Oilfield Professional Tools

The Inspection Was Done. The Man Who Did It Is the Man Who Uses the Procedure.

So it certifies nothing. 29 CFR 1910.147(c)(6) does not just ask for an annual look at your lockout procedures โ€” it asks for one carried out by an authorized employee other than the ones using that procedure, written up naming the machine, the date, the employees included and who performed it. A paper log cannot tell you when the inspector's own name is on the procedure he inspected. This can.

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1910.147 is the fourth most-cited standard OSHA writes.
The annual inspection is where the paperwork quietly fails.

๐Ÿ“…

The annual clock, per procedure

Every energy-control procedure carries its own twelve-month clock โ€” the pumping unit, the compressor skid, the heater treater, each one separately. Bands run from never inspected through overdue to current, so a procedure written two years ago and never looked at since cannot hide in a folder.

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The inspector has to be someone else

(c)(6)(i)(A) requires an authorized employee other than those using the procedure being inspected. List who uses each procedure once, and a self-inspection is caught the moment it is entered โ€” including where the inspector signed himself into his own review.

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The certification, in full

(c)(6)(ii) names four things the written certification must identify: the machine, the date, the employees included, and who performed it. A record missing one of them is kept โ€” and banded as an incomplete certification, not quietly counted as done.

An inspection that happened is not the same as a certification that stands.

Rule one

A self-inspection certifies nothing

Name an inspector who appears on that procedure's own list of authorized employees, and the record is kept exactly as entered โ€” but the procedure does not go green. It bands as certification not valid, because ยง1910.147(c)(6)(i)(A) requires an authorized employee other than the ones using the procedure being inspected.

The check runs both ways. If the inspector is not on the procedure's list but is named among the employees whose responsibilities were reviewed at that inspection, it is still a self-inspection, and it is still caught. Case and punctuation differences do not get past it: "R. Alvarez", "r alvarez" and "R Alvarez" are one man.

Rule two

A later clean inspection does not close an open deviation

When an inspection finds a deviation or an inadequacy in the procedure, that finding stays open on the register until a correction is recorded, dated on or after the inspection that found it. Running another inspection next year and ticking "no deviations" does not retire it โ€” the app reads the most recent inspection that found something, not the most recent inspection.

This axis is tracked separately from the clock, so a procedure inspected perfectly on time can still be sitting on an open deviation โ€” and it stays visible on the card even when a worse band wins the row.

Rule three

Tagout asks for more people than lockout

Where lockout is used, (c)(6)(i)(C) requires the inspector to review each authorized employee's responsibilities under the procedure. Where tagout is used, (c)(6)(i)(D) extends that review to affected employees as well.

Mark a procedure as tagout and the affected-employee field appears on the inspection form and becomes a required element of that certification. Leave it empty and the certification is short one thing the rule names โ€” which is exactly the gap a form that treats both methods identically will never show you.

Seven bands, worst first

Every procedure sits in exactly one band โ€” the worst one that applies โ€” so the register reads from the top down. A procedure with nothing recorded against it is not treated as clean; it lands in the emptiest band of all, because no evidence is worse than bad evidence.

  • Never inspected โ€” on the register, nothing recorded against it.
  • Certification not valid โ€” the inspector uses the procedure he inspected.
  • Deficiency open โ€” a deviation was found and no correction recorded since.
  • Overdue โ€” past the twelve-month interval.
  • Certification incomplete โ€” missing one of the four required elements.
  • Due soon โ€” falls due inside 60 days.
  • Current โ€” inspected in time, independently, certified in full, nothing open.

One row per procedure, one row per inspection

The machine

The equipment the procedure applies to, its asset tag, its type and where it sits โ€” the first thing (c)(6)(ii) asks the certification to identify.

The energy isolated

Electrical, mechanical, hydraulic, pneumatic, chemical, thermal, stored or gravity โ€” plus anything else typed in free.

Lockout or tagout

Set per procedure, because it changes who has to be included in the review.

Who uses it

The authorized employees on that procedure โ€” the people reviewed at the inspection, and the people who cannot be its inspector.

Every inspection

Date, who performed it, everyone included in the review, individually or as a group meeting, and what was found.

The pack

A dated certification page per procedure, laid out in the order the rule names the elements, with anything missing marked plainly.

Every band tile on the dashboard opens the register filtered to exactly those procedures. There is no counted band you cannot act on โ€” a number you can see but not drill into is a number that gets ignored.

Field-ready. Built for the lease, not the office.

๐Ÿ›ข๏ธ LOTO Periodic Inspection & Certification Log
๐ŸŒ™
StatusProceduresRecord InspectionRegisterHistoryCertification Pack
1
Never inspected
1
Not valid
1
Deficiency open
1
Overdue
1
Incomplete
1
Due soon
1
Current
Certification not valid
Water injection pump โ€” WIP-2 โ€” ECP-033
Lockout ยท Pump / injection ยท Electrical ยท Hydraulic โ€” SWD station
Certification not valid
Annual inspection
Due in 120 days
Certification
Not valid
Deficiency
None recorded
Certification does not stand โ€” M. Farrell is listed as an authorized employee who uses this procedure, so this is a self-inspection. ยง1910.147(c)(6)(i)(A) requires an authorized employee other than the ones using the procedure being inspected.
Authorized employees using this procedure: M. Farrell
Deficiency open
Gathering skid โ€” GS-11 โ€” ECP-061
Lockout ยท Gathering skid ยท Pneumatic ยท Mechanical โ€” North line
Deficiency open
Annual inspection
Due in 210 days
Certification
Complete
Deficiency
Open since 12 Oct 2025
Deviation open โ€” the inspection on 12 Oct 2025 found that two block valves upstream of the skid are not covered by the written procedure, and no correction has been recorded on or after that date. A later inspection found nothing wrong; that does not close it.
Certification incomplete
Heater treater โ€” HT-7 โ€” ECP-040
Tagout ยท Heater treater ยท Thermal ยท Chemical โ€” Battery 4
Certification incomplete
Annual inspection
Due in 180 days
Certification
Missing 1 element
Deficiency
None recorded
Not a certification โ€” the record does not identify the affected employees included in the review, which a tagout procedure requires under (c)(6)(i)(D).
Affected employees: J. Whitcomb ยท L. Pryor

What it does not do

It does not carry out an inspection. It does not write your energy-control procedures or judge whether one is adequate. It does not replace 29 CFR 1910.147, your employer's programme, or the authorized employee who has to walk the machine. It records which procedures exist, when each was inspected and by whom, who was included in the review, what was found, and which certifications are missing something the rule names.

One payment. Yours to keep.

$19
one-time ยท no subscription ยท no account
  • โœ“ Unlimited procedures, inspections and corrections
  • โœ“ Annual inspection clock per procedure
  • โœ“ Independent-inspector rule checked both ways
  • โœ“ All four (c)(6)(ii) certification elements captured
  • โœ“ Tagout procedures ask for affected employees too
  • โœ“ Open deviations tracked on their own axis
  • โœ“ Drillable band tiles and a filtered register
  • โœ“ Printable dated certification pack
  • โœ“ Backup and restore to a file
  • โœ“ Installs to your phone, works with no signal
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Everything stays on your device. Nothing is uploaded, no account is created, and the app keeps working when the lease has no bars.