Last updated 2026-07-09

TL;DR
OSHA's lockout/tagout standard (29 CFR 1910.147) requires six steps in order: notify affected employees, identify and shut down the equipment, isolate every energy source, apply your lock or tag, release or restrain stored energy, and verify zero energy before work begins. Skip or reverse a step and you get a serious OSHA violation and one of the leading causes of fatal maintenance injuries.
Why lockout/tagout matters more than almost any other safety procedure
About 3 million workers service or maintain equipment that could start back up or dump stored energy without warning. OSHA has tracked the toll for decades, and the number it lands on is blunt: proper lockout/tagout (LOTO) prevents roughly 120 fatalities and 50,000 injuries every year. [1] That's not a rounding error. That's a full emergency department, running all year.
The hazard has a name: unexpected energization. It happens because machines hold energy in ways your eyes can't see. A press is off, but the hydraulics are still pressurized. A conveyor motor is dead, but the belt is under tension. A capacitor bank looks harmless and holds enough charge to stop your heart. Reach into that equipment without controlling those sources and the result is often an amputation or worse.
OSHA's control-of-hazardous-energy standard, at 29 CFR 1910.147, sets the general industry rules. Construction runs under 29 CFR 1926.417, and maritime under 29 CFR 1915.89. If you run a general industry facility, 1910.147 is your standard. It lands in OSHA's top ten most cited violations year after year, which tells you plenty about how many employers still get it wrong. [2]
Here's the part nobody says out loud: the procedure isn't hard. Six steps, in order, every single time.
What does OSHA's lockout/tagout standard actually require?
29 CFR 1910.147 asks four things of you. You need a written energy control program. You need machine-specific energy control procedures for equipment that gets serviced or maintained. You need to train your people. And you need to inspect each procedure at least once a year. [3] Miss any one of those and you have a paper program, not a real one.
The procedures have to be specific enough that an authorized employee can follow them machine by machine. OSHA's interpretation letters draw a narrow exception: a single generic procedure works only when eight conditions all hold. No potential for employee exposure to hazardous energy. A single energy source that's easy to spot and isolate. Isolating and locking that source fully de-energizes the machine. The machine stays isolated and locked during servicing. One lockout device does the job. That device stays under the exclusive control of the authorized employee. The servicing creates no hazard for others. And there's no history of accidents from unexpected activation. [3] Meet all eight and one procedure can cover a group of similar machines. Miss even one and you write machine-specific procedures.
Tagout alone, with no physical lock, is allowed only when the equipment has no way to accept a lockout device. Even then it protects you less, because a tag is paper. OSHA states it plainly: "Tags are essentially warning devices affixed to energy isolating devices, and do not provide the physical restraint on those devices that is provided by a lock." [3] If you can lock it, lock it.
What are the 6 steps of the lockout/tagout procedure?
Here are the six steps, in order. The order is the whole point. Skipping step five (releasing stored energy) after you've locked out in step four is the classic mistake, and it's the one that puts people in the hospital.
Step 1: Notify all affected employees
Before you touch anything, tell everyone in the area what's about to happen. Affected employees are the ones who run the equipment or work where energy control is happening. They need to know work is starting, which machine is going down, and roughly how long it'll be out. This isn't paperwork for its own sake. It stops a coworker from firing up a machine while someone's arm is inside it.
Step 2: Identify all energy sources
This is where your machine-specific procedure earns its keep. Name every energy source on the equipment: electrical, hydraulic, pneumatic, mechanical, thermal, chemical, gravitational. One machine might have a single electrical disconnect and two pneumatic supply lines. Your procedure lists all of them. You have to know every source now, because in the next steps you isolate all of them.
Step 3: Shut down the equipment
Use the machine's normal stop. Hit the stop button, flip the off switch, run the shutdown sequence, whatever the equipment is built to use. It looks obvious, and it's still a separate step, because stopping through normal controls is not the same as isolating the energy. The machine goes quiet. The energy is still there.
Step 4: Isolate all energy sources
Go to each energy-isolating device and move it to the safe, de-energized position. Electrical: open the disconnect or breaker. Pneumatic: close the supply valve. Hydraulic: close the gate valve and release line pressure. Each device gets its own lockout device. Multiple sources mean multiple locks. Every authorized employee working the machine puts their own personal lock on each isolating device. That's not optional. OSHA requires each authorized employee to keep exclusive control of their own lock. [3]
Step 5: Release or restrain all stored (residual) energy
This is the step that gets skipped, and it's the reason people get hurt after the power is off. Stored energy doesn't vanish when you isolate the source. You deal with it on purpose. Bleed the compressed air lines. Drain hydraulic pressure through the bleed-off valves. Discharge capacitors. Block or restrain parts that could fall or swing under gravity (a suspended load, a raised press ram, an elevated conveyor section). Dissipate heat. Let springs relax to neutral or block them in place. OSHA lists "release of stored energy" as a required element of energy control procedures. [3] Until stored energy reads zero, the machine can still hurt you.
Step 6: Verify de-energization before starting work
Before anyone reaches in, the authorized employee confirms the equipment is fully dead. For electrical work, that means a calibrated voltage tester reading zero at the exact points where hands will go. Push the start button to prove the machine won't run. If residual pneumatic pressure should be gone, check the gauge. This is the last safety net before hands go inside. Don't skip it because you're sure it's off. Be sure by checking. [3]
These six steps aren't suggestions. Each one maps to a specific employer obligation under 29 CFR 1910.147(d).
What's the correct order to restore equipment after LOTO work is done?
Re-energizing has its own sequence, and it runs roughly in reverse. Get it wrong and you've built a new hazard on top of a repaired machine.
First, confirm the work is done and every tool, part, and scrap of material is out of the machine. Second, confirm all employees are clear and standing somewhere safe. Third, take off any PPE that's no longer needed. Fourth, re-install the guards and safety devices you pulled for the job. Fifth, tell affected employees the lockout is coming off and the equipment is going live. Sixth, each authorized employee removes their own lock from the isolating device. Nobody removes anybody else's lock. That rule exists because only the person who set the lock knows for certain they're clear. Seventh, re-energize in the sequence the machine's procedure spells out.
When an employee forgets their lock and goes home, you need a plan already written. OSHA requires that if the authorized employee isn't available to pull their own lock, the employer must have a documented removal procedure, and the employee has to be notified before returning to work. [3] Write that procedure before you ever need it, not the night you do.
One more thing. If you leave the work area and come back on the next shift, re-verify the equipment as de-energized before work resumes. Don't assume the locks held just because they were sitting there when you left.
What equipment is covered by the LOTO standard, and what's exempt?
29 CFR 1910.147 covers "servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy could cause injury to employees." [3] That language is broad on purpose.
Generally covered: presses, conveyors, compressors, pumps, fans, HVAC units, electrical panels, hydraulic equipment, pneumatic systems, ovens, mixers, and most powered equipment you'd find in a plant or processing line.
Not covered by 1910.147, because other standards handle them: work on electric power generation, transmission, and distribution lines (29 CFR 1910.269 and 29 CFR 1926.950); cord-and-plug connected equipment where the cord is unplugged and the plug stays under the exclusive control of the person doing the work (an exemption exists, but read it carefully); hot tap operations; and minor tool changes during normal production if an alternative procedure gives effective protection. [3]
The cord-and-plug exemption trips people up. Unplug a machine and hold the plug in your hand while you work, and 1910.147 doesn't technically require a lockout device. But the second you set that plug down, someone else can plug it back in. For most real situations, locking out is still the safer call even when you're technically off the hook.
See our main lockout tagout overview for the full scope of coverage.
Who is authorized to perform lockout/tagout, and who is "affected"?
OSHA sorts employees into three groups under 1910.147.
Authorized employees lock out or tag out the machines and do the service work. They get the deepest training. They have to know how to spot hazardous energy sources, the type and magnitude of energy present, and the methods to isolate and control it. [3]
Affected employees operate or use the equipment being locked out, or work where lockout is happening. They don't apply locks in most cases, but they need to know a lockout is on, that they can't start or use the equipment, and why. Shorter training, still required.
Other employees are anyone else who might be in an area where LOTO happens. They need one thing: don't touch locks or tags. That's about the whole of their required training.
Group lockout adds a wrinkle. When more than one authorized employee works the same machine, each one sets a personal lock on each isolating device, often through a hasp (which accepts several locks on one point). Everyone exposed to the hazard has their own lock on. When a person is done and personally clear, they pull only their own lock. The machine can't come back to life until the last lock is off. [3]
Contractors add another layer. Bring in an outside crew to service your equipment and both companies have to coordinate their energy control procedures. OSHA requires each party to inform the other of its program. [3] Get that exchange in writing before the contractor lifts a wrench.
How often do lockout/tagout procedures need to be inspected and updated?
At least once a year, per 29 CFR 1910.147(c)(6). This isn't a stroll past the machine. The inspection has to be done by an authorized employee who doesn't use that particular procedure, and you certify it in writing: the machine the procedure covers, the date, the employees involved, and the name of the person doing the inspection. [3]
The reason is practical. Procedures drift from reality. Equipment gets modified. Hoses get re-routed. Someone adds a new pneumatic line and nobody updates the paper. A year later the written procedure says one thing and the machine is another. That gap is exactly where the injury happens.
Procedures also need updating when equipment changes, not on the annual clock. Add an energy source or swap an isolating device and you revise the written procedure before anyone performs LOTO on that machine again. Don't wait for the yearly cycle.
Training carries its own recurring trigger. Retraining is required whenever there's reason to believe an employee doesn't understand the procedure, when procedures change, or when an inspection turns up deficiencies. [3] There's no fixed calendar beyond those triggers, though most safety pros run an annual refresher anyway.
What does a lockout/tagout written program need to include?
Your written energy control program is the umbrella document. It doesn't have to be long, but it has to hit specific topics. Under 1910.147 it covers: the scope, purpose, rules, and techniques used; how you enforce compliance; the requirements for protective hardware (locks, tags, hasps, chains); the training requirements; and the periodic inspection requirements. [3]
Separate from the program is the machine-specific energy control procedure. For each covered machine, that procedure lists the equipment ID, the types and magnitude of hazardous energy, the methods to isolate and control it (which valves, which disconnects, in what order), and how to verify de-energization. OSHA's 1910.147 Appendix A has a non-mandatory compliance guideline that reads well as a starting template. [6]
Writing all of this from scratch for a facility with twenty machines takes real hours. If you want a head start, SafetyFolio's safety program generator can build a compliant energy control program framework in about fifteen minutes, which you then fill in with your machine-specific details. Useful if you're starting from zero. You'll still have to walk your actual equipment to nail down the energy sources. No software replaces that physical survey.
For osha training on LOTO, OSHA's own outreach materials are free on its website and make a reasonable starting point.
What are the OSHA penalties for lockout/tagout violations?
LOTO lands in OSHA's top ten most cited standards every year. In fiscal year 2023, 29 CFR 1910.147 was the fifth most frequently cited standard in general industry, with more than 2,000 citations in a single year. [2] That frequency reflects how often employers skip the written program, skimp on training, or run procedures that no longer match the machines.
The fines are real money. As of January 2024, OSHA's maximum penalty for a serious violation is $16,131 per violation. Willful or repeated violations reach $161,323 per violation. [4] One inspection that turns up three separate LOTO deficiencies (no written program, weak training, procedures not followed) can top $48,000 before any willful or repeat multiplier.
Beyond the money, a serious LOTO citation becomes public record. OSHA's inspection data is searchable by anyone. That stings if you bid work for clients who vet a contractor's safety history.
The real cost isn't the fine. It's the injury. OSHA estimates that workers hurt in LOTO-related incidents lose an average of 24 workdays per incident. [5] Add workers' comp, replacement labor, and lost output, and one serious LOTO injury usually costs a small employer far more than the OSHA fine ever would.
How is lockout/tagout training supposed to work?
Training under 1910.147 is role-specific. Authorized employees learn the type and magnitude of hazardous energy in the workplace, the methods to isolate and control it, and how to verify that isolation is complete. Affected employees learn why and when to stay clear of locked-out equipment. Other employees learn not to touch locks or tags. [3]
The training happens before employees do LOTO work. You can't train someone after they've spent six months running lockouts on their own. Initial training before task assignment is the floor, not the goal.
Retraining kicks in when the employer believes an employee lacks the knowledge, when job assignments change, when machines or processes change, or when a periodic inspection finds deficiencies. There's no magic number of years between cycles if none of those triggers fire, though most safety pros run an annual refresher anyway.
Documentation matters. Keep records with the employee's name, the training date, and the subject. OSHA doesn't mandate a format, but when a compliance officer asks whether you trained a specific person before they serviced a machine, you need paper that answers the question.
If your supervisors oversee LOTO work, an osha 30 course covers energy control at the supervisory level. It's not a substitute for machine-specific hands-on training.
What hardware do you actually need for a lockout/tagout program?
The standard requires lockout and tagout devices to be singularly identified, used only for energy control, and used for nothing else. Lockout devices have to be durable enough for the environment and strong enough that they can't come off without excessive force. [3] In practice, that means:
Personal padlocks: one per authorized employee, each keyed differently from the rest. No master keys for daily use. The key stays with the employee.
Hasps: they let multiple locks sit on a single disconnect or valve. You need these for group lockout.
Lockout tags: used on lockout devices, or alone when a lock won't fit. Each tag carries the authorized employee's name and states clearly that the equipment can't be operated. Tags have to survive their environment.
Lockout stations: wall boards or carts where hardware lives and gets inventoried. Handy for facilities with many machines, so people find the right hasp or adapter fast.
Device-specific adapters: breaker lockouts, ball valve lockouts, pneumatic valve lockouts, electrical plug lockouts. Kits often ship with dozens. If your equipment has odd isolating devices, buy the matching hardware before you need it in a hurry.
A basic lockout station kit for a small facility runs roughly $100 to $400 depending on the adapter count. Individual padlocks run $5 to $25 each. That's pocket change next to one workers' comp claim, and far less than a single OSHA fine.
How does lockout/tagout connect to other workplace safety requirements?
LOTO doesn't stand alone. It ties into several other rules and practices that small employers usually run together.
Hazard communication (29 CFR 1910.1200) comes into play when you service equipment that processes or holds hazardous chemicals, because de-energizing may also mean purging, flushing, or isolating chemical lines. The two programs have to line up so employees know the chemical hazards they might hit during LOTO work.
Machine guarding under 29 CFR 1910.212 sits right next to LOTO. Guards come off during maintenance, which is exactly when lockout applies. Putting the guards back before re-energizing is part of the restoration sequence. [10]
PPE doesn't disappear during LOTO. An authorized employee doing electrical lockout may still need arc flash PPE under NFPA 70E. Hydraulic work may need face protection. The hazard analysis for the task drives the PPE choice.
If you've had a LOTO-related incident, the incident report clock starts right away. OSHA requires reporting a fatality within 8 hours and a hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39). [8] LOTO failures cause amputations at a high rate, so those reporting duties connect directly.
Seeing how all of this fits together is what a well-run safety program looks like. Building yours from scratch? SafetyFolio's generator gives you the written program structure. The real work is training your people and walking every covered machine yourself.
Frequently asked questions
What are the 6 steps of lockout/tagout in order?
The six steps: (1) notify affected employees, (2) identify all energy sources, (3) shut down the equipment using normal stopping procedures, (4) isolate all energy-isolating devices, (5) release or restrain all stored or residual energy, and (6) verify de-energization before starting work. This sequence is required by 29 CFR 1910.147(d). Every step must be finished before work begins.
What is the difference between lockout and tagout?
Lockout puts a physical lock on an energy-isolating device so the device can't be re-energized. Tagout attaches a warning tag with no physical lock. OSHA requires lockout whenever equipment can be locked out. Tagout alone is allowed only when the equipment has no provision for a lockout device. A tag doesn't physically stop re-energization the way a lock does, which is why OSHA prefers lockout.
Who needs lockout/tagout training?
Three groups. Authorized employees, who perform LOTO and do the service work, get the deepest training including energy identification and isolation methods. Affected employees, who operate the equipment, need to know not to use locked-out machines and why. Other employees in the area need to know not to touch locks or tags. Training must happen before employees perform covered tasks, per 29 CFR 1910.147(c)(7).
Can one person do a group lockout?
Group lockout applies when more than one authorized employee works on the same equipment. Each person places a personal lock on each energy-isolating device, usually through a hasp. Each employee removes only their own lock when their work is done. The equipment can't be re-energized until every lock is off. If one person works the equipment alone, a single-person lockout applies instead.
What happens if an employee forgets to remove their lock and leaves the facility?
OSHA requires a written procedure for exactly this. It must document the steps to verify the employee isn't exposed to hazardous energy, name who is authorized to remove the lock, and require that the employee be notified before returning to work. Without a written lock-removal procedure, you're out of compliance with 29 CFR 1910.147 and have no safe way to clear the machine.
How often do lockout/tagout procedures need to be reviewed?
At least once a year, per 29 CFR 1910.147(c)(6). The inspection must be done by an authorized employee other than the one who normally uses the procedure. You document it in writing: the machine, date, employees involved, and inspector's name. Procedures also need updating whenever equipment is modified, a new energy source is added, or an isolating device changes, without waiting for the annual cycle.
Is cord-and-plug equipment exempt from lockout/tagout?
There's a limited exemption under 1910.147(a)(2)(iii)(A) for cord-and-plug connected equipment, but only when the plug is unplugged and stays in the exclusive control of the person doing the work. The moment the plug is set down, someone could re-energize it. For most real situations, locking out is still the safer choice, and OSHA's interpretation letters make clear the exemption is narrow.
What stored energy sources do I need to release during lockout/tagout?
Any energy left in the machine after the source is isolated. Common types: compressed air in pneumatic lines, hydraulic pressure in cylinders and hoses, capacitor charge in electrical equipment, gravitational energy in raised parts like press rams or suspended loads, spring tension, and residual heat in ovens or heated surfaces. Step five requires releasing, restraining, or dissipating all of these before work starts.
What OSHA standard covers lockout/tagout?
General industry: 29 CFR 1910.147, the Control of Hazardous Energy standard. Construction: 29 CFR 1926.417. Maritime: 29 CFR 1915.89. Electrical utilities have separate coverage under 29 CFR 1910.269. If you operate a general industry facility, 1910.147 is your standard, and it lands in OSHA's top ten most frequently cited violations every fiscal year.
What are the OSHA penalties for lockout/tagout violations?
As of January 2024, OSHA's maximum penalty for a serious violation is $16,131 per violation. Willful or repeated violations reach $161,323 per violation. One inspection that finds multiple LOTO deficiencies, such as no written program, weak training, and procedures not followed, can top $48,000 before any willful-violation multiplier applies.
Does lockout/tagout apply to contractors working on my equipment?
Yes. When outside contractors service or maintain your equipment, 29 CFR 1910.147(f)(2) requires your company and the contractor to inform each other of their respective lockout/tagout programs. You have to make sure the contractor's procedures are at least as effective as yours and coordinate so both sets of employees are protected. Document that coordination in writing before the contractor starts work.
Can I use a tagout-only program instead of lockout?
Only if the energy-isolating devices on your equipment can't be locked out because they have no provision for a lockout device. Tagout-only programs must add safety measures that reach an equivalent level of protection, like removing a circuit element, blocking a controlling switch, or opening an extra disconnecting device. OSHA treats tagout-only as a last resort, not a shortcut around buying locks.
What documentation do I need for a lockout/tagout program?
You need a written energy control program, machine-specific energy control procedures for each covered machine, records of the annual periodic inspection for each procedure (date, machine, employees involved, inspector name), and training records for each employee (name, date, topic). OSHA doesn't mandate a specific form for most of these, but you need enough documentation to prove compliance if a compliance officer asks.
Sources
- OSHA, Control of Hazardous Energy (Lockout/Tagout) - Safety and Health Topics page: OSHA estimates proper LOTO prevents approximately 120 fatalities and 50,000 injuries annually; roughly 3 million workers service equipment that could unexpectedly energize.
- OSHA, Top 10 Most Frequently Cited Standards: 29 CFR 1910.147 is consistently among OSHA's top ten most frequently cited standards in general industry.
- OSHA, 29 CFR 1910.147 - The Control of Hazardous Energy (Lockout/Tagout): All specific regulatory requirements cited from 1910.147 including the six-step procedure, training requirements, periodic inspection, tagout limitations, absent-employee lock removal, contractor coordination, and written program elements.
- OSHA, Penalties page: As of January 2024, OSHA's maximum penalty for a serious violation is $16,131 per violation; willful or repeated violations can reach $161,323 per violation.
- OSHA, OSHA Fact Sheet: Lockout/Tagout: Workers injured in LOTO-related incidents lose an average of 24 lost workdays per incident.
- OSHA, 29 CFR 1910.147 Appendix A - Compliance Guidelines: OSHA's non-mandatory compliance guideline provides template elements for machine-specific energy control procedures.
- OSHA, 29 CFR 1910.269 - Electric Power Generation, Transmission, and Distribution: Electrical utility work on power generation, transmission, and distribution lines is covered by 1910.269, not 1910.147.
- OSHA, 29 CFR 1904.39 - Reporting fatalities, hospitalizations, amputations, and losses of an eye: OSHA requires reporting of fatalities within 8 hours and hospitalizations, amputations, or loss of an eye within 24 hours.
- OSHA, 29 CFR 1910.212 - General Requirements for All Machines (Machine Guarding): Machine guarding requirements under 1910.212 are closely related to LOTO since guards are often removed during maintenance covered by 1910.147.
- OSHA, 29 CFR 1926.417 - Lockout and Tagging of Circuits (Construction): Construction industry lockout/tagout requirements fall under 29 CFR 1926.417, separate from general industry standard 1910.147.