Lockout tagout steps: the complete sequence every worker needs

Last updated 2026-07-10

What is lockout tagout and why does the step sequence matter?

Lockout tagout (LOTO) is the OSHA-required procedure for controlling hazardous energy during equipment service and maintenance. The regulation is 29 CFR 1910.147, called the "Control of Hazardous Energy" standard, and it applies to general industry. Construction has a parallel requirement under 29 CFR 1926.417. ^[1][9]

The sequence matters for one reason. Skipping or reordering steps kills people.

OSHA estimates that proper energy control prevents roughly 120 fatalities and 50,000 injuries every year. The Bureau of Labor Statistics tracks machinery-related deaths in its annual fatal injury census, and the numbers stay high enough that LOTO has ranked in OSHA's top 10 most cited standards for years running. ^[2][8]

The standard tells authorized employees to follow the established procedure in a set order, and inspectors write citations when a worker skips verification or pops a lock before re-notifying the crew. That order is not a suggestion. It's the enforceable part. ^[1]

One more thing worth getting straight: lockout and tagout are not the same. A lockout device (a physical lock) makes the isolating device impossible to operate. A tagout device (a standardized warning tag) only warns people not to re-energize. Where you can attach a lock, you use one. Tagout alone is allowed only when the equipment design blocks a lock, and even then you owe extra protective measures. ^[1]

For how the whole program fits together, see our guide on lockout tagout.

What are the 8 steps of lockout tagout in order?

Here are the eight steps that 29 CFR 1910.147 and OSHA's compliance directive CPL 02-00-147 describe. Your written procedure has to cover all of them, and authorized employees have to perform them in this order. ^[1][3]

Step 1: Prepare for shutdown. Before you touch anything, identify every energy source connected to the equipment: electrical, pneumatic, hydraulic, mechanical, thermal, chemical, gravitational. Read the machine-specific energy control procedure for that exact machine. Gather your locks, hasps, tags, blocks, and restraints. Do not improvise on the fly.

Step 2: Notify affected employees. Tell everyone who works on or near the equipment that it's going down and why. These workers aren't performing the shutdown. They just need to know it's happening so nobody tries to run the machine mid-service. Name this step in your written procedure, because inspectors look for it by name.

Step 3: Shut down the equipment. Use the normal stopping procedure: press stop, close valves, flip breakers, whatever the machine-specific procedure calls for. This is a controlled shutdown, not an emergency stop.

Step 4: Isolate all energy sources. Move every energy-isolating device (circuit breaker, valve, block) to off or closed. Each source gets its own isolation point. If a machine has three separate electrical feeds, all three get isolated. This is where small shops get burned: someone kills the main breaker and never touches the secondary control circuit.

Step 5: Apply lockout/tagout devices. The authorized employee puts a personal lock and tag on each energy-isolating device. One person, one lock, name on it. On a group job, every authorized employee adds their own lock to a hasp at each isolation point. The device goes on the isolating device itself, never on some downstream part. ^[1]

Step 6: Release or restrain stored energy. This is the step most workers get wrong. Isolated equipment can still hold deadly energy: charged capacitors, springs under tension, hydraulic lines under pressure, parts suspended by gravity, steam in pipes. Bleed it, drain it, block it, or restrain it. The standard calls for "relieving, disconnecting, restraining, and otherwise rendering safe all potentially hazardous stored or residual energy." ^[1]

Step 7: Verify a zero energy state. Try to start the machine with the normal controls. Use a meter or gauge to confirm zero voltage, zero pressure, zero stored energy of every type. This is the last gate before work begins. Find any energy present, and you go back to Step 4.

Step 8: Perform the maintenance or service work. Now, and only now, the actual work starts.

When the work is done, a restoration sequence mirrors this in reverse: remove tools and materials, get all workers clear, remove lockout devices (only by the person who applied them), notify affected employees, then restore energy. Some people call that Step 9. The standard treats it as a defined return-to-service sequence rather than a separate numbered step in the isolation procedure. ^[1]

What is the final step in lockout tagout?

People ask this two ways, and the answer depends on which end of the procedure you mean.

The final step before work begins is verifying the zero energy state (Step 7). You hit the start button, read the gauges, and meter the circuit to confirm the machine can't move and holds no residual energy. Check out clean, and work proceeds. That verification is the last barrier between a worker and a machine that might still bite.

The final step in the full procedure, restoration included, is putting energy back and telling affected employees the equipment is live again. Before you re-energize, you have to confirm all tools and parts are off the machine, get every employee clear of the equipment, verify all lockout/tagout devices are removed, re-energize using the normal procedure, then notify affected employees the machine is running. ^[1][3]

OSHA letters of interpretation are clear that only the authorized employee who applied a lock may remove it, with narrow exceptions for shift changes and emergencies, and those exceptions demand written procedures. ^[4] If someone else pulls your lock, that's a serious violation.

Restoration gets its own emphasis because a large share of LOTO injuries happen right here, when someone assumes the job is finished and re-energizes before the last worker steps clear.

What does a machine-specific energy control procedure need to include?

29 CFR 1910.147(c)(4) says every employer must develop, document, and use energy control procedures for each machine or type of equipment where unexpected energization could hurt someone. ^[1] The procedure has no required format, but it has to cover specific elements or it doesn't count.

At minimum, the written procedure identifies the equipment by name and location, lists every step for shutting it down and isolating energy, states the type and magnitude of each energy source, and describes the method for controlling each one. The compliance directive CPL 02-00-147 hands inspectors a checklist of exactly what they look for. ^[3]

For most small shops, this ends up as a laminated one-page sheet posted on or near each machine. It shows a diagram of where the breakers, valves, and lockout points sit, the size of lock or hasp needed, and the verification method. A vague line like "turn off machine before servicing" fails the standard and draws a citation.

The standard does allow a shortcut. If you can demonstrate that one procedure covers a group of machines with identical energy sources, types, and magnitudes, you can use that single procedure for the whole group. Any machine with unique energy inputs still needs its own document. ^[1]

This is the part where a tool like SafetyFolio's safety program generator saves you hours. Writing machine-specific procedures with every required element is tedious work that most small businesses start and never finish. A template built to match 1910.147 gets you to a reviewable draft in minutes.

How does group lockout work when multiple workers are on the same job?

When more than one authorized employee works on the same equipment, the standard requires a group lockout procedure. Each authorized employee applies a personal lock to a group hasp or box. The equipment stays dead until the last lock comes off. ^[1]

This is not optional. A supervisor cannot hold one master lock for the whole crew. The entire point is that no single person can restore power while another worker is still inside the machine.

Jobs that cross shifts need a shift transfer procedure that keeps protection unbroken. The outgoing employee's lock stays on until the incoming employee applies their own. Only then does the first lock come off. Your written program has to spell out how that handoff works, because a missing shift transfer procedure is a common inspection finding. ^[3]

For complex jobs with several contractors on site, each contractor's authorized employees follow their own employer's LOTO program, and the host employer coordinates between programs so they don't conflict. 29 CFR 1910.147(f)(2) addresses that coordination directly. ^[1]

What training does OSHA require for lockout tagout?

OSHA sorts LOTO workers into three groups with different training: authorized employees, affected employees, and other employees. ^[1]

Authorized employees apply the locks and do the work. They need training on recognizing hazardous energy sources, the type and magnitude of energy in their workplace, and the methods to isolate and control it. That training has to be specific to the equipment they'll actually service.

Affected employees run the equipment or work in the area where LOTO happens. Their core lesson is simple: when a lock or tag is on a machine, you do not try to restart it.

Other employees only need to know LOTO devices exist and must not be touched.

Retraining is required when an employee shows they don't understand the procedure or when procedures change. The standard sets no fixed interval, but annual retraining is a sensible floor and what most compliance help recommends in practice. ^[1]

Training certification has to be documented with the employee's name, the date, and what was covered. Inspectors ask for these records, and verbal-only training counts for nothing.

If your supervisors want a solid base in energy control and broader compliance, OSHA 30 training covers LOTO inside the general industry curriculum. For a wider look at structured worker education, see our overview of OSHA training options.

How often do you need to inspect your lockout tagout procedures?

At least once a year. 29 CFR 1910.147(c)(6) requires an annual inspection of each energy control procedure. ^[1] This isn't a general safety audit. It's a procedure-specific review done by an authorized employee other than the one who normally uses that procedure.

For lockout procedures, the annual inspection includes a review of the procedure with each authorized employee. Tagout-only procedures get stricter treatment: the review has to be more detailed and must reinforce the extra limits of tags compared to locks.

The employer must certify the inspection happened. That certification identifies the machine or equipment, the date, the employees involved, and the person who performed it. ^[1] Keep it available for OSHA review.

Here's where small businesses lose. They write a procedure, train on it once, and never look again. Equipment changes. Energy sources get added or rerouted. The original procedure quietly goes stale. An annual inspection catches that drift before an inspector does.

If you have an incident involving equipment energy in that window, document it carefully. Our guide on filing an incident report covers what OSHA wants when someone gets hurt.

What are the most common OSHA violations found during lockout tagout inspections?

LOTO lands in OSHA's top 10 most cited standards nearly every year. In fiscal year 2023, 1910.147 drew 2,554 citations, the fifth most cited standard across general industry. ^[5]

Here's what inspectors find most often.

No written procedures for specific machines. The single most common finding: a generic LOTO program with no machine-specific procedures behind it. 1910.147(c)(4) requires written procedures for each piece of equipment unless an exception applies.

Failure to address all energy sources. An electrician isolates the power feed but ignores the pneumatic line. Someone locks the breaker but never bleeds the hydraulic accumulator. Inspectors test this by asking a worker to walk the procedure on a real machine.

Improper tagout instead of lockout. Tags used where a lock would fit. Tags are permitted only when lockout isn't feasible, and even then extra protective measures are required. ^[1]

Missing or incomplete training records. Verbal training with no paperwork doesn't count.

No annual procedure audits. A hard requirement, and a routine finding.

No group lockout procedure. Multi-worker jobs with no individual-lock rule.

Penalties for serious violations run from a few thousand dollars up to $16,550 per violation as of 2024, with willful or repeated violations reaching $165,514 each. ^[6]

When is tagout alone allowed instead of lockout?

The standard's preference is blunt: if you can apply a lock, apply a lock. Tagout alone is allowed only when the energy-isolating device can't be locked out, meaning it was built without a hasp or locking mechanism and no adapter works. ^[1]

Go tagout-only, and the standard demands additional protective measures that give safety equal to lockout. OSHA lays these out in 1910.147(c)(3) and in CPL 02-00-147. They can include removing an isolating circuit element, blocking a controlling switch, opening an extra disconnecting device, or pulling a valve handle. ^[1][3]

Tagout devices have to be standardized across your facility in color, shape, and size. They must hold up to the environment where they'll hang. And they carry a warning statement such as "Do Not Start, Do Not Open, Do Not Close, Do Not Energize, Do Not Operate." ^[1]

My honest opinion: if your equipment lacks hasp-ready isolation points, retrofit them. A lockout hasp kit for a breaker runs under $20. Running a tagout-only program, with its extra procedural steps and inspection scrutiny, almost always costs more than upgrading the hardware once.

What are some real examples of what goes wrong when steps are skipped?

OSHA's inspection records and fatality/catastrophe reports (available at osha.gov) document hundreds of LOTO-related deaths and amputations. The patterns repeat.

A maintenance worker climbs into a machine to clear a jam. The operator, not knowing anyone's inside, starts it. No lockout was applied. This kind of event, sometimes called unexpected energization, is exactly what 1910.147 exists to stop.

A worker locks out a hydraulic press but never releases the stored energy. The ram drops the moment a line is disconnected. Stored energy incidents are disproportionately fatal because hydraulic and pneumatic forces are large and instantaneous.

Shift change. The outgoing worker pulls their lock, assuming the incoming worker is set. The incoming worker is still inside the machine. No shift transfer procedure existed.

The common thread: a step got skipped, or the sequence got treated as optional. The standard's insistence on a documented, step-by-step order is a direct answer to these exact failures.

Nobody has a clean national count of how many incidents each specific skipped step causes. The closest picture comes from OSHA's fatality data and enforcement files, which show failures cluster around stored energy release (Step 6) and verification (Step 7). Those two steps feel redundant when you're in a hurry. They aren't.

How do you write a lockout tagout program for a small business?

A compliant LOTO written program for a small business has to cover seven things. ^[1]

1. The scope and purpose (which equipment and operations it covers) 2. Rules and techniques for applying energy control (who can apply locks, what devices are used) 3. Rules for using energy control devices (uniqueness, durability, standardization) 4. Machine-specific procedures for each covered piece of equipment 5. Training requirements and records 6. The annual inspection process and certification method 7. The procedure for removing a lock when the person who applied it isn't available

The machine-specific procedures are the hard part because every machine differs. Walk each one with an operator who knows it. List every energy source: electrical panels, control circuits, pneumatic lines, hydraulic accumulators, gravity-held components, springs. For each, write down the isolation point, the lockout device required, and the verification method.

Most small shops end up with a two to four page written program. Machine-specific procedures run one page each, usually with a simple diagram. A 10-machine shop might carry 15 pages of LOTO documentation total.

If building this from scratch feels like a project that never gets finished, SafetyFolio's safety program generator walks you through the required elements machine by machine and outputs a document you can hand to an inspector.

For how LOTO fits into your broader OSHA compliance picture, and which other written programs you're required to have, start with the basics.

How does lockout tagout differ from hazard communication requirements?

LOTO and hazard communication (HazCom) are both general industry standards, but they cover different hazards. LOTO covers energy hazards during equipment service. HazCom (29 CFR 1910.1200) covers chemical hazards: labeling, safety data sheets, and training on chemical properties. ^[7]

They overlap in one practical spot. If you're servicing equipment that handles hazardous chemicals, and the work involves opening lines or exposing workers to those chemicals, both programs run together. Your LOTO procedure should name the chemical energy hazard and any PPE required. Your HazCom program should be reachable by workers who hit a chemical release during maintenance.

For a plain explanation of chemical hazard rules, see our guide on hazard communication.

The enforcement tone differs too. LOTO citations tend to be serious or willful when equipment is in service without proper isolation. HazCom citations skew other-than-serious for missing labels or an incomplete SDS binder, though a chemical exposure can escalate fast. Both programs need written documentation, training records, and annual review.

Frequently asked questions

What is the correct order of lockout tagout steps?

The correct order is: (1) prepare and identify all energy sources, (2) notify affected employees, (3) shut down the equipment using its normal stopping procedure, (4) isolate all energy sources, (5) apply lockout or tagout devices to each isolating device, (6) release or restrain all stored energy, (7) verify a zero energy state, then perform the work. Restoration reverses this sequence.

What is the final step in lockout tagout before work begins?

The final step before work begins is verifying the zero energy state. The authorized employee tries to start the equipment using its normal controls and uses instruments like a voltmeter or pressure gauge to confirm every energy source reads zero. Only after a clean verification does the service work start. If any energy shows up, the worker goes back to isolation and stored energy release.

Can an employer use one lockout tagout procedure for all machines?

Only if all machines share identical energy types, magnitudes, and isolation points. 29 CFR 1910.147(c)(4) allows a single procedure for a group of machines when those conditions hold. In practice, most shops need machine-specific procedures because equipment differs. Using a generic procedure for dissimilar equipment is one of the most common OSHA LOTO citation categories.

Who is allowed to remove a lockout device?

Only the authorized employee who applied it. If that person is unavailable, the written program must describe an emergency removal procedure, which typically requires the supervisor to verify the employee is out of the danger zone, try to reach them, and document the removal in writing. OSHA letters of interpretation confirm this is a narrow exception, not routine practice. ^[4]

How often must lockout tagout procedures be reviewed?

At least once per year. 29 CFR 1910.147(c)(6) requires an annual certification inspection of each energy control procedure. The inspection must include a review with each authorized employee who uses that procedure. For tagout-only procedures, the review requirements are more extensive. The inspection must be certified in writing with the machine, date, employees, and inspector identified.

What is stored energy and why does releasing it matter?

Stored energy is any energy left in equipment after the main source is isolated. Examples: charged capacitors, pressurized hydraulic or pneumatic lines, springs under tension, suspended loads held by gravity, and steam in pipes. Stored energy has caused many LOTO deaths because workers assumed isolation was enough. Step 6 of the sequence requires bleeding, blocking, draining, or restraining every stored energy source before work starts.

What OSHA standard covers lockout tagout?

The primary standard is 29 CFR 1910.147, "The Control of Hazardous Energy (Lockout/Tagout)," which applies to general industry. Construction work falls under 29 CFR 1926.417. Maritime has separate provisions. OSHA's compliance directive CPL 02-00-147 gives inspectors detailed enforcement guidance and is public on osha.gov.

What is the difference between an authorized employee and an affected employee in LOTO?

An authorized employee locks or tags out equipment and performs the service work. They get full LOTO training, including energy recognition and isolation. An affected employee operates the equipment or works nearby; they need to understand that LOTO devices mean the machine is off-limits, but they don't apply or remove devices. Each group has different training requirements under 1910.147.

Do lockout tagout requirements apply to small businesses?

Yes. 29 CFR 1910.147 applies to any general industry employer whose employees service or maintain machinery that could release hazardous energy, with no size exemption. A small shop with even one powered machine that needs servicing needs a written program, machine-specific procedures, and documented training. OSHA targets high-hazard industries more often, but small employers get cited regularly.

What PPE is required during lockout tagout procedures?

The LOTO standard doesn't specify PPE, but the hazard assessment required under 29 CFR 1910.132 governs what protection workers need during energy control tasks. Electricians verifying zero voltage need insulated gloves and face shields rated for the voltage. Workers releasing hydraulic pressure may need face and eye protection. The machine-specific LOTO procedure should name the PPE required for that equipment's energy types.

Can a supervisor override or remove an employee's lockout device in an emergency?

Only under a documented emergency removal procedure in the written program. The supervisor must verify the employee is out of the danger zone, attempt to contact them, and document every step. This is not a routine management option. OSHA's position is that unauthorized lock removal is a serious violation regardless of the business pressure behind it.

What penalties does OSHA assess for lockout tagout violations?

As of 2024, serious LOTO violations carry penalties up to $16,550 per violation. Willful or repeated violations can reach $165,514 per violation. ^[6] OSHA often groups multiple LOTO findings into separate citations from one inspection, so a shop with no written program, missing machine procedures, and no training records could face total penalties well above $50,000 from a single visit.

Does lockout tagout apply to cord-and-plug equipment?

There's an exception for cord-and-plug connected equipment when the plug stays under the exclusive control of the employee doing the work, meaning it stays in that person's possession the whole time. ^[1] If someone else could reinsert the plug, or if the equipment holds hazardous stored energy even unplugged, the full LOTO procedure applies. Many bench-top machines qualify; most production equipment does not.

How many steps are in the lockout tagout procedure?

Most compliance guidance describes eight steps from shutdown through verification, plus a defined restoration sequence to return equipment to service. Some sources count restoration as extra steps, pushing the total to 12 to 14 depending on how granular the breakdown is. The count matters less than covering every element: preparation, notification, shutdown, isolation, lock application, stored energy release, verification, work, then the reversal.

Sources

1. OSHA, 29 CFR 1910.147 Control of Hazardous Energy (Lockout/Tagout): Full regulatory text of the LOTO standard, including the eight-step sequence, authorized/affected employee definitions, tagout-only conditions, annual inspection requirement, and cord-and-plug exception
2. OSHA, Control of Hazardous Energy (Lockout/Tagout) Safety and Health Topics page: OSHA estimate that compliance with the lockout/tagout standard prevents an estimated 120 fatalities and 50,000 injuries each year
3. OSHA, CPL 02-00-147, Inspection Procedures for the Control of Hazardous Energy (Lockout/Tagout) Standard: Compliance directive specifying what inspectors examine in energy control procedures, group LOTO, shift transfer, and tagout-only requirements
4. OSHA, Letters of Interpretation - 1910.147 Lockout/Tagout: OSHA letters of interpretation clarifying that only the authorized employee who applied a lock may remove it, with narrow documented exceptions for shift changes and emergencies
5. OSHA, Top 10 Most Frequently Cited Standards, Fiscal Year 2023: 1910.147 (Control of Hazardous Energy) ranked fifth most cited standard in general industry in FY2023 with 2,554 violations
6. OSHA, Penalties: Maximum penalty for serious OSHA violations is $16,550 per violation and $165,514 for willful or repeated violations as of 2024
7. OSHA, 29 CFR 1910.1200 Hazard Communication: HazCom standard covering chemical labeling, safety data sheets, and employee training on chemical hazards in general industry
8. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program: BLS data on machinery-related fatal occupational injuries by year, supporting the scale of hazardous energy fatalities in industry
9. OSHA, 29 CFR 1926.417 Lockout and Tagging of Circuits (Construction): Construction-specific LOTO requirements under the construction standards, parallel to 1910.147 for general industry
10. OSHA, 29 CFR 1910.132 Personal Protective Equipment - General Requirements: Hazard assessment requirement that governs PPE selection during LOTO and maintenance tasks