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Annual LOTO Audits That Satisfy 1910.147(c)(6) on Inspection

OSHA requires a documented annual review of every machine-specific LOTO procedure. The certification has to name the machine, the date, the employees involved, and the person who performed the inspection. Most facilities know the rule. Most facilities also miss the documentation. We close that gap two ways: we run the audit for you, or your team runs it inside LockStep auditing software.

1910.147(c)(6) Compliant Written Certification Full-Service or LockStep

Set Up Your Annual Audit See Gap Analysis

The Regulation

1910.147(c)(6) in Plain Language

OSHA 1910.147(c)(6) requires the employer to conduct a periodic inspection of energy control procedures at least annually. The inspection has to verify that the procedure is being followed as written and that authorized employees know their responsibilities. The result has to be a written certification identifying the machine, the date, the employees, and the person performing the inspection.

It is not optional. It is not a recommendation. And the moment a compliance officer asks for the certification and the facility cannot produce it, that is a citation regardless of how good the procedures themselves are.

Per-cell verification of the written procedure against actual practice
Interview with at least one authorized employee per procedure
Review of training records and authorization roster
Documented findings and corrective actions where deficiencies are noted
Written certification signed and dated, retained on file

Two Ways to Get It Done

Full-service audit. We come on-site. We walk every cell, verify procedures against practice, interview authorized employees, and deliver the written certification. You file it. Inspector finds it.

LockStep self-audit. Your team runs the audit inside LockStep auditing software. The software walks them through each cell, captures findings, and generates the written certification automatically.

Pick the Path That Fits

LockStep Robot Cell Audit Software

Offline-First Audits Built for Robotics Floors With No Wifi

If your team has the bandwidth to run audits internally, LockStep is the path most facilities prefer. It is offline-first because plant floors rarely have reliable wifi, mobile-first because clipboards do not survive a cell walkthrough, and built specifically around the way 1910.147(c)(6) audits work on robotics floors with multi-source energy.

Works Offline

Download the audit package to the tablet before the walkthrough. Capture every finding, photo, and interview on the floor with no network. Sync when the device is back in coverage. The certification is preserved either way.

Cell-by-Cell Walkthrough

Software walks the auditor through each robot cell in your facility. The current procedure displays alongside the verification questions. Multi-source energy isolation is enforced cell by cell, not skipped at the workflow level.

Authorized Employee Interview Script

Standardized interview prompts that satisfy the (c)(6)(i)(C) verification step. Responses captured directly into the audit record at the cell, not transcribed back at a desk later.

Automatic Certification

Once the cell is complete, the software generates the written certification with the four required fields under (c)(6)(ii): machine identifier, inspection date, employees included, inspector name. Sign, file, done.

Multi-Site Rollup

Corporate EHS teams see audit status across every facility from one dashboard. The rollup is the difference between knowing your program status and assuming.

OSHA-Ready Export

Every cell's audit history lives in one place. Pull a single procedure or the whole facility for an inspector or insurance carrier in seconds, as PDF or CSV.

LockStep is included complimentary with most service engagements. Stand-alone licensing available.

FAQ

What Manufacturers Ask About the Annual Audit

Does every cell need its own audit, or can I do one annual review for the whole facility?

Per cell. The certification has to identify the machine specifically. A facility-wide attestation does not satisfy 1910.147(c)(6). It is one of the most common citation grounds we see during follow-up inspections.

What happens if we miss a year?

The procedure is technically out of compliance from the missed anniversary forward. Get the audit done immediately, document the gap, and resume the annual cadence. If an inspector asks, an honest record of a one-year miss followed by corrective action is better than a falsified certification.

Can the same person who wrote the procedure run the audit?

Yes, but they cannot be the only authorized employee for that procedure. The audit has to verify that authorized employees know their responsibilities, which means interviewing someone other than the procedure author.

Do you handle the audit for facilities outside Michigan?

Full-service audit is West Michigan focused with on-site availability across the broader Midwest. LockStep self-audit works anywhere the facility has internet. Many multi-state manufacturers use both: full-service at the headquarters facility, LockStep at the satellite plants.