Lockout Tagout Procedure Checklist and OSHA Requirements

A lockout/tagout procedure checklist follows the sequence OSHA requires under 29 CFR 1910.147: prepare for shutdown, notify affected employees, shut the equipment down, isolate every energy source and apply locks and tags, release or restrain stored energy, and verify isolation before work begins.¹ The same checklist governs how the equipment goes back into service and what gets documented along the way. Lockout tagout violations consistently rank among OSHA’s top five most-cited standards, with willful violations reaching $165,514 per instance.

Start With the Written Energy Control Procedure

Every machine with hazardous energy sources needs its own written energy control procedure before anyone services it. The document must state its intended use, the specific shutdown and isolation steps, how lockout or tagout devices are applied and removed, and how the equipment will be tested to confirm energy has been controlled.¹

The procedure has to identify every type of hazardous energy at that machine: electrical, hydraulic, pneumatic, thermal, chemical, or gravitational. Larger machines often have multiple energy sources that interact, and an isolation point can sit behind a panel or on a different floor. The written procedure is what keeps an authorized employee from missing one.

Preparation and Hardware

Before touching the equipment, the authorized employee gathers the specific locks, tags, and isolation hardware called for in the written procedure. Locks must be sturdy enough for the environment and individually identifiable to the person who applied them. Tags carry a warning like “Do Not Operate” along with the installer’s name and the date, and they must stay legible for the whole maintenance period.¹ Employers supply these devices, and they cannot be used for any other purpose.

The checklist itself is a record. Fill it in before the physical shutdown starts: the authorized employees performing the work, the affected employees who operate the equipment or work nearby, and every energy isolation point being controlled. That way there is a clear paper trail of who locked out what, and when.

Shutdown, Isolation, and Locking

Notify all affected employees that the equipment is going offline. Once everyone is clear, the authorized employee shuts the machine down using its normal stopping procedure, following the sequence in the manufacturer’s instructions and the written procedure. Then each energy isolation device moves to the “off” or “safe” position, physically disconnecting the machine from its power sources. That might mean flipping a circuit breaker, closing a gate valve, or disconnecting a hydraulic line.¹

Each isolation point gets its own lock and tag. The authorized employee keeps the only key to their personal lock so nobody else can re-energize the machine while work is underway.¹

Release Stored and Residual Energy

Cutting the supply is not enough. Energy already trapped in the system can still injure or kill. The authorized employee must dissipate or restrain any stored energy before starting work.¹ Common examples: bleed air from pneumatic lines, release pressure from hydraulic cylinders, discharge electrical capacitors, allow hot components to cool. Heavy flywheels or raised arms may need to be physically blocked or pinned so gravity cannot pull them into motion.

Some systems can re-accumulate energy after initial dissipation. If that is possible for the equipment at hand, the written procedure should address ongoing monitoring or periodic re-checks during the maintenance window.

Verify With a Try-Out

The final step before starting maintenance is the try-out. The authorized employee confirms no one is in the danger zone, then attempts to start the machine using its normal operating controls. If nothing moves or activates, the lockout is verified.¹ Return the controls to “off” so nothing starts by accident once the locks eventually come off. Skipping the try-out is one of the most common shortcuts inspectors catch. A lock on a breaker means nothing if a second energy source was missed.

Group Jobs and Shift Changes

When a crew or multiple departments service the same equipment, group lockout replaces individual lockout at the primary isolation points. A primary authorized employee applies locks to the energy isolation devices and coordinates overall control. Each individual authorized employee in the group then attaches a personal lock to a group lockbox or comparable device before beginning work and removes it when finished.¹ The primary locks stay on the isolation points until every personal lock is off the group box. Where more than one crew or department is involved, a single authorized employee must be designated to coordinate them all and track each worker’s exposure status.

Multi-shift jobs create a dangerous gap if lockout protection lapses at the handoff. The standard requires an orderly transfer of lockout or tagout devices between outgoing and incoming employees so protection never drops to zero.¹ In practice the incoming employee applies their personal lock before the outgoing employee removes theirs. Record each transfer on the checklist with names and timestamps.

Returning Equipment to Service

When maintenance is done, inspect the work area. Clear tools, loose parts, and debris. Reinstall and secure any guards or covers that came off during servicing.

Only the authorized employee who applied a lock may remove it. Before removal, notify all affected workers that the equipment is about to return to service and confirm everyone is clear.¹ Once the locks and tags are off, the isolation devices go back to the “on” position to restore power.

Emergency Lock Removal

If the employee who applied a lock is unavailable, the employer may remove it only by following a specific procedure that requires, at minimum, three things: verifying the authorized employee is not on site, making all reasonable efforts to contact that employee to inform them the lock has been removed, and ensuring the employee is told about the removal before their next shift begins. Some employers use a master key rather than bolt cutters. OSHA allows this when access to the master key is tightly controlled, the process is documented and incorporated into the energy control program, and only trained, authorized personnel can use it. Tagout devices have no master-key equivalent, so emergency removal of a tag necessarily destroys it.²

Training the Three Employee Categories

OSHA divides the workforce into three categories for training, and each needs different instruction:¹

Authorized employees apply and remove locks and tags. They must be trained to recognize every hazardous energy source in their work area, understand its type and magnitude, and know the specific methods for isolating and controlling it.
Affected employees operate or use the equipment being serviced. They need instruction on the purpose and use of the energy control procedure so they know why a machine is locked out and what they cannot do while it is.
All other employees whose work might bring them into an area where lockout is in progress must be instructed on the procedure and told never to attempt to restart or re-energize locked-out equipment.

Where tagout is used instead of locks, all employees also need training on the limitations of tags. Tags are warnings, not physical barriers.

Retraining is not on a fixed calendar. It is triggered by specific events: a change in job assignments involving different machines or procedures, changes to equipment or processes that introduce new hazards, deficiencies found during a periodic inspection, or an injury or near-miss involving energy control.¹ Waiting for a scheduled class after one of these triggers has already occurred is not compliant.

Annual Inspection and Certification

Every energy control procedure must be inspected at least once a year by an authorized employee who was not involved in the procedure being reviewed.¹ The inspector reviews each authorized employee’s responsibilities under the procedure and identifies any deviations or gaps. Where tagout is used, the review must also include affected employees.

The employer certifies the inspection with four pieces of information: the identity of the machine or equipment, the date of the inspection, the names of the employees included, and the name of the person who performed it.³ Keep the certification until the next inspection replaces it. Retain training records for the duration of each employee’s employment.

When Full Lockout Is Not Required

Two narrow exceptions exist, and both have conditions that have to be met precisely.

The standard does not apply to servicing cord-and-plug connected electrical equipment when unplugging the cord fully controls the hazard and the plug stays under the exclusive control of the employee doing the work.⁴ The exception covers only that equipment. Any other energy sources at the worksite still require full lockout.

Minor tool changes, adjustments, and similar activities that are routine, repetitive, and integral to normal production operations can use alternative protective measures instead of full lockout, provided those alternatives give effective protection.¹ “Routine” and “integral” are the operative words. One-off repairs or tasks that go beyond minor adjustments do not qualify.

Penalties for Noncompliance

OSHA penalty amounts were not adjusted for inflation in 2026, so the 2025 maximums remain in effect. A serious violation of the lockout tagout standard carries a penalty of up to $16,550 per instance. Willful or repeated violations can reach $165,514 per instance.⁵ Inspectors often cite each deficient machine or each missing procedure element separately, so a single facility audit can produce dozens of individual violations.

1
Occupational Safety and Health Administration. 29 CFR 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
2
Occupational Safety and Health Administration. Removal of Lockout Devices by Persons Other Than Those Who Applied Them
3
Occupational Safety and Health Administration. eTool – Lockout-Tagout – Tutorial – Periodic Inspection
4
Occupational Safety and Health Administration. Application of Lockout/Tagout to Employees Performing Maintenance Tasks on Cord and Plug Equipment
5
Occupational Safety and Health Administration. OSHA Penalties