Periodic Reviews

 In 2022, Tip of the Week

When we say “periodic review” what do you think of? Do you think of employee performance reviews? While we are thinking of performance reviews, we are thinking more about confined space permits and lockout/tagout (LOTO) procedures. Did you know that these things have required annual reviews? They do.

29 CFR Part 1910.146(d)(13) & (14) and 1910.147(c)(6) require reviews, at least annually, to see how these programs are working for you. Does the process of completing a confined space permit do what it should do in providing a safe entry into the confined space? Does the procedure for completing a LOTO before working on equipment ensure that employees are not in contact with hazardous energy?

The confined space regulation has some specific requirements for a review. You are required to review both the confined entry procedures when something potentially unsafe happens and review your permits annually. In subparagraph (d)(14), it says that the employer must “[r]eview the permit space program, using the canceled permits retained … within 1 year after each entry and revise the program as necessary, to ensure that employees participating in entry operations are protected from permit space hazards.” You can see the regulation here: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146

The LOTO regulation also has some details of what is required. The review must be performed by an “authorized employee.” Who is the authorized employee? It is anyone who does the LOTO to service, repair or work on equipment as described in the regulation. In fact, the regulation says that “…the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure being inspected.…” If you want to see the regulation, you can find it here: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147

SCM recommends you take the results of your reviews and use them as training tools for your employees. You can make copies of the confined space permits and/or LOTO procedures. Ask your employees, the people that are really using them, if these are effective, and what improvements they would make. They are the ones that are entering the permit-required confined space and/or working on equipment where there is a potential for contact with hazardous energy if the LOTO is not performed correctly. They may be able to see something or have experienced something that you were not aware of.

This could be done in a group, or if you have experienced workers who seem to be shy or hesitant to speak up in a group, you can approach them privately. By listening to knowledge they have gained through years of experience, you may not only gain further information, you also satisfy the LOTO regulation’s requirement to involve the authorized employees actually doing the job. You can then take what you have learned, use it to update the programs and procedures, and use it as learning moments for your employees.

Remember to document both the review process and any training that occurs. It will prepare you for any OSHA inspector asking to see records.

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