Routine, Repetitive, Integral
Hey all! Looking to guage who documents their procedures for tasks that fall under the routine, repetitive, and integral minor servicing exemption!
If so, do you audit these like normal loto documents? Care to share a good format?
Comments (3)

I have not done this in the past, but curious if others have done this.

You are correct. 1910.147 requires you know that your LO Policy is "EFFECTIVE". 1910.147(c)(6) outlines what OSHA means by "Periodic Inspections". Of course with OSHA my best advice is to always remember one of "Fitz's Laws of OSH Management", that is, "Dealing with OSHA, unless you documented it, YOU DID NOT DO IT!" ANSI/ASSE Z44.1-2016, 6.5, Page 27 also requires "Program Review."
OSHA in 1910.147 requires "periodic at least annual" inspection. But for the life of me "periodic" is a lot more often than once a year, but that is just me. However, when I write a LO Policy or advise a client on 1910(c)(6):
#1 Review your overall LO Policy at least once per year. In my opinion your OSH Policies are work documents, Standard Work or SOPs if you will (they inform people how to work). As such If you are ISO in anything all work documents must be reviewed annually anyways! The person charged with EHS should do that or someone like me.
#2 Audit your Machine Specific LO Procedures annually. Many ways to do this but I recommend you do at least 25 percent of your machines annually (in my last job we had 850 machines). Any Authorized user familiar with that machine may do the audit.
#3 In (c)(6)(i)(d) it requires authorized users to be checked of the employee's knowledge of your LO policy annually. Many ways to do it, but I have each Authorized user audit another Authorized User than they switch places, switch roles and, do it again,
#4 On an on-going basis the plant is audited to see Lockout is being done. Many ways to do it but I did this: Put a question about observing LO on My Safety Audit Sheets, done by Supervisors, Safety Teams employees, and myself. When we did BBS we saved all mention of LO. Kept all all emails concerning LO in a Cloud file. Asked supervisors to send emails every time they counseled or disciplined and employee on LO. Basically we documented when we were watching.