Lockout Tagout Training: Who, Retraining, and Penalties

Lockout/tagout training requirements under OSHA’s 29 CFR 1910.147 scale to what each worker actually does: employees who apply locks need full procedural training, employees who operate the affected equipment need awareness of the program and the prohibition on tampering, and everyone else in the area needs enough instruction to recognize LOTO when they see it. The employer must certify the training in writing, deliver it in a language the employee understands, and repeat it whenever jobs, equipment, procedures, or observed performance give reason to.¹ Getting the training piece right matters disproportionately because most LOTO citations trace back to training failures rather than missing hardware, and LOTO sits near the top of OSHA’s most-cited standards year after year.²

Who You Have to Train and How Deeply

The standard sorts workers into three groups. Misclassifying someone is one of the more common ways employers end up cited, so start here before designing any curriculum.

Authorized Employees

Authorized employees are the ones who actually perform servicing or maintenance and physically apply locks or tags to energy-isolating devices. They get the deepest training. Instruction must cover recognition of every type of hazardous energy in the workplace, the magnitude of that energy, and the specific methods for isolating and controlling it.¹ They need to walk the complete shutdown-to-verification sequence for every piece of equipment they touch, not a general overview.

Affected Employees

Affected employees operate the machines or work in the areas where LOTO takes place, but they don’t perform the maintenance themselves. Their training is narrower. They need to understand what energy control procedures are for and that they are absolutely prohibited from restarting or re-energizing locked-out equipment.³ If an affected employee’s duties later expand to include servicing, the additional authorized-level training has to happen before they apply a lock.

Other Employees

This catch-all covers anyone who works in an area where LOTO might occur but who doesn’t operate or maintain the equipment. Awareness training is enough: recognize when LOTO is in progress and never tamper with a lock or tag. Light as this is, skipping it is still a citable violation.¹

What Authorized-Employee Training Must Actually Cover

The regulation doesn’t leave the content to your discretion. Every element below has to be present, and each one is something an inspector will probe.

Hazard recognition comes first. Authorized employees must be able to identify every applicable energy source, including stored energy that is easy to overlook: compressed springs, elevated machine parts, residual pressure in lines, thermal energy in heated components. Training has to address both the type and the magnitude of the energy, because a worker who doesn’t grasp how much force is stored in a system may not take isolation seriously.¹

Beyond recognition, authorized employees need hands-on proficiency in the specific isolation methods for their equipment. That means shutting the machine down, isolating the energy source, applying their lock or tag, and verifying zero energy before work begins. They also have to know the removal sequence: verify the area is clear, notify affected employees, and remove devices in the correct order. Generic training that doesn’t map to the equipment on your floor is where employers routinely get into trouble.

Extra Content for Tagout-Only Programs

When an employer uses tags instead of locks, everyone in the program needs additional instruction on what tags cannot do. A tag is a warning device. It does not physically prevent someone from flipping a switch or opening a valve, and workers have to understand that distinction, because tags can create a false sense of security that locks don’t.¹

Training also has to cover that a tag is never removed without authorization from the person who placed it, that tags must be legible and understandable to everyone in the area, and that they must be attached securely enough to survive the environmental conditions on site. When tagout is used on a device that could be locked out, the employer has to demonstrate the tagout program achieves safety equivalent to lockout, typically through additional measures like removing circuit elements or blocking controlling switches.³

Language, Certification, and Records

Training must be delivered in a language and vocabulary the employee can understand. For workplaces with non-English-speaking employees, that means instruction in their language or through effective translation, not the same English manual handed to everyone. This applies to all three employee categories.

The employer must certify in writing that each required training session has been completed and is current, with each employee’s name and the training dates.¹ The standard doesn’t dictate a format, but inspectors expect records that can be produced on request. Missing or incomplete documentation is one of the easiest citations for OSHA to issue, because the paperwork either exists or it doesn’t.

When Retraining Is Required

LOTO training isn’t a one-and-done event. Authorized and affected employees must be retrained whenever any of the following happens:

A job assignment change gives the employee new duties involving different equipment or energy sources.
Equipment, processes, or machinery change in a way that introduces a new hazard.
The employer revises its energy control procedures.
A periodic inspection reveals gaps in an employee’s knowledge or deviations from procedure.
The employer has any reason to believe a worker doesn’t fully understand or isn’t following the procedures.

That last trigger is deliberately broad. A supervisor who watches someone skip the verification step and shrugs it off has given the employer “reason to believe” there’s a problem, and retraining becomes an obligation.¹ Retraining has to re-establish proficiency; running through the same slides again doesn’t count if the underlying misunderstanding is still there.

The Annual Inspection and Its Link to Training

Each energy control procedure has to be inspected at least once a year to verify workers are actually following it. The inspection has to be conducted by an authorized employee who is not one of the workers using that particular procedure, which trips up smaller operations with limited staff.¹

For lockout procedures, the inspector must individually review each authorized employee’s responsibilities under the procedure. For tagout procedures, the review must include both authorized and affected employees and must revisit the tag-limitation training elements. The employer certifies the inspection in writing, documenting the machine or equipment inspected, the date, the employees who participated, and the person who performed the inspection. When the inspection uncovers problems, whether procedural deviations or knowledge gaps, the employer has to correct the issues and retrain the people involved. The inspection is, in practice, the mechanism that surfaces the need for retraining.

Contractors, Group Lockout, and Shift Changes

When contractors come on site to service equipment, the host employer and the contractor each have distinct obligations. Both must inform each other of their respective LOTO procedures, and the host has to ensure its own employees understand and follow any restrictions imposed by the contractor’s program.⁴ Contractors aren’t required to use the host’s procedures; they can bring their own. But if a contractor adopts the host’s procedures, those employees have to be trained on them to the same level as the host’s own workforce. Both parties can be cited under OSHA’s multi-employer citation policy if either fails to meet its obligations. Host employers commonly handle this through contractor orientations that include a quiz or test, and the coordination has to be documented.

Group lockout brings its own training content. When multiple employees service the same equipment, each authorized employee must apply their own personal lock to a group lockout device, group lockbox, or equivalent mechanism. A supervisor applying one lock on behalf of the crew does not comply.⁵ Training for group scenarios has to cover how your facility’s group lockbox system works and reinforce that personal locks are non-negotiable.

Shift changes require an orderly transfer of LOTO devices between outgoing and incoming crews so the equipment is never unprotected during the handoff.⁶ Training must walk employees through your facility’s specific handoff protocol, so incoming workers know to apply their own locks before the outgoing crew removes theirs.

Penalties for Training Failures

Training-related citations are among the most common LOTO violations because they’re easy for inspectors to verify. An inspector can ask any worker on the floor to explain the procedure for their equipment. If the worker can’t answer, or if the employer can’t produce a training record with that worker’s name and date, the citation writes itself.

Penalties are per violation, and OSHA can cite each untrained employee, each deficient procedure, or each uninspected machine separately. As of the January 2025 inflation adjustment, maximum fines are up to $16,550 for a serious or other-than-serious violation, up to $165,514 for a willful or repeated violation, and up to $16,550 per day past the abatement deadline for failure to abate.⁷ A facility with ten machines and no documented annual inspections is not looking at one citation; it’s looking at ten.

Industries the Standard Doesn’t Cover

LOTO under 1910.147 applies to general industry. Construction and agriculture fall under separate OSHA standards. Maritime operations (shipyard employment, marine terminals, longshoring) are covered by their own parts of Title 29. Electric utility installations under the exclusive control of the utility for power generation, transmission, and distribution follow different rules, and oil and gas well drilling and servicing are also outside the standard.¹ If your operation falls into one of those categories, the training requirements above aren’t the ones that apply to you.

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eCFR. 29 CFR 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
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Occupational Safety and Health Administration. Top 10 Most Frequently Cited Standards
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Occupational Safety and Health Administration. 29 CFR 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
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Occupational Safety and Health Administration. Lockout/Tagout As Applies to Contractor Employers
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Occupational Safety and Health Administration. Group Lockout or Tagout
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Occupational Safety and Health Administration. Lockout/Tagout Tutorial – Shift and Personnel Changes
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Occupational Safety and Health Administration. OSHA Penalties