CONFORMiT News Hot Take How To's Industry News News

HOT TAKE | A Loophole for OSHA ECP Inspections?

22 May 2024
paper machine yearly ecp inspection

Hot Take on OSHA Compliance for Annual ECP Inspection

OSHA requires periodic (yearly) inspections of each Energy Control Procedure (ECP) – this is the most cited problem for large organizations like yours. It’s tedious, to say the least. It requires you to spend valuable time out in the field re-checking every single procedure, and to make matters worse, you aren’t even able to consider using that procedure out in the field as an inspection tool. Additionally, each ECP must be inspected by an authorized employee and that employee cannot be someone who actually uses said procedure.

Fun, right? If only there was a secret hack that could cut the work by half…a third, even a fourth? Sadly, there is not, the regulations are strict about this one. Don’t despair, there is a better way to ensure you’re getting all of it done and within the required yearly time frame. After all, the only thing worse than having to complete ECP inspections on time is submitting them just to find out you missed some and getting fined anyway. 

The Recipe for a Successful ECP Inspection

Before we bake the cake, we need a couple of ingredients!

  • Inventory of all your ECPs by:

    • Title/ID

    • Last inspection date

  • List of your authorized employees, per area

  • A calendar

Now for the instructions, a.k.a. what you do for each area of the plant once you have those ingredients!

1. Divide the total number of ECPs by 12 (this is going to be the target number you’ll want to manage, per month).

2. List every procedure, per month, based on the last inspection date.

3. If each month perfectly aligns with your target number (the number from Step 1) congratulations, go to Step X.

4. If your calculations do not meet your target number, start moving ECPs backward in time to fill in any gaps.

5. Assign each ECP to one of the Authorized Employees for the specific area.

6. Track inspections to ensure that nothing slips through the cracks.

7. Remember to add any new ECPs to the inspection calendar.

8. Deleted ECPs must be removed from the inspection calendar.

You might end up inspecting your ECPs faster the first year because you shuffled things around, but it’s all going to right itself starting the second year. In the end, a successful OSHA ECP inspection isn’t rocket science. It is however, a lot of work and a lot of tracking – but who wants to get caught with their pants down when OSHA comes knocking? We didn’t think so. 

Did we miss something? We’ve seen a lot in our 35+ years of working to protect those in the Industry.  That said, we are open to any opportunity to gain another perspective – so, feel free to reach out and teach us something new. Your voice is one we want to hear!

Leo signs off on CONFORMiT Lockout Tagout Software


For 35 years, CONFORMiT has developed and marketed Cloud-Based Software-as-a-Service products to analyze and manage environmental, social, and governance (ESG) risks to support sustainability strategies. CONFORMiT’s simple and reliable solutions also promote companies’ and workers’ excellence in occupational health and safety management.

CONFORMiT enables its clients and their communities to provide a healthy and safe workplace while improving their productivity and profitability to build a more sustainable future.

For more information:  

Written by Gabriel LeRoi