Annual LOTO training does NOT satisfy the Annual Periodic Inspection requirements
There is an evil myth regarding LOTO training and Periodic Inspections. I recently had a lengthy discussion with a Labor Lawyer regarding the FACT that annual LOTO training does NOT satisfy the Annual Periodic Inspection requirements. An employer is NOT required to perform annual training on LOTO, but they are REQUIRED to conduct a periodic inspection on EACH authorized employee. And far too many do not believe this to be the case. Their arguments are... "I have never heard of such a thing," "This is the way we have always done it," or my favorite... "OSHA was here last year, and they never said anything" (OSHA was there for a non-LOTO complaint!). So here are the 1910.147 specifics stating Periodic Inspections are required ANNUALLY on EACH authorized employee, that training is NOT required annually, and that training does not replace periodic inspections. |
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