I'm a little unclear as to the requirements of 110.1(K)(2) Field Work Audit and 110.1(K)(3) LOTO Program and Procedure Audit. Are all maintenance personnel involved with energized work or LOTO required to be audited yearly or only a sampling of the maintenance work force?

Theoretically you are only qualified if you demonstrate the skill by doing it. Since workers are no longer considered qualified if they don't do a task after 1 year it would seem to be an annual thing. The big thing here is keeping track of the paperwork. It's not a big deal for a foreman to verify that each of their crew members performs an LOTO for instance. It's almost a check-box kind of thing. It gets harder as you get further away from maintenance crews doing the work into specialists, engineers, planners, etc., that might not do much field work. You can make the audit as in depth as you want of course. You get out of it what you put into it. If it's more or less a "pencil whip" exercise, don't expect much. Also if you announce that you are doing an audit and watch every move, behaviors will change drastically compared to if you keep the audit checklist in your pocket and go out and do the observation without announcing what you are doing or act like you are doing something entirely different, and only after you walk away, fill out the check list. The goal here should be of course to watch for risky behaviors and correct them as required.

When I do announced audits, often I purposely ask open ended questions and lead people to their own answers. For instance when I audited one plant they pulled out a bunch of slip on electrical overshoes and were embarrassed by the fact that they were all out of date, often by years. I asked if they knew what the purpose of them was...were they stepping on top of and over energized bus work? I asked when they used them and why, and what they thought they were for. The conversation got pretty intense but I told them I was only making observations, not criticizing as far as the audit goes. Judging people's reactions and knowledge of the requirements was part of the audit so the overshoes were intended to ellude knowledge answers. I could care less what the subject matter was. Once I finished the audit I purposely took the pen and note book and put them away then we had a discussion about what overshoes are, what they are for, and specifically based on their task design whether they were even necessary (they weren't). I also stated that if they weren't going to maintain them and had no use for them, they needed to get rid of them so somebody didn't attempt to use them at some point in the future thinking they were serviceable safety equipment. Needless to say they got thrown away that day. Other topics that work similar are hot sticks and rescue hooks. A rescue hook is usually found hanging in the maintenance shop but there is no switchgear in the maintenance shop, and the inspection date on it is usually several years old. Perfect way to talk about emergency release procedures and what that might entail. Again we're looking for judging levels of engagement, actual procedures when the boss isn't looking, and overall subject knowledge. Sometimes the answers to this audit format are very informative.

You can really use any subject matter for this interview format. Ask someone to explain what they were doing in a lockout procedure and why they do it, and what can happen. I usually like to pick on either an obvious error or mistake, or a procedure that is out of the ordinary. Often halfway through the interview they will catch their own mistake and again...this really helps find out what the level of knowledge really is. It's easier to do this also if you're not the foreman of the area. It works equally well in a small group setting and with individuals. It works better most of the time to record answers but not to have the notebook out or to give any kind of feedback as to what the correct answer is. If I see something blatant and dangerous though I stop the interview immediately and address the issue.