure. The OSH Act protects workers who raise safety concerns from retaliation.
- If the problem is not fixed, you may contact OSHA or your state's program.
What to remember
- Training depends on your role; retraining follows changes and problems.
- Procedures are inspected at least annually, by someone who does not use them.
- Training and inspections are certified in writing.
- This course does not replace your employer's machine-specific training.