LOTO Program Audits: A Beginner’s Guide for Success

How to successfully conduct LOTO Program Audits. Tips for assessing and improving your safety procedures, training, and more!

An effective lockout tagout (LOTO) program is critical for ensuring workplace safety and regulatory compliance. Regular program audits provide a structured way to evaluate the effectiveness of your LOTO procedures, identify weaknesses, and implement improvements. This article explores the importance of LOTO program audits, how to conduct them, and actionable steps for enhancing your safety procedures.

A LOTO program audit is a systematic review of all aspects of your lockout tagout program including procedures, documentation, training, equipment use, and compliance with OSHA 1910.147 or ANSI Z244.1 regulations. The goal of a program audit is to ensure that all processes effectively control hazardous energy and safeguard workers during servicing and maintenance tasks.

Key elements of a LOTO program audit include:

1. Reviewing written LOTO procedures.
2. Inspecting lockout devices and equipment.
3. Evaluating employee training and competency.
4. Verifying compliance with relevant regulations.
5. Identifying and addressing gaps or inconsistencies.

Audits are a proactive way to maintain and improve safety standards. They provide the opportunity to critically analyze what is working and what needs improvement. Here are some specific areas in which a LOTO program audit can be helpful:

• Regulatory Compliance: The Occupational Safety and Health Administration (OSHA) requires periodic inspections to ensure adherence to safety standards. Those who are found violating their established standards are subject to fines based on the severity of the infraction. Therefore, conducting a program audit can help the team recognize any compliance issues and promptly address them to avoid costly fines.
• Risk Mitigation: Lockout tagout is a process that is meant to help safeguard lives while inspections or maintenance are performed on hazardous energy sources. However, if completed half-heartedly or not at all, the very process that is intended to reduce risks can become its own hazard to safety. Audits can reduce risks by identifying potential problems that could lead to accidents.
• Process Optimization: When companies find a good work flow, they are generally able to produce more, which in turn makes them more profitable. By reviewing and refining procedures during audits, companies are able to identify problem areas in their process. This can help them find a more suitable rhythm that ensures efficiency and effectiveness.
• Training Validation: Managers don’t have time to sit around and babysit their workers. On the contrary, they need to be able to trust that their employees are sufficiently educated and motivated to perform their work tasks well. LOTO program audits provide a sensible time to verify that employees understand and correctly implement lockout tagout practices.
• Continuous Improvement: Companies are always looking for ways to maximize their profit margins. This boils down to two main things: decreasing production costs and increasing worker productivity. Audits provide space for companies to assess their current safety culture and practices and then make needed adjustments.

Since audits are such powerful agents for change, let’s dive into the specifics of when, who and how they should be conducted.

The minimum requirement for audits is at least once a year. However, companies are at liberty to audit their procedures and employees on a more frequent basis if they desire. OSHA’s safety standard for lockout tagout specifies that companies “shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.” (1910.147(c)(6)(i)) These audits can be performed at any time within the calendar year, so long as the requirement is met.

LOTO program audits should be performed by an individual or team who is not involved in the procedure or program aspect that is being reviewed. This is supported by OSHA’s standard which states that periodic inspections should be “performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.” (1910.147(c)(6)(i)(A)) 

Within these established parameters, companies can opt to have another worker such as a supervisor perform the audit or hire the job out to a third party auditor. Either way, the individual performing the audit should be knowledgeable about the current compliance regulations around lockout tagout that way they can provide adequate feedback.

Before an audit can occur, there are 3 steps that the company needs to take to prepare.

1. Set Audit Objectives – Start by defining the purpose of your audit—whether it’s a routine compliance check, preparation for an OSHA inspection, or part of a broader safety initiative. Having a clear objective will guide the audit process and highlight key areas to focus on and review.

2. Select an Auditor & Schedule- As mentioned before, audits can be completed internally by someone who is not involved in the procedures or by a hired auditor. No matter who is selected, establish a time for the audit and convey the audit objectives from step 1. 

3. Alert Other Employees – Once the audit has been scheduled, inform any employees who will be affected by this appointment, including those who will be audited for performing procedures. 

When the time arrives, here is what you can expect the auditor to do for a full LOTO program audit. If you have someone internally performing the audit, share these steps with them to ensure a complete job. If an outsider is coming to perform the audit, look to ensure that they take these steps as well.

Audits often uncover recurring issues, such as:

• Incomplete or outdated procedures.
• Missing or improper use of lockout devices.
• Inconsistent training across departments.
• Lack of periodic inspections or documentation.
• Failure to address new equipment or processes.

Recognizing these challenges is the first step in addressing them effectively.

LOTO program audits provide the opportunity to recognize strengths and weaknesses in your current operations. Here are some tips for utilizing an audit to make improvements. 

1. Regularly Update Procedures
   Use an audit as an excuse to go back and review your lockout tagout procedures. The auditor will review them to verify that the procedures are compliant with current regulations, but you can look over them for ways to improve their clarity, efficiency, or flow. Should there be any suggestions from the auditor, this is a great time to implement them. 
2. Standardize Equipment
   Hopefully, you already have standardized equipment. However, if not, make the effort to standardize your locks, tags, and devices across the organization. Doing so will help to reduce confusion and ensure compatibility.
3. Enhance Training Programs
   Audits can be useful in identifying gaps in the knowledge or understanding of employees. Recognize these gaps and make adjustments to training programs accordingly. Incorporate a variety of training techniques such as hands-on training, role-playing scenarios, and digital tools to improve retention and application. Employees who are well trained will be best equipped to work efficiently, maximize safety, and perform their duties well. 
4. Leverage Technology
   If you are looking to improve operations, one of the best tools to incorporate is technology. With modern day solutions like LOTO software, companies can easily streamline procedure management, track compliance, automate reminders for audits and inspections, and so much more. It can be a real advantage for organization, scheduling, and consistency. 
5. Encourage Employee Feedback
   A program audit provides an opportune time to encourage feedback from employees. After all, workers on the ground often have valuable insights into procedural flaws or equipment issues. Their input can help continuously refine your program. 
6. Perform Follow-Ups
   After the audit is complete, promptly address audit findings and conduct follow-up reviews to ensure corrective actions have been implemented. If you procrastinate, you will likely forget to make the necessary changes.

Lockout tagout software and other forms of technology can be significant tools for both running a LOTO program AND performing audits. Here are some of the ways that digital solutions can make a difference: 

• Provide a centralized platform for managing procedures and documentation.
• Track training and certification records.
• Automate reminders for periodic inspections and audits.
• Facilitate mobile access to procedures via QR codes or apps.
• Improve worker efficiency with the mobile procedure builder. 
• Reduce the likelihood of human errors by guiding users through procedures and data input. 
• Offer a detailed user history. 
• Scale to be used across multiple job sites and projects. 
• And so much more!! 

By adopting these tools, organizations can enhance efficiency, accuracy, and accountability in their LOTO programs. Want to know more about our lockout tagout software? Request a demo to talk with one of our specialists. 

Lockout tagout program audits are essential for maintaining a safe workplace and ensuring compliance with regulatory standards. By following a structured approach and addressing audit findings, organizations can identify weaknesses, refine procedures, and foster a culture of continuous improvement. Regular audits not only mitigate risks but also demonstrate a commitment to protecting employees and maintaining operational excellence.