Last updated 2026-07-09
TL;DR
OSHA's lockout tagout standard, 29 CFR 1910.147, requires you to control hazardous energy before anyone services or maintains equipment. It covers about 3 million workers in general industry. A compliant program needs a written energy control program, machine-specific procedures, and trained authorized and affected employees. Lockout tagout ranks among OSHA's most-cited standards every year, and the penalties are steep.
What is the OSHA lockout tagout standard?
The lockout tagout standard is 29 CFR 1910.147, formally titled "The Control of Hazardous Energy (Lockout/Tagout)." OSHA published it in 1989. It applies to general industry workplaces. Construction and maritime have their own related rules, but 1910.147 is the one most small businesses need to understand.
The rule's job is to stop the unexpected energization, startup, or release of stored energy while employees service or maintain equipment [1]. That sounds narrow. In practice it touches almost any shop, warehouse, food plant, or facility with machines that move or store energy.
Hazardous energy under the standard includes electrical, mechanical, hydraulic, pneumatic, chemical, and thermal. If you have a conveyor that could restart while someone has an arm inside it, or an air cylinder that could fire, 1910.147 applies. OSHA estimates the standard protects roughly 3 million workers and prevents about 120 fatalities and 50,000 injuries a year [1].
Tagout-only programs are allowed, but OSHA treats them as a weaker level of protection. The agency's position is blunt: if you can feasibly apply a lockout device to a piece of equipment, you must use lockout instead of tagout [1]. Tags don't physically stop re-energization. Locks do.
Who does 29 CFR 1910.147 apply to?
The standard covers general industry employers whose workers service or maintain machinery where unexpected energization or startup could cause injury. It does not apply to electrical hazards covered by 29 CFR 1910.331 through 1910.335, construction work under 29 CFR 1926, agriculture, or marine terminals covered elsewhere [7].
Small manufacturers are one of the most common places OSHA finds lockout violations. A machine shop with five employees whose workers change tooling or clear jams on a press is squarely covered. A restaurant probably isn't covered for routine cleaning of commercial kitchen equipment, unless that cleaning means removing guards or putting a body part into a hazard zone.
The standard also skips normal production operations, meaning routine work using the controls the manufacturer built for that purpose, with guards in place. The moment a worker opens a guard, reaches into a point of operation, or services a machine, the standard kicks in [1]. That line matters for small employers trying to sort out which tasks actually need lockout procedures.
What are the main requirements of the lockout tagout standard?
There are six core things 29 CFR 1910.147 requires. Miss any one and you have a citable violation.
1. Written energy control program. You need a documented program covering your scope, rules, and enforcement. It has to be specific enough to be useful. A generic one-pager you downloaded off the internet will not pass an inspection [2].
2. Energy control procedures for each piece of equipment. This is where most small employers fall short. You need machine-specific procedures that identify the type and magnitude of energy, the steps to shut down and isolate, where the energy isolation points are, and how to release or restrain stored energy. OSHA lets one procedure cover multiple machines only if they're identical in type, size, energy source, and hazard [2].
3. Employee training. Three categories of workers need training. Authorized employees (those who actually lock out equipment) need full training on energy control. Affected employees (those who operate equipment others lock out) need to know why they shouldn't touch the machine or try to restart it. Other employees who work nearby need awareness-level training [1].
4. Periodic inspections. At least once a year, a qualified person reviews each energy control procedure with the employees who use it. The inspection gets certified with the machine name, date, employees involved, and inspector's name [1].
5. Hardware. Locks, hasps, tags, and other energy-isolating devices come from the employer and get used for nothing else. They have to be durable, standardized in color or shape, and strong enough that nobody removes them without force [1].
6. Contractor coordination. When outside contractors do maintenance, you tell them your lockout procedures and they tell you theirs. You make sure the two don't conflict [1].
See also the lockout tagout overview for a plain-language breakdown of each step in the actual procedure.
What does a lockout tagout written program need to include?
The written energy control program governs your entire lockout system. OSHA doesn't hand you a rigid template, but the regulation at 1910.147(c)(1) says it must cover "the purpose, rules, and techniques" you use plus the means of enforcing compliance [1].
At minimum, a defensible written program covers:
- Scope: which equipment and operations are covered
- Roles and responsibilities: who authorizes, who is affected, who supervises
- The general procedure sequence (shut down, isolate, lock out, release stored energy, verify)
- What happens when an authorized employee's shift ends before the work is done (shift change procedures)
- How you handle group lockout when several workers service the same machine at once
- How you handle contractors
- What to do if a lock has to come off in an emergency when the authorized employee isn't available
- How you run and document the annual inspection
The machine-specific energy control procedures usually hang off the written program as appendices or a separate binder. They aren't the same thing as the program itself, but they're part of the overall compliance picture.
Want a starting point that matches the standard's structure without paying a consultant to build one from scratch? Tools like SafetyFolio's safety program generator can produce a program framed around your equipment list in about 15 minutes. That still doesn't replace accurate machine-specific procedures, which need someone who has walked the floor.
What are the steps in a lockout tagout procedure?
OSHA lays out the sequence in 1910.147(d). Here's how it runs in practice.
Step 1: Notify affected employees. Tell the operators and anyone nearby that the machine is going down for service.
Step 2: Identify all energy sources. Electrical panels, hydraulic lines, pneumatic supplies, gravity-loaded parts, spring tension, steam lines, all of it. Skipping a secondary source is how people get hurt.
Step 3: Shut down the equipment using the normal stopping procedure.
Step 4: Isolate each energy source. Throw the disconnect, close the valve, block the part. The isolation device moves to the off or closed position.
Step 5: Apply locks and tags. Each authorized employee working on the equipment puts a personal lock on each isolation point. Two people working means two locks. That's the whole point of individual locks.
Step 6: Release or restrain stored energy. Bleed the air line. Block the suspended component. Discharge the capacitor. Drain the hydraulic accumulator. Stored energy has killed workers whose machines were locked out at the panel but still held pressure downstream.
Step 7: Verify the equipment is de-energized. Try to start it. Check with a meter. Confirm zero energy before touching anything. OSHA calls this verification of isolation, and it's required [1].
To re-energize after the work is done, run the sequence in reverse: remove tools and parts, account for everyone (each worker pulls their own lock), notify affected employees, then power it back up.
How often does OSHA cite lockout tagout violations, and what are the penalties?
Lockout tagout lands in OSHA's top ten most-cited standards year after year. In fiscal year 2023, 29 CFR 1910.147 was the fifth most-cited standard, with 2,554 violations [3]. This is not a fringe regulation. It gets cited about as often as fall protection does in construction.
The penalties bite. OSHA's maximum for a serious violation in 2024 is $16,131 per violation, and willful or repeated violations can reach $161,323 per instance [4]. When a fatality or catastrophic injury happens and the employer had no lockout program at all, penalties climb well into six figures.
One number worth memorizing: OSHA estimates about 10 percent of all serious accidents in manufacturing tie back to inadequate lockout tagout [1]. The BLS Census of Fatal Occupational Injuries shows contact with objects and equipment, a category that includes the caught-in and struck-by events lockout is built to prevent, was the third leading cause of workplace fatalities in 2022, with 705 deaths [5].
The table below compares 1910.147 citation frequency against a few other commonly cited general industry standards in FY2023.
| Standard | Description | FY2023 Citations |
|---|---|---|
| 29 CFR 1910.147 | Lockout/Tagout | 2,554 |
| 29 CFR 1910.1200 | Hazard Communication | 3,213 |
| 29 CFR 1910.132 | PPE General Requirements | 2,074 |
| 29 CFR 1910.212 | Machine Guarding | 1,874 |
| 29 CFR 1910.305 | Electrical Wiring Methods | 1,590 |
Sources: OSHA FY2023 Top 10 violations data [3].
See also the hazard communication standard if your facility uses chemicals, since the two programs often show up together in the same compliance review.
What training is required under the lockout tagout standard?
Training under 1910.147(c)(7) is specific about who needs what. Authorized employees, the people who actually apply locks, need training on the hazardous energy sources in their workplace, the type and magnitude of energy, and the methods for isolation and control [1]. This has to be hands-on. Watching a video isn't enough if the employee can't show they know where every isolation point sits on their machines.
Affected employees need to know the purpose of the energy control program and that they must not restart or re-energize equipment that's locked out. They don't need the full authorized-employee training.
Other employees who work in areas where lockout happens must be trained to recognize when a procedure is in use and to leave locked-out equipment alone.
Retraining is required when there's reason to believe an employee doesn't understand their role, when job assignments or machines or processes change, or when the periodic inspection turns up gaps [1]. OSHA doesn't set a fixed retraining interval beyond that inspection trigger. Some employers retrain every year out of habit, which is fine but not strictly required unless the inspection shows a problem.
You have to certify training happened. Certification means a written record with each employee's name, the training date, and what was covered. No format is mandated, but you need to produce it during an inspection.
For a wider look at how OSHA training requirements work across different standards, that page covers the general framework.
What is the annual periodic inspection requirement?
Section 1910.147(c)(6) requires an annual inspection of each energy control procedure. This is one of the more misunderstood parts of the standard. It's more than a paper audit. You watch an authorized employee run the procedure on the actual machine and correct any deviations you find [1].
The inspection has to be done by an authorized employee who isn't the one being evaluated. The text doesn't spell that out word for word, but OSHA's enforcement guidance and interpretation letters treat self-certifying inspections with suspicion. Having a safety manager or a senior authorized employee review the procedure with each worker is the practical move.
Documentation is required. OSHA says the certification must include the machine or equipment, the date, the employees involved, and the name of the person who did the inspection [1]. Keep these records somewhere you can find them. An inspector will ask.
If your annual inspection shows the written procedure is wrong (the machine got modified, an energy source got added), fix the procedure before the next use. That's the point of the inspection. It's a living-document check, not a compliance box.
For tagout-only programs, the annual inspection also has to review the limits of tagout versus lockout, OSHA's way of reminding everyone that a tag is a warning, not a physical restraint [1].
What is an OSHA lockout tagout checklist and how do you use one?
An OSHA lockout tagout checklist is a field tool, not an OSHA-published form. OSHA doesn't provide an official checklist. What people mean by the term is either a compliance audit checklist to verify your program covers everything 1910.147 requires, or a step-by-step job aid authorized employees use during an actual lockout.
For compliance auditing, a useful checklist covers these items:
- Written energy control program exists and is current
- Machine-specific procedures exist for all covered equipment
- Procedures include energy type, magnitude, and isolation point locations
- Employer-provided lockout hardware is available and dedicated to LOTO only
- All authorized employees have documented training
- All affected and other employees have documented awareness training
- Annual inspections are current and certified
- Group lockout procedures are addressed if multiple workers service the same machine
- Contractor coordination procedures exist
- Shift change provisions are documented
For a daily field checklist, the authorized employee runs the seven-step sequence (notify, identify, shut down, isolate, apply lock, release stored energy, verify) and signs off. Some facilities build this into a paper tag that stays on the machine while it's locked out.
The checklist doesn't replace a written program. It's a prompt to make sure the written program is being followed. An inspector cares far more about whether your program is current and your people are trained than whether you have a laminated checklist on the wall.
How does lockout tagout apply to specific industries like manufacturing, food processing, and construction?
The general industry standard, 1910.147, is written for manufacturing, processing, warehousing, and similar operations. Its requirements stay the same across industries within that scope, but how you apply them shifts a lot with the equipment and energy involved.
In manufacturing, the usual trouble spots are presses, conveyors, robotic cells, and mixing equipment. Multi-step machinery with several energy sources often needs group lockout procedures and hasps that hold multiple locks at once. Robotic cells are a particular headache because isolating a robot means more than cutting power. You also have to handle stored-energy positions and pneumatic actuators [6].
In food processing, sanitation crews carry the highest risk. Cleaning inside grinders, mixers, and slicers is exactly the servicing activity 1910.147 covers. OSHA has cited plenty of food plants for lacking procedures that specifically address sanitation tasks, which tend to happen at shift change when coordination breaks down.
Construction falls under 29 CFR 1926 subpart K for electrical work, not 1910.147. But construction contractors who maintain manufacturing equipment at a general industry site are subject to the host employer's 1910.147 program and the contractor coordination requirement [1].
Oil and gas operations sometimes sit under process safety management (29 CFR 1910.119) rather than lockout tagout, though both can apply at the same time depending on the task.
One more industry note: 29 CFR 1910.147 covers electrically powered equipment, but machines running on stored mechanical, hydraulic, or other alternative energy are covered too. Plenty of small shops assume lockout is only about electrical panels. It isn't.
What are the most common lockout tagout violations OSHA finds?
OSHA's citation data and enforcement activity point to a predictable set of failures under 1910.147.
No written energy control program. Some employers never wrote one. This is usually a serious violation.
No machine-specific procedures. The employer has a general program but no procedures for individual pieces of equipment. This is the single most common specific deficiency OSHA documents.
Training not documented or not performed. Workers doing lockout with no training records. This also covers failing to retrain after an equipment or process change.
No annual periodic inspection. The employer never runs or documents the required annual review.
Inadequate hardware. General-purpose locks instead of dedicated lockout locks, or tags that miss the durability requirements at 1910.147(c)(5).
Failure to address stored energy. Electrically isolating a machine but leaving pneumatic, hydraulic, or gravitational energy unreleased. This is the one that kills people.
Group lockout failures. Several workers service the same machine but only one lock goes on, leaving everyone else unprotected the moment that one person walks away.
The pattern in OSHA inspection reports is clear. Employers with a written program but sloppy field execution tend to draw serious violations. Employers with nothing draw willful citations and much higher penalties. A mediocre program is genuinely better than no program from a penalty standpoint, though it obviously protects workers worse than a good one.
To see how past violations played out, you can search OSHA's public inspection database by standard number and read the actual citations [9].
How do you build a lockout tagout program from scratch?
Start with a walk-through of your facility to identify every machine that needs servicing or maintenance and carries a hazardous energy source. Write down what you find. For each machine, note the type and magnitude of energy, where every isolation point is, and how to release or restrain stored energy. That inventory becomes the foundation for your machine-specific procedures.
Write the energy control program next. You can base it on OSHA's sample program in Appendix C of 29 CFR 1910.147, which is non-mandatory but gives you the structure [2]. The program document doesn't need to run long. Three to five pages covering scope, roles, the general procedure, group lockout, contractor coordination, and enforcement is plenty.
Then write machine-specific procedures. One procedure per machine, or per group of identical machines. Use a standard form with fields for machine name, equipment ID, energy sources, isolation locations, steps in sequence, and verification method. Keep them where workers can reach them, on the machine itself or in a nearby station.
Train authorized and affected employees before they work under the program. Document every session. Schedule your first annual inspection for 12 months out and put it on the calendar now.
Want to move faster? SafetyFolio can generate a written energy control program tailored to your workplace in about 15 minutes. You still walk your floor and write the machine-specific procedures yourself, but getting the program structure right up front saves time and closes a common compliance gap.
Budget for hardware too. A basic lockout station with locks, hasp, tags, and a pouch runs roughly $50 to $150 from industrial suppliers. Facilities with many isolation points spend more, but that's not where the real cost sits. The cost is your time to write procedures and run training, which for a small facility with 10 to 15 machines is typically 8 to 20 hours of internal labor.
What is the difference between lockout and tagout, and when can you use tagout only?
Lockout uses a physical lock to hold an energy-isolating device in the safe position. Tagout uses a warning tag on the isolation point to tell others the equipment must not run. The difference is physical force versus a warning sign.
OSHA's rule is direct: "Lockout shall be used as the preferred method of controlling hazardous energy" [1]. Tagout is allowed only when the equipment can't be locked out because the machine's design won't let a lockout device attach to the energy-isolating device.
Go tagout-only and OSHA requires extra protective measures to match the protection lockout gives. That means removing an isolating circuit element, blocking a controlling switch, opening an extra disconnecting device, or pulling a valve handle [1]. These steps aren't optional when you go tagout-only. They exist because a tag by itself provides zero physical restraint.
Most equipment built after 1989 has lockable isolation points precisely because of this standard. Older equipment may not. If you have older machinery with no lockable isolation, you face a choice: retrofit it with an attachable lockout device (many run $5 to $30 per point from safety suppliers), or run a compliant tagout-only procedure with the additional controls in place.
OSHA interpretation letters have stayed consistent that tagout-only programs carry a higher burden of proof during inspection. The agency's guidance states that lockout is preferred when maximum safety is desired [6]. If you can lock it, lock it.
Frequently asked questions
Does the lockout tagout standard apply to small businesses with fewer than 10 employees?
Yes. 29 CFR 1910.147 has no small-employer exemption. If you have even one employee who services or maintains equipment with hazardous energy sources, the standard applies. Small employers are exempt from some OSHA programmed inspections, but if an injury occurs or a complaint gets filed, OSHA will inspect regardless of size.
Do I need separate lockout tagout procedures for every single machine?
Generally yes, one procedure per machine. OSHA does allow a single procedure to cover multiple machines if they're identical in type, energy source, and hazard level. A fleet of identical conveyors can share one procedure. A press and a conveyor cannot. When in doubt, write separate procedures. The cost of one extra page beats a citation.
Can employees use their own personal padlocks for lockout tagout?
No. OSHA requires the employer to provide lockout devices, and they must be dedicated to energy control and used for nothing else. A personal padlock someone also uses on a gym locker doesn't meet the standard. Employer-provided locks should be standardized in color or marking and assigned to individual authorized employees only.
What happens if an authorized employee leaves at the end of their shift and their lock is still on a machine?
Your written program must address this. OSHA doesn't require a specific shift-change procedure but does require your program to cover it. A common approach is a shift-change log where the incoming authorized employee applies their lock before the outgoing one removes theirs, so the machine is never unprotected between shifts.
Is lockout tagout training required every year?
The standard doesn't require annual retraining on a fixed schedule. Retraining is required when an employee's knowledge or performance is deficient, when job assignments or equipment change, or when the annual inspection reveals gaps. Many employers retrain annually anyway as a practical matter, but the annual inspection requirement is what drives the regulatory calendar.
Does lockout tagout apply to electrical work covered by NFPA 70E?
The electrical safety work practices in 29 CFR 1910.331 through 1910.335 apply to electrical hazards and pull those tasks out of 1910.147. NFPA 70E is a consensus standard OSHA may cite as evidence of recognized practice. For most maintenance tasks that aren't purely electrical, 1910.147 applies even when electrical energy sits among several hazard types.
What is a group lockout hasp and when do you need one?
A group lockout hasp lets multiple padlocks attach to a single isolation point at the same time. You need one whenever more than one authorized employee works on the same machine at once. Every worker applies their own lock to the hasp, so the machine can't be re-energized until all locks come off. Group lockout is covered at 1910.147(f)(3).
How long do I need to keep lockout tagout training records?
OSHA's lockout tagout standard doesn't specify a retention period for training certifications. As a practical matter, most employers keep records at least three years to cover OSHA's citation window (six months from the violation, but prior-year records help establish compliance history). Keep annual inspection certifications at least three years too.
Can a contractor working in my facility follow their own lockout tagout program instead of mine?
Yes, under 1910.147(f)(2), outside contractors may use their own procedures. But you must coordinate so the procedures don't create hazards for your employees, and you must inform them of your energy control procedures. Both programs get followed, and you must make sure they don't conflict. Get the contractor's written procedures before work begins.
What is the OSHA penalty for not having a lockout tagout program?
A missing or inadequate written energy control program is typically cited as a serious violation, with a maximum penalty of $16,131 per instance in 2024. If OSHA finds the employer knew the requirement existed and willfully ignored it, the maximum jumps to $161,323 per violation. After a fatality, willful citations are common.
Does the lockout tagout standard apply to cord-and-plug connected equipment?
Generally no, with conditions. Cord-and-plug connected equipment is excluded from 1910.147 if the plug stays under the exclusive control of the employee doing the servicing, meaning they hold the plug and can see it the entire time. If someone else could plug it back in while the employee works, lockout tagout requirements apply.
How is lockout tagout related to machine guarding requirements?
They're complementary, not interchangeable. Machine guarding under 29 CFR 1910.212 prevents contact during normal operation. Lockout tagout protects workers during servicing when guards come off. An OSHA inspection checks both. If a machine needs its guard removed for maintenance, a lockout procedure covering that task is expected.
Sources
- OSHA, 29 CFR 1910.147 (The Control of Hazardous Energy): Full text of the lockout tagout standard covering purpose, scope, written program, procedures, training, periodic inspection, hardware, and tagout limitations
- OSHA, Control of Hazardous Energy (Lockout/Tagout) topic page: OSHA guidance on written energy control programs, machine-specific procedures, and the non-mandatory Appendix C sample program
- OSHA, Top 10 Most Cited Standards FY2023: 29 CFR 1910.147 was the fifth most-cited general industry standard in FY2023 with 2,554 violations
- OSHA, Civil Penalty Adjustments (Penalties page): Maximum serious violation penalty of $16,131 and willful/repeated penalty of $161,323 per instance in 2024
- Bureau of Labor Statistics, Census of Fatal Occupational Injuries 2022: Contact with objects and equipment was the third leading cause of workplace fatalities in 2022, accounting for 705 deaths
- OSHA, Lockout/Tagout eTool: OSHA guidance on robotic cell energy isolation, tagout-only program limitations, and the statement that lockout is preferred when maximum safety is desired
- OSHA, 29 CFR 1910.331-335 (Electrical Safety Work Practices): Electrical safety work practice standards that exclude covered electrical tasks from 1910.147 scope
- OSHA, 29 CFR 1910.212 (Machine Guarding): Machine guarding standard that operates alongside 1910.147 for equipment with moving parts
- OSHA, Establishment Search (Inspection Database): Public database of OSHA citations searchable by standard number, used to research actual citation outcomes