OSHA Lockout/Tagout Requirements: A Compliance Checklist

What are OSHA's lockout/tagout requirements, and what should your compliance checklist include?

OSHA's lockout/tagout (LOTO) requirements live in the Control of Hazardous Energy standard, 29 CFR 1910.147. The standard requires employers to establish a written energy control program, develop machine-specific written procedures, train authorized and affected employees, and conduct periodic inspections of those procedures at least annually. A compliance checklist gives you a structured way to verify that each of these elements actually exists, is current, and is documented, rather than assuming a program is complete.

What is lockout/tagout?

Lockout/tagout is the practice of controlling hazardous energy during the servicing and maintenance of machines and equipment. Hazardous energy is not just electrical: it includes mechanical, hydraulic, pneumatic, chemical, thermal, and stored energy such as that held in springs, capacitors, or elevated machine parts. The unexpected startup or release of that energy is what injures and kills workers performing maintenance, which is the harm 1910.147 is designed to prevent.

Lockout means applying a physical lock to an energy-isolating device so it cannot be operated until the lock is removed. Tagout means attaching a prominent warning tag to that device. OSHA treats lockout as the preferred method; tagout alone is permitted only when the employer can demonstrate that the protection is equivalent to lockout, which in practice means meeting additional requirements.

Do you need a written energy control program?

Yes. The standard requires a documented energy control program consisting of energy control procedures, an employee training program, and periodic inspections. The written program is the foundation that ties the other requirements together. If servicing or maintenance is performed on machines where unexpected energization or startup could cause injury, the employer must have this program in place.

When are machine-specific written procedures required?

Under 1910.147(c)(4), employers must develop, document, and use specific procedures for the control of hazardous energy. In most facilities this means a separate written procedure for each machine or piece of equipment, because energy sources, isolation points, and shutdown sequences differ. A single generic procedure rarely satisfies the standard where equipment varies.

There is one limited exception. Under 1910.147(c)(4)(i), a documented machine-specific procedure is not required when all of the following conditions are met: the machine has no potential for stored or residual energy or reaccumulation of energy after shutdown; it has a single energy source that can be readily identified and isolated; isolating that single source completely de-energizes and deactivates the machine; the machine is isolated and locked out during servicing; a single lockout device achieves a locked-out condition; the lockout device is under the exclusive control of the authorized employee; the servicing does not create hazards for other employees; and the employer has had no accidents involving unexpected energization during servicing of that machine. Because every condition must be met, most equipment does not qualify, and erring toward writing a procedure is the safer path.

What six elements should a documented procedure contain?

When a written procedure is required, it should clearly outline the scope, purpose, authorization, rules, and techniques for controlling hazardous energy. A well-built procedure generally documents the following elements:

1. A specific statement of the intended use of the procedure and the machine or equipment it covers.
2. Specific procedural steps for shutting down, isolating, blocking, and securing the machine to control hazardous energy.
3. Specific steps for the placement, removal, and transfer of lockout or tagout devices and the responsibility for them.
4. Specific requirements for testing the machine to verify the effectiveness of the energy control measures (the zero-energy verification step).
5. Identification of every energy source and its corresponding isolation point.
6. The sequence for safely releasing stored energy and restoring the machine to service.

Who must be trained?

Training requirements appear in 1910.147(c)(7) and depend on the employee's role. The standard recognizes three categories, and your program must address each:

• Authorized employees, who lock or tag out machines to perform servicing or maintenance, must be trained in recognizing hazardous energy sources, the type and magnitude of energy in the workplace, and the methods and means to isolate and control it.
• Affected employees, who operate machines being serviced or work in the area, must be trained to recognize when energy control procedures are in use and the importance of not attempting to restart or use locked-out equipment.
• Other employees, whose work is or may be in an area where energy control procedures are used, must be instructed about the procedures and the prohibition against restarting locked-out machines.

Retraining is required when there is a change in job assignments, machines, or procedures, or when a periodic inspection reveals deviations or inadequacies in an employee's knowledge. Training should be documented, including the employee's identity and the dates of training.

How often are periodic inspections required?

Under 1910.147(c)(6), the employer must conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the standard's requirements are being followed. The inspection must be performed by an authorized employee other than the one using the procedure being inspected. For lockout procedures it must include a review, between the inspector and each authorized employee, of that employee's responsibilities under the procedure. The employer must certify the inspection, identifying the machine, the date, the employees included, and the person who performed it.

How do group lockout, shift changes, and contractors fit in?

When servicing involves a crew, group lockout or tagout must give each authorized employee the same level of protection as a personal lockout device, typically through a group lockbox where each worker applies a personal lock. Procedures must also address shift or personnel changes so that protection is continuous and lockout responsibility transfers cleanly between outgoing and incoming employees. When outside contractors work on site, the host employer and the contractor must inform each other of their respective lockout/tagout procedures so both workforces understand and comply with the restrictions.

Your lockout/tagout compliance checklist

Use this checklist to verify your program against 29 CFR 1910.147. Each item should be in place, current, and documented:

• A written energy control program covering procedures, training, and periodic inspections is in place.
• Machine-specific written energy control procedures exist for equipment that does not fully meet the 1910.147(c)(4)(i) exception.
• Each written procedure includes scope, shutdown and isolation steps, device application and removal, verification of zero energy, energy source identification, and a safe restoration sequence.
• All energy sources (electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and stored energy) are identified for each machine.
• Standardized, durable, identifiable, and substantial locks and tags are provided and used exclusively for energy control.
• Authorized, affected, and other employees are trained for their respective roles, with retraining triggered by changes or inspection findings.
• Periodic inspections are performed at least annually by an authorized employee other than the one using the procedure, and are certified in writing.
• Group lockout, shift-change, and outside-contractor coordination provisions are documented and followed.
• Training and inspection records are retained and readily available for review.

What about construction work under 29 CFR 1926?

OSHA's construction standards in 29 CFR 1926 do not contain a single, direct lockout/tagout analog to 1910.147. Construction has hazard-specific energy-control requirements scattered through standards such as those addressing electrical work, but no comprehensive control-of-hazardous-energy rule equivalent to the general industry standard. Where a construction activity involves servicing equipment and a specific 1926 provision does not apply, employers should treat 1910.147 and OSHA's General Duty Clause as the reference framework for protecting workers from hazardous energy.

Putting your program into practice

A LOTO program is only as good as the procedures behind it and the records that prove it is being followed. The hardest part for most safety managers is producing accurate machine-specific procedures for every applicable piece of equipment and keeping the annual inspection trail current and certifiable. Software can speed this work by helping you draft procedures and track inspection due dates, but any generated procedure is a draft that a qualified person must review and validate against the actual machine before use.

This article is educational information about OSHA requirements and is not legal advice. Consult the full text of 29 CFR 1910.147 and a qualified safety professional to confirm how the standard applies to your specific equipment and operations.