OSHA Lockout/Tagout: Requirements, Training, and Inspections

OSHA’s lockout/tagout requirements, set out at 29 CFR 1910.147, obligate employers to build a formal program that keeps machines from starting up or releasing stored energy while workers service or maintain them. Compliance rests on three pieces: written, machine-specific energy control procedures; trained employees who know their role; and annual inspections that catch drift before it causes an injury. Violations regularly land among OSHA’s most-cited safety failures, and a single willful citation can reach $165,514.¹

Which Employers and Activities Are Covered

The standard reaches any servicing or maintenance work where a machine could injure a worker through unexpected startup or the release of stored energy. “Hazardous energy” is broad: electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and others all count.¹

Normal production runs are outside the rule. So are minor tool changes and adjustments that are routine and integral to production, provided the employer uses alternative measures that effectively protect workers. Two other exclusions matter because employers often assume they still owe full LOTO when they don’t. Cord-and-plug equipment is excluded when the machine’s only energy source is an electrical cord and the worker unplugs it and keeps the plug under their exclusive control for the entire task.² Hot tap operations on pressurized pipelines are excluded when the employer shows that shutdown is impractical and documented procedures provide effective protection.

The Written Energy Control Program

Every covered employer needs a written program that identifies who is authorized to perform LOTO, how hazardous energy will be controlled, and the specific techniques workers will use.¹

A generic procedure that covers “all equipment” won’t satisfy the rule. The employer needs a separate documented procedure for each machine that requires LOTO, walking through how devices are applied, removed, and transferred, with a verification step confirming the equipment is fully de-energized. Each procedure has to identify:

The specific machine or piece of equipment
The type and magnitude of hazardous energy present
The location of every energy-isolating device
The steps for shutting down and isolating the equipment

Lockout vs. Tagout

If an energy-isolating device can accept a lock, the employer must use lockout. A lockout device physically prevents the isolating device from being operated; a tag is only a warning. Tagout is permitted only when the isolating device genuinely cannot be locked out, and even then the employer must show the tagout program delivers protection equivalent to a lockout program.¹

Device Requirements

The hardware itself has to meet specific standards, and inspectors notice when it doesn’t.

Every lockout and tagout device must withstand the environment where it will be used for as long as it is expected to stay in place. Tags in particular must hold up against weather, moisture, and corrosive settings; a tag that becomes illegible is worse than useless.²

Devices must be standardized across the facility by at least one of color, shape, or size. Tagout devices are also standardized by print and format. Every device must clearly identify the employee who applied it, and every tag must carry a warning against energizing the equipment, using language such as “Do Not Start” or “Do Not Operate.” LOTO devices should not be repurposed as general-use tags or locks elsewhere in the facility.

Applying and Removing Lockout Devices

The standard sets a specific sequence for locking equipment out, and a mirror image for restoring it. Skipping steps is where injuries happen.

The Lockout Sequence

The authorized employee first notifies every affected employee that the machine is going down for service. The machine is then shut down using its normal stopping procedure, so the shutdown itself doesn’t create a new hazard.³

Next, the authorized employee positions each energy-isolating device (circuit breakers, valves, disconnects) to cut the machine off from every energy source, then applies their personal lockout or tagout device to each one.

Stored or residual energy is the step most often rushed, and it accounts for a disproportionate share of LOTO injuries. Hydraulic pressure, compressed air, springs, elevated machine parts, electrical capacitors, and trapped steam or water all qualify. Each must be relieved, disconnected, blocked, grounded, or otherwise made safe before work begins.

The last step before maintenance starts is verification. With no one in a danger zone, the authorized employee tries to start the machine using its normal operating controls. If nothing happens, isolation is confirmed. The controls then go back to the neutral or “off” position.

Restoring Equipment to Service

Before removing any device, the authorized employee inspects the work area to confirm that tools and nonessential items are cleared and that machine components are intact. All employees must be confirmed clear. Only the authorized employee who applied a lockout or tagout device may remove it, and affected employees must be notified before energy is restored.²

When the Authorized Employee Isn’t There

There is one narrow exception to the rule that only the person who applied a device may remove it. When the authorized employee is not at the facility, the employer may direct removal, but only if every one of the following is in place:

The employer has already developed, documented, and incorporated a specific removal procedure into the energy control program.
The employer verifies the authorized employee is not at the facility.
The employer makes all reasonable efforts to contact the absent employee and tell them the device was removed.
The employer ensures the employee knows the device was removed before returning to work.

An employer without a pre-documented removal procedure cannot invoke this exception in the moment.²

Group Lockout and Shift Changes

When a crew or multi-trade team services the same equipment, a group lockout procedure must give each worker protection equivalent to an individual lockout.² One authorized employee takes primary responsibility for a defined group operating under a group lockout device, often called an operations lock, and must be able to determine the exposure status of every individual in the group at any time. When more than one crew or department is involved, a single authorized employee coordinates all work forces to keep protection continuous. Each authorized employee in the group attaches their own personal lock to a group lockout device or lockbox when they begin work and removes it when they stop.

Shift changes create the same continuity problem. The employer must have specific procedures for the orderly transfer of protection between outgoing and incoming employees, so protection never lapses during the handoff. In practice, the incoming worker applies their lock before the outgoing worker removes theirs.

Training the Three Employee Categories

The standard sorts workers into three groups, each with a different training obligation. Under-training someone who actually performs LOTO is a common citation.

Authorized employees perform the lockout or tagout. They must be trained to recognize every applicable hazardous energy source, understand the type and magnitude of energy present, and know the methods for isolating and controlling it.⁴

Affected employees operate the machine or work in the area being serviced. They need to understand the purpose of the procedure and what it means for their work when LOTO is in place.

Other employees work near LOTO activities without directly operating or servicing the equipment. They must know the procedure exists and must understand that attempting to restart or re-energize locked-out equipment is prohibited.

When Retraining Is Required

Authorized and affected employees must be retrained whenever their job assignment changes, a machine or process is modified in a way that introduces a new hazard, the energy control procedure changes, or a periodic inspection reveals gaps in the employee’s knowledge or execution. The employer must be able to certify that each authorized and affected employee received and understood the required training.¹

Contractors and Outside Personnel

When outside contractors do covered maintenance, communication runs both ways. The host employer and the contractor inform each other of their respective LOTO procedures. The host employer then makes sure its own employees understand and follow the contractor’s energy control restrictions during that work, and affected employees, including contractor workers in the area, are notified before devices are applied and after they come off.

Annual Periodic Inspections

Every energy control procedure must be inspected at least once a year. The point is catching drift: procedures that read well on paper can degrade in practice as workers take shortcuts or equipment changes stack up.

The inspection must be performed by an authorized employee other than the one currently using the procedure being reviewed. The inspector watches the authorized employee actually perform the LOTO procedure and verifies that each step is followed and that the employee understands their responsibilities.⁵

When tagout is used, the inspection must also include a discussion with authorized and affected employees about the limitations of tags: a tag is a warning device, not a physical barrier, and can be removed by anyone.

If the inspection reveals deviations, the employer must correct them, and that correction often triggers retraining. Each inspection must be certified, and the record must include the machine or equipment covered, the date of the inspection, the employees included in the review, and the name of the inspector.

Penalties for Noncompliance

OSHA adjusts its penalty maximums annually for inflation. As of the most recent adjustment effective January 2025:⁶

Serious violation: up to $16,550 per violation
Willful or repeated violation: up to $165,514 per violation

Those figures apply per violation, and OSHA can cite each machine with a deficient procedure separately. An employer with ten machines and no written procedures could face ten separate serious citations. Willful violations, where the employer knew about the hazard and made no effort to fix it, carry penalties roughly ten times higher. LOTO failures are also among the failures most likely to result in amputations and fatalities, which bring mandatory OSHA investigations.

1
eCFR. 29 CFR 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
2
Occupational Safety and Health Administration (OSHA). 1910.147 – The Control of Hazardous Energy (Lockout/Tagout)
3
Code of Federal Regulations. 29 CFR 1910.147 – Typical Minimal Lockout Procedure
4
Occupational Safety and Health Administration. eTool – Lockout-Tagout – Employee Training and Communication
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Occupational Safety and Health Administration. Lockout/Tagout eTool – Periodic Inspections
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Occupational Safety and Health Administration. OSHA Penalties