OSHA 1910.147 Lockout/Tagout: Six Steps, Training, Penalties

OSHA 1910.147 lockout/tagout requirements obligate general industry employers to establish a written energy control program, develop machine-specific shutdown procedures, train employees according to their role, use standardized lock and tag devices, and inspect every procedure at least once a year. The rule governs the servicing and maintenance of machines whose unexpected startup or stored energy could injure a worker, and it is one of OSHA’s five most frequently cited standards.¹

When the Standard Applies

The rule covers general industry workplaces where employees service or maintain machines that could injure someone through unexpected startup or the release of stored energy.² That includes manufacturing, warehousing, food processing, and any general industry site running machinery. Energy sources in scope are electrical, mechanical, hydraulic, pneumatic, chemical, and thermal, along with stored energy such as residual hydraulic pressure, retained heat, or spring tension.

During normal production, lockout is required in two situations: when a worker must remove or bypass a machine guard, or when a worker must place any part of their body into the point of operation or another danger zone.

Several categories fall outside 1910.147 and are governed by other federal rules: construction and agriculture, maritime employment (29 CFR parts 1915, 1917, and 1918), electric utility generation, transmission, and distribution facilities, electrical work covered by Subpart S, and oil and gas well drilling and servicing. If you work in one of these areas, this standard does not apply to you, but other energy-control requirements almost certainly do.

Two narrow exceptions exist within general industry. Cord-and-plug equipment is exempt if the employee performing the work unplugs it and keeps the plug under exclusive control the entire time. Minor tool changes and adjustments that are routine, repetitive, and integral to production are exempt if the employer provides alternative measures that actually protect the worker. Both conditions must be met for either exception, and OSHA frequently cites employers who stretch them.

The Written Energy Control Program

Every covered employer must establish a written energy control program built on documented procedures, employee training, and periodic inspections.² The program sets the facility’s overall approach: which types of lockout and tagout devices are used, when and how employees apply them, and how compliance is enforced. OSHA compliance officers review this program early in any inspection.

Machine-Specific Procedures

Beyond the general program, the standard requires a written procedure for each individual machine where lockout or tagout is used. A procedure written for a hydraulic press will not work for a conveyor. At minimum, each procedure must document:

Every energy source the machine uses or stores
The physical location of each circuit breaker, valve, disconnect, or block that controls energy flow
The step-by-step shutdown sequence
Instructions for applying locks or tags to each isolation point
How to bleed pressure, release tension, discharge capacitors, or otherwise eliminate residual energy
How the worker verifies the machine is de-energized before starting work

Verification is where many written procedures fall short. The instructions must tell the worker exactly how to test the equipment after lockout, whether that means pressing the start button, reading a pressure gauge, or using a voltage tester. Writing this step vaguely is one of the fastest ways to draw a citation.

The Six-Step Sequence

The standard lays out a specific order that every lockout must follow.³

Preparation. The authorized employee identifies every energy source on the machine, the hazards each one presents, and the method for controlling each one, before touching a switch.
Shutdown. The machine is turned off using its normal stopping procedure, so the shutdown itself does not create new hazards.
Isolation. Every energy isolating device is physically moved to the off or safe position, cutting the machine off from all energy sources.
Device application. A lock or tag is attached to each energy isolating device. Locks hold the device in the off position; tags clearly indicate that operating the equipment is prohibited.
Stored energy. Any residual or stored energy is relieved, disconnected, or restrained. If it could rebuild to a dangerous level, the worker must keep monitoring throughout the job.
Verification. Before starting work, the authorized employee tests the machine to confirm all energy has been isolated.

Lockout vs. Tagout

If an energy isolating device can accept a lock, the employer must use lockout. Tagout alone is only permitted on a lockable device if the employer can demonstrate it provides an equivalent level of safety, which is a difficult bar to clear.² A device is considered capable of being locked out if it has a hasp, a built-in locking mechanism, or can otherwise accept a lock without being dismantled or permanently altered.

When an employer chooses tagout on a lockable device, additional measures are required, such as removing a circuit element, blocking a controlling switch, or pulling a valve handle. These compensate for the fact that a tag can be ignored or accidentally removed in a way a lock cannot. When the device genuinely cannot accept a lock, tagout is permitted, but all tagout provisions in the standard apply.

Device and Hardware Requirements

Every lock, tag, chain, or block used for energy isolation must withstand the environment where it is used, including any chemical exposure, moisture, or temperature extremes. Devices must be standardized within the facility by color, shape, or size, so that anyone in the plant can recognize an energy control device on sight. They must be strong enough that they cannot be knocked off or casually removed, and tags must remain legible throughout use.

Lockout and tagout devices must be used exclusively for energy control. A padlock that doubles as a toolbox lock on other days does not comply. Each device must identify the specific authorized employee who applied it and cannot serve any purpose other than hazardous energy control.

Training the Three Employee Categories

The standard divides workers into three groups, each with different training obligations.⁴

Authorized employees apply and remove lockout devices and perform the servicing work. They need the deepest training: recognizing every type of hazardous energy in the workplace, understanding its magnitude, and knowing the specific methods for isolating and controlling it.
Affected employees operate the machines being serviced or work nearby. Their training focuses on the purpose of lockout and recognizing when a procedure is underway, so they never attempt to restart a locked-out machine.
Other employees pass through areas where lockout may be in progress. They must understand one rule: do not touch, remove, or interfere with any lockout or tagout device.

An affected employee who takes on servicing duties must receive full authorized-employee training before performing that work. Retraining is required whenever job assignments change, new equipment is introduced, processes are modified in ways that create new hazards, or an inspection reveals employees are not following established procedures. Keep training records; inspectors ask for them.

Group Lockout and Shift Changes

When a crew or multiple departments service the same equipment, the standard requires a group lockout procedure that gives each worker the same protection they would have with a personal lock. One authorized employee takes primary responsibility for the group and tracks the exposure status of each person working under the group lockout. When multiple crews are involved, a coordinator manages overall protection across the groups.

The usual mechanism is a group lockbox or hasp. Each authorized employee attaches a personal lock when starting work and removes it when finished. The machine cannot be re-energized until every individual lock is off, so no one gets left inside a machine because someone else decided the job was done.

Shift changes require an orderly transfer of protection so the machine is never unprotected during the handover.⁵ In practice, the incoming employee applies a lock before the outgoing employee removes one.

Annual Inspections

Every energy control procedure must be inspected at least once per year, performed by an authorized employee who is not the person currently using the procedure being reviewed.² That separation forces a fresh set of eyes on whether the procedure matches what actually happens on the shop floor. Deviations trigger retraining.

Employers must certify each inspection with the date, the equipment covered, the employees included, and the identity of the inspector.⁶ Missing or outdated certifications are a reliable source of citations.

Restoring Energy After Service

Removing locks is as regulated as applying them. Before any device comes off, the authorized employee must inspect the work area to confirm tools and loose parts have been removed, verify the machine is mechanically intact, and ensure every employee is safely clear. After the devices are removed but before the machine is started, affected employees must be notified that lockout is over.

Only the employee who applied a lock or tag may remove it. There is one narrow exception: when that employee is not at the facility, the employer may direct removal, but only under a documented procedure the workforce has been trained on. The procedure must verify the employee is genuinely absent, make all reasonable efforts to contact them and tell them the lock was removed, and ensure the employee knows about the removal before returning to work. This provision is not a convenience option, and casual use of it invites both injuries and citations.

Penalties for Violations

Lockout/tagout was the fifth most frequently cited OSHA standard in fiscal year 2024.¹ Penalties adjust annually for inflation. As of January 2025, the maximum fine for a serious violation is $16,550 per violation, and a willful or repeated violation can reach $165,514 per violation.⁷

A single facility can accumulate multiple violations quickly because OSHA cites per instance. One missing procedure, one untrained employee, and one uninspected machine are three separate violations. Willful violations carry a minimum penalty of $11,823 in addition to the higher ceiling. Failure-to-abate penalties of $16,550 per day can accumulate when an employer does not fix a cited hazard by the deadline OSHA sets. These amounts typically increase each January, so check OSHA’s published penalty schedule for the current year’s figures.

1
Occupational Safety and Health Administration. Top 10 Most Frequently Cited Standards
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Occupational Safety and Health Administration. 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
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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. Lockout-Tagout – Tutorial – Employee Training and Communication
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Occupational Safety and Health Administration. Lockout-Tagout – Tutorial – Shift and Personnel Changes
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Centers for Disease Control and Prevention. Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tagout) Program
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Occupational Safety and Health Administration. OSHA Penalties