For work covered by federal OSHA’s lockout/tagout standard, the energy control program must include procedures, employee training and periodic inspections. 29 CFR 1910.147(c)(1)
Start your records review with two questions: can you produce the employer’s training certification, and can you produce the periodic-inspection certification?
- The training certification must include each employee's name and dates of training.
- Authorized employees, affected employees, and all other employees whose work operations are or may be in an area where energy control procedures may be used have different training requirements under the rule.
- Retraining is required for authorized and affected employees after a change in their job assignments, a change in machines, equipment or processes that presents a new hazard, or a change in the energy control procedures, and also when an inspection reveals, or the employer has reason to believe, that there are deviations from or inadequacies in an employee's knowledge or use of the procedures; the at-least-annual schedule applies to the procedure inspection.
- The inspection certification identifies the machine or equipment, inspection date, employees included and inspector.
Source: 1910.147(c)(6) and (c)(7).
What belongs in the training certification?
The employer must certify that employee training has been accomplished and is being kept up to date. The certification must contain each employee’s name and dates of training. 1910.147(c)(7)(iv)
Practical recommendation: Make the record understandable without relying on the person who filed it. Alongside the required fields, consider documenting the employee’s training role, the procedure covered, the procedure revision, the trainer and the reason for retraining. Treat these as recommended supporting details, not extra certification fields specified in (c)(7)(iv).
Match the training to the employee’s role
Authorized employees must receive training on recognizing applicable hazardous energy sources, the type and magnitude of energy available in the workplace, and the methods and means needed for isolation and control. Affected employees must be instructed in the purpose and use of the energy control procedure. Other employees whose work operations are or may be in an area where these procedures may be used must receive instruction about the procedure and the prohibition on attempts to restart or reenergize locked-out or tagged-out machines or equipment. 1910.147(c)(7)(i)(A)-(C)
When tagout systems are used, training must also address the limitations of tags listed in (c)(7)(ii). 1910.147(c)(7)(ii)
Practical recommendation: Use separate role labels in your training matrix, and identify the relevant procedure in the supporting record.
When is retraining required?
For authorized and affected employees, retraining is required when their job assignments change, when machines, equipment or processes change in a way that presents a new hazard, or when energy control procedures change. Additional retraining is required 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 energy control procedures. Retraining must reestablish proficiency and introduce new or revised control methods and procedures as necessary. 1910.147(c)(7)(iii)(A)-(C)
Practical recommendation: Include a training review in your process for changing equipment, job assignments or procedures. Record the resulting training dates and connect any retraining to the change or finding that prompted it.
Keep the periodic-inspection evidence distinct
The employer must inspect the energy control procedure at least annually to ensure the procedure and the standard’s requirements are being followed. An authorized employee other than the employees using the procedure being inspected must perform that inspection. The inspection must be conducted to correct any deviations or inadequacies identified. 1910.147(c)(6)(i)-(i)(B)
For lockout, the inspection includes a review between the inspector and each authorized employee of that employee’s responsibilities under the procedure being inspected. For tagout, the inspection includes a review between the inspector and each authorized and affected employee of that employee’s responsibilities under the procedure being inspected and of the tag limitations in (c)(7)(ii). 1910.147(c)(6)(i)(C)-(D)
| Evidence | What the cited rule requires | Recommended filing practice |
|---|---|---|
| Training certification, (c)(7)(iv) | Certify training is accomplished and kept current; include each employee’s name and training dates. | Link the certification to the relevant procedure and training role. |
| Periodic-inspection certification, (c)(6)(ii) | Certify inspections were performed; identify the machine or equipment, inspection date, employees included and inspector. | Keep the inspection findings and resulting retraining references together. |
Source: 1910.147(c)(6)(ii) and (c)(7)(iv).
Practical recommendation: Keep both certifications easy to retrieve. Do not use an annual training attendance sheet as a substitute for documenting the required procedure inspection. See our guide to organizing audit-ready training records.
Retention and day-to-day filing
The training-certification paragraph does not prescribe a fixed retention period. 1910.147(c)(7)(iv)
Practical recommendation: Document a retention policy after checking applicable requirements, and assign an owner to review records when procedures or duties change. Read our OSHA training-records overview before applying a retention rule from another standard to LOTO records.
TrainGrid by Solvesoft lets permitted users attach a certificate or other file to a training record. TrainGrid user guide