Performing Personnel Audits

Paul Chamberlain, American Electrical Testing Co., LLCColumns, Safety Corner, Summer 2022 Columns

They are called many things — observations, audits, assessments — but they are all intended to accomplish the same task: Evaluate the people in the field performing the task at hand. Generally, you observe an employee doing a task, then audit or assess whether performance of the task meets expectation.

These inspections can be performed by any level within a company and should be performed on all levels. Some companies hire a third-party entity to ensure the inspections remain completely impartial. However, in most cases, companies choose to have a manager or a member of the supervisory team conduct the inspection of their field personnel. If this is the case, it is a wise idea to set up some standards, such as frequency, for the inspection and have a verification done by a third party or safety manager.

While the main intent of these inspections is to ascertain several things, not everyone is aware of the potential benefits to the company. A check sheet should be used to facilitate the observation and to help gain the most out of it. Let’s review the aspects of a proper field  observation and the benefits any company, employee, and manager could gain from it.


First, let’s review some important items that should be verified when a manager is observing a crew performing work in the field. OSHA requires lockout/tagout procedures to be verified annually. Under 29 Code of Federal Regulations 1910.147, OSHA specifically states when this verification is required, although the requirements may be slightly different across each of the industries OSHA regulates. Within OSHA, each industry-specific regulation has its own separate section indicating the control of hazardous energy. Let’s consider two specific areas that pertain directly to electrical testing: 1910.147 regulates commercial installations, and 1910.269 specifically regulates utility installations.


Under 1910.147, you are required to ensure that procedures are being correctly followed by the employee performing the lockout/tagout. Specifically it states:

1910.147(c)(6) Periodic Inspection

1910.147(c)(6)(i) The employer 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)(A) The periodic inspection shall be performed by an authorized employee other than the ones(s) utilizing the energy control procedure being inspected.

1910.147(c)(6)(i)(B) The periodic inspection shall be conducted to correct any deviations or inadequacies identified.

1910.147(c)(6)(i)(C) Where lockout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized employee, of that employee’s responsibilities under the energy control procedure being inspected.

1910.147(c)(6)(i)(D) Where tagout is used for energy control, the periodic inspection shall include a review, between the inspector and each authorized and affected employee, of that employee’s responsibilities under the energy control procedure being inspected, and the elements set forth in paragraph (c)(7)(ii) of this section.

1910.147(c)(6)(ii) The employer shall certify that the periodic inspections have been performed. The certification shall identify the machine or equipment on which the energy control procedure was being utilized, the date of the inspection, the employees included in the inspection, and the person performing the inspection.


We can further see that the 1910.269 standard does not differ greatly from 1910.147 in its requirements:

1910.269(a)(2)(ii)(D) The proper use of the special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment. Note: For the purposes of this section, a person must have this training in order to be considered a qualified person.

1910.269(a)(2)(iii) The employer shall determine, through regular supervision and through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this section.

After reviewing these regulatory excerpts, it can be seen that every company is required to inspect and certify that employees are properly performing lockout/tagout whether they are working for a utility or a commercial entity. Incorporating this certification as part of a field observation or assessment kills two birds with one stone. Other regulatory mandated observations are dependent upon the task and industry. Please check to guide you in determining which regulations apply.


Another benefit gained by performing field observations of employees is that the employer can ensure they are following other pertinent company policies. For example, observing vehicle use might verify whether employees wear seatbelts while driving company vehicles, only use hands-free devices, do not talk on a cell phone while driving or performing a complex task, and minimize  the need for backing.

Additionally, if your company does a lot of driving or uses federally regulated vehicles, it may be necessary to observe employees as they operate the vehicle. This can be conducted as a ride-along observation where the supervisor rides in the vehicle with the employee, or as a follow-along observation where the supervisor follows the employee while in a separate vehicle. It is usually wise to create separate forms just for these types of observations, since the rules of the road are extensive and can vary depending upon the state they operate in and the type of vehicle they are driving. Another example would be the operation of a fork truck.


A company could also include a check sheet for documenting the proper use of protective and cautionary flagging and tagging. In some instances, a client may have a different procedure for this, so it is good company policy to ensure that employees not only follow your company’s policy, but also the client’s company policy if applicable. The default course of action in this type of scenario is to play it safe and follow the stronger policy. The observer would need to know what the client’s requirements are prior to going to the site.


One benefit to conducting field observations and audits is to ensure that employees use the correct personal protective equipment (PPE).

Hard hats, safety glasses. The inspector should check to see that employees are wearing hard hats whenever something could fall or strike their head or when they could make incidental contact with high-voltage equipment. The inspector should examine the hard hat for cracks, wear, discoloration, or torn cradles and straps. Safety glasses are necessary whenever there is potential for a liquid or solid to fly through the air and enter the eye. The inspector should ensure that the glasses are ANSI Z87-approved, which is indicated on the lens or the brow.

Clothing, footwear, gloves. Verifying correct PPE clothing can also be an item on the check sheet, as can ensuring employees are wearing the proper footwear, such as ASTM F2413.05-approved electrical hazard safety-toed footwear, which may or may not have height and laces requirements. Ensuring that the clothing they are wearing is cotton or calorie-rated for fire and arc protection could be an item. Additionally, verify that electrical protection such as voltage-rated gloves are inspected before each use, the correct level of protection is worn, and the test date is within the required date range. If a manager is planning to inspect these more-disposable PPE items, it is always a good idea to bring extra hard hats and safety glasses out into the field in case an employee needs a new set.

Heat-related illness. In companies where there is extensive physical labor or employees work in very hot areas, the observer could supply drinking water or other suitable fluids. This will not only boost morale, but will also improve productivity. Just the act of a manager supplying the drink and talking with employees can provide the adequate cool-off time needed to prevent a potential heat-related illness, and preventing that heat-related illness can prevent a potential OSHA-recordable injury.


Inspection of the general work environment can also benefit the company and the manager. Even though a lead technician or foreman may be conducting this inspection daily, they can still miss things or get used to seeing something that needs correction. Having someone different as well as new to the site can provide a new set of eyes, which may make it easier to identify potential problems or issues that could contribute to lost production or an injury. In some cases, the manager can arrange to meet with the client during the audit, thus presenting that all-important face for the client to remember.

During the observation, the observer should make it a point to ask questions:

  • Is there anything the company could do to make the job easier, safer, or better? The answers to this question can range from thought-provoking to ludicrous. But occasionally, a brilliant idea that can revolutionize a task can be evoked by simply asking that question. Remember, employees don’t know how much you care until you show them you care. If they give a good answer, act on it, and a reward should accompany any good idea that is a benefit to the company.
  • Is all the equipment you need for the job present and working properly, and is it the right equipment for the task? Newer employees may be hesitant to speak up if something doesn’t work right and just struggle along using what they’ve got. This can obviously slow down task performance and potentially contribute to injury or equipment damage.


The observer should be familiar with the procedure they are observing. In some cases, they may be considered experts in the task. If this is the case, the inspector could provide direction and add to the employee’s knowledge of the task by observing and critiquing. Being knowledgeable in the procedure can also help the inspector identify when a procedure is being performed incorrectly. We all develop bad habits, and in many cases, we are unaware of them. If the observer is knowledgeable of the proper procedure and notices an employee performing it in a different or incorrect manner, the manager can correct the task before the error causes an incident.

An added benefit to having an upper-level manager perform these observations is simply face time. All too often, field employees don’t associate a face with a name. All they know is the name and that when the phone rings, the manager will likely have another request or change in scope. Sending the manager out into the field increases the camaraderie in the project, which in turn can potentially make it more productive. If the manager is just some faceless voice that calls to change things, it becomes easier for employees to become complacent in responding to requests. If you show up on site and form a bond with employees, it goes a long way to improve your relationship with them. And with the stress placed upon a manager these days when managing a client, getting outside of the cubicle or office can go a long way to improving morale. The best way a manager can ensure getting out there happens is to schedule it, and the best way a company can ensure it gets done is to mandate it and reward those who meet or exceed the requirement.


There are many advantages to performing field observations, audits, or inspections. They boost morale and prevent injuries and ensure that the correct equipment is available, is being used correctly, and can be used to satisfy regulatory requirements. It helps to select observers knowledgeable in the scope of work, schedule adequate time to get them out in the field, and give praise when it is due. Utilize a check sheet to make the observer’s job easier to perform. Properly performed field inspections can go a long way to improving your company’s safety culture.

Paul Chamberlain has been the Safety Manager for American Electrical Testing Co. LLC since 2009. He has been in the safety field since 1998, working for various companies and in various industries. Paul received a BS from the Massachusetts Maritime Academy.