Tags used for lockout tagout procedures must clearly identify the authorized employee

Last updated 2026-07-09

What does OSHA actually require lockout tagout tags to say?

The plain-text answer: 29 CFR 1910.147(c)(5)(ii) lists seven criteria every tagout tag must meet. Miss one and you have a citation waiting to happen.

First, the tag needs a legend. OSHA specifies a signal word, either "DANGER" or "WARNING", plus a message such as "Do Not Start," "Do Not Open," "Do Not Close," "Do Not Energize," or "Do Not Operate." ^[1] The standard says, in part, that tags must convey that "the energy control device and the equipment being controlled may not be operated until the tagout device is removed." That is a direct statement of what the message has to accomplish, not a loose suggestion.

Second, and this is the piece that trips up the most small shops: the tag has to clearly identify the authorized employee who applied it. A name. Not "maintenance dept." Not a badge number that takes a supervisor three minutes to cross-reference. The name of the person. OSHA letters of interpretation confirm that the employee identification must be specific enough that any worker on the floor could immediately know who to contact. ^[2]

The other five criteria cover durability, standardization, legibility, understandability, and being the only tag of its type in the facility. All seven get their own sections below, because each one generates its own category of citations.

Why does the tag have to identify the authorized employee by name?

Because a tag with no name is a tag with no owner, and a machine with no owner is how people die. The whole point of tagout is that one specific, known human being is responsible for an energy source. If that machine gets accidentally re-energized, anyone on the floor needs to know instantly who locked it out, whether that person is still on-site, and whether they have cleared the area.

OSHA's standard in 29 CFR 1910.147(c)(5)(ii)(C) is unambiguous: tagout devices must "identify the employee applying the devices." ^[1] Courts and OSHA review commissions have consistently held that a generic department label does not satisfy this requirement.

Think about shift changes. An authorized employee locks out a conveyor at 2 PM and goes home sick at 3 PM. The next shift arrives at 6 PM. If the tag says "Maintenance" instead of "Jorge Reyes," the incoming crew has no idea whether Jorge is still in the building, whether the work is actually done, or whether the tag is left over from yesterday. That ambiguity kills people.

For context on how often these situations go wrong: the Bureau of Labor Statistics reports roughly 1,800 workplace fatalities per year in industries covered by LOTO requirements, though BLS does not isolate LOTO-specific fatalities in a single published table. ^[3] OSHA itself estimates that proper lockout/tagout programs could prevent approximately 50,000 injuries and 120 fatalities annually. ^[4]

What are all 7 tag criteria under 29 CFR 1910.147?

Here is the full breakdown pulled directly from 29 CFR 1910.147(c)(5)(ii), with plain-English commentary on each.

#	OSHA Criterion	What That Means in Practice
1	Durable	Withstands wet, oily, corrosive, or outdoor environments without deteriorating. Cardstock fails this. Coated, laminated, or plastic tags pass.
2	Standardized	Color, shape, or size is consistent across your facility. You pick the standard; OSHA requires that one exists and gets followed.
3	Substantial (not lockout)	Strong enough that removal takes intentional force, not a zip tie you can snap with one finger.
4	Legible	Print is clear, large enough to read at a glance, and stays legible after exposure to the environment where it is used.
5	Understandable	Understood by all employees in the facility, including those whose first language is not English.
6	Warns of hazard	Includes a signal word (DANGER or WARNING) and a specific prohibition message ("Do Not Energize," etc.).
7	Identifies the authorized employee	Names the person who applied it, specific enough for any coworker to identify them immediately.

The "understandable" criterion is the one small employers overlook most often. If you have Spanish-speaking workers and your tags are English-only, you have a problem. OSHA's compliance officers have cited this. Bilingual tags are cheap and stocked by every industrial supplier. ^[2]

The "substantial" criterion is worth a moment. OSHA uses the phrase "non-releasable with a minimum unlocking strength of no less than 50 pounds" in Appendix A of 1910.147 as a guidance benchmark. Appendix A is non-mandatory, but it gives you a real engineering target. ^[7]

What is the difference between a lockout device and a tagout tag, and when can you use tags alone?

A lockout device physically stops the energy-isolating device from being re-energized. A tagout tag just warns people not to. That single distinction drives the entire rule, and it is more nuanced than most safety supply catalogs let on.

A lockout device holds the switch in the off position, usually with a hasp and a padlock. A tagout tag is a warning label. It carries no physical energy-isolating power at all. It relies entirely on the people in your facility respecting it and leaving it alone.

Because of that difference, OSHA's default preference is lockout. The standard says that "whenever an energy-isolating device is capable of being locked out, an energy control program shall use lockout." ^[1] Tagout-only programs are allowed, but only when the machine or equipment genuinely cannot accommodate a lock, and even then, the employer has to demonstrate that tagout provides a level of safety equivalent to lockout. That equivalent-safety demonstration usually involves extra measures like removing a circuit element, blocking a controlling switch, or opening an additional disconnecting device.

For your lockout tagout program, this matters because if you run tagout-only on equipment that could accommodate a lock, OSHA can cite you under 1910.147(c)(1). The tag criteria in 1910.147(c)(5) apply either way, but the question of whether tags are even permissible comes first.

Locks plus tags is safer and cleaner from a compliance standpoint. Tags alone mean more documentation and additional protective measures to earn the equivalent-safety finding.

What materials and durability standards must lockout tagout tags meet?

The durability requirement in 29 CFR 1910.147(c)(5)(ii)(A) says tags must withstand the environmental conditions in the workplace without deteriorating. That is functional language, not a materials spec. OSHA does not mandate Mylar or polyester. But in practice, paper tags fail most industrial environments.

Here is what matters. If your facility has oil mist, water, cleaning chemicals, or UV exposure, a paper tag from a standard inkjet printer goes unreadable within hours or days. An OSHA inspector will photograph that illegible tag and write it up under both the durability and legibility criteria at once.

Industrially rated tagout tags from major suppliers (Brady, Master Lock, Panduit) are typically polyester film or rigid plastic with UV-resistant printing. These run roughly $0.50 to $2.00 per tag for blank-fill versions. Pre-printed danger tags with write-in name fields are the most common compliant option and cost about the same.

Get the attachment right up front. OSHA's non-mandatory Appendix A describes a "non-releasable" nylon cable tie or equivalent that can withstand a minimum of 50 pounds of pull force. Nylon zip ties rated to that spec are standard. String ties are not. If an inspector can snap your tag attachment with a firm tug, expect a citation.

Some employers use tag-plus-lock combinations, where a hasp lock holds the energy isolation and a tag on the same hasp identifies the employee. That is the setup I would use in any facility where equipment can be locked.

How does OSHA cite employers for non-compliant lockout tagout tags?

OSHA classifies LOTO violations under 29 CFR 1910.147, and this standard lands on the agency's "top ten most cited standards" list every single year. In fiscal year 2023, Control of Hazardous Energy (lockout/tagout) was the fifth most cited OSHA standard, with 2,554 citations issued. ^[5]

Violations of the tag criteria themselves (1910.147(c)(5)) are typically cited as Serious violations, which carry penalties up to $16,550 per violation as of January 2024. ^[6] Willful or repeat violations go up to $165,514 per violation. If OSHA finds that your tagout program lacks employee identification and that failure contributed to an injury or near-miss, expect a Serious or Repeat classification.

The sub-citations most commonly issued for tag requirements are:

• 1910.147(c)(5)(ii)(C): Failure to identify the authorized employee
• 1910.147(c)(5)(ii)(D): Tags not standardized across the facility
• 1910.147(c)(5)(ii)(F): Tags without required warning legend
• 1910.147(c)(5)(i): Tags not durable enough for the environment

OSHA's citation database (publicly searchable at osha.gov) shows plenty of small employers hit with $5,000 to $15,000 penalties specifically for tag deficiencies. The fix is cheap: a box of proper tags costs under $50. The fine for skipping them does not.

If you want to understand how OSHA structures its inspection and citation process more broadly, the OSHA compliance overview is a good starting point.

Does your written lockout tagout program need to describe the tag requirements?

Yes, and this is where a lot of small employers have a gap between what their written program says and what actually happens on the floor.

29 CFR 1910.147(c)(1) requires employers to establish an energy control program that includes written energy control procedures. 29 CFR 1910.147(c)(5) requires that the hardware (the actual tags) meet the seven criteria. And 29 CFR 1910.147(c)(6) requires that employees are trained to understand the purpose and use of the energy control program, tags included.

Your written program should spell out four things: what your standardized tag looks like, what information gets filled in (name, date applied, equipment ID), what tag material and attachment method is approved, and what an employee does if they find a tag with incomplete information.

The common failure is a written program that says "use danger tags" without specifying what goes on the tag or what attachment hardware is required. An OSHA inspector reads your written program, then walks the floor. If the tags on your machines do not match what your program describes, you can get two separate citations: one for the program deficiency and one for the field deficiency.

If you are building or updating your written LOTO program, SafetyFolio's safety program generator can produce a compliant written program with tag specifications built in, typically in about 15 minutes. The written program is the first document an inspector asks for, so it is worth getting right.

What should you write on a lockout tagout tag?

Minimum required information, based on 29 CFR 1910.147(c)(5)(ii) and standard industry practice:

1. Signal word: DANGER or WARNING (printed, not handwritten, on a proper tag) 2. Prohibition statement: "Do Not Operate," "Do Not Energize," or the specific prohibition for this energy source 3. The authorized employee's name (the person who applied the tag) 4. Date applied 5. Equipment or machine identifier (not explicitly required by the standard, but strongly recommended in OSHA compliance guidance and effectively required by any well-written procedure)

The name and date are the two fields most often left blank or filled in sloppily. A tag that says "John" with no last name is arguably non-compliant if your facility has two Johns. Use full names.

OSHA does not mandate a national tag format, so you have latitude on layout. What you cannot do is vary the format from machine to machine or department to department. Standardization is required. Pick one tag design, stock it facility-wide, and train everyone to use it the same way.

Many employers add a contact phone number or shift information. That exceeds the minimum and makes practical sense for shift-change situations. There is no penalty for putting more on a tag than the standard requires.

How do lockout tagout tag requirements apply in group lockout situations?

Group lockout is where tag identification gets messy, and it is an area where many facilities run informal practices that do not actually meet the standard.

29 CFR 1910.147(f)(3) addresses group lockout and tagout. Each authorized employee in the group affixes their own personal lockout or tagout device to the group lockout device (a hasp) while working on the equipment. ^[10] So if four technicians work on a machine, four locks and four tags should be visible, each identifying one of those four people.

In a tagout-only group situation, each employee applies their own tag. The tag still has to meet all seven criteria and still has to identify that specific employee. You cannot use one group tag with a supervisor's name and call it done.

The person in charge of the group lockout also carries specific responsibilities under 1910.147(f)(3)(ii), including verifying that all workers in the group are protected before work begins and that all workers are clear before any energy is restored.

Small employers with two or three maintenance people often skip the individual tagging in group situations because it feels redundant. It is not redundant. It is the mechanism that keeps each person's safety independently tracked.

For a broader look at hazard communication requirements that interact with energy control on complex equipment, that article covers the overlap between GHS labeling and lockout procedures.

How do you train employees to use lockout tagout tags correctly?

29 CFR 1910.147(c)(7) requires training for three groups: authorized employees (who perform the lockout/tagout), affected employees (who operate the equipment being locked out), and all other employees in areas where LOTO is used. ^[9]

For tags specifically, authorized employees must learn that tags are warning devices only, that they cannot be removed except by the authorized employee who applied them, what information must appear on a tag, and how to complete a tag before attaching it. Affected employees must understand that they cannot remove a tag or restart equipment with a tag on it.

Training must be documented. 29 CFR 1910.147(c)(7)(iv) requires the employer to certify that training has been given, with the employee's name and the date of training.

Refresher training is required whenever a supervisor has reason to believe an employee does not understand the procedures, or when a change in machines, equipment, or processes presents a new hazard. Annual refresher is not explicitly mandated by the standard, but many OSHA compliance officers treat a gap of several years without retraining as evidence of a program deficiency, especially after an incident.

OSHA training options like the OSHA 30 course cover LOTO principles, though that course is no substitute for site-specific training. Site-specific means your equipment, your tags, your procedures.

Can you use a digital or electronic tag for lockout tagout?

No. Paper or physical tags are still required. A QR code or electronic record cannot substitute for a physical tag on the energy-isolating device, no matter how sophisticated your maintenance software is.

OSHA has not issued a standard or letter of interpretation authorizing digital-only tagout. The physical tag has to be present on the machine because its job is to warn someone who has not checked any digital system, someone who walks up to a conveyor and needs an immediate, visible warning not to energize it.

Digital systems (CMMS software, maintenance management platforms) can add useful information on top of physical tags: work order details, equipment history, contact information. That supplemental record is fine and often useful. But it supplements. It does not replace the physical tag.

Some employers print QR codes on their tags that link to digital procedure documents. That exceeds the minimum and is a reasonable practice. The physical tag still has to meet all seven criteria on its face. The QR code is bonus information, not a compliance shortcut.

Nobody has good data on how widespread digital-only practices are in small facilities, but OSHA compliance officers have cited employers for relying on electronic systems in place of physical tags. Do not risk it.

What happens when a lockout tagout tag is found on equipment with no name on it?

This is a real operational problem, and your written program needs to address it with a specific procedure.

If an employee finds a tag with no name (or an illegible name), the worst thing they can do is pull it and restart the equipment. Someone applied that tag for a reason. The work may not be done. People may be inside the machine.

Your written program should have an unidentified tag procedure that reads something like: stop work, notify the shift supervisor, attempt to identify the employee through records or coworker inquiry, and do not remove the tag or restore energy until the authorized employee is identified and confirms the work is complete and the area is clear.

If the employee who applied the tag has left the facility and cannot be reached, most written programs and OSHA guidance say a designated manager can remove the tag only after a thorough inspection of the affected machinery confirms no workers are present and the hazardous energy is controlled. The manager documents the decision. This is a judgment call with real liability, and it is exactly why proper tag identification matters in the first place.

OSHA's enforcement position is that an employer whose program allows anonymous tags is in violation of 1910.147(c)(5)(ii)(C), whether or not an incident occurred. The control is the control.

Frequently asked questions

What specific information must be on a lockout tagout tag?

At minimum: a signal word (DANGER or WARNING), a prohibition statement ("Do Not Operate" or similar), and the full name of the authorized employee who applied the tag. Date applied and equipment identification are not explicitly mandated by 1910.147 but are required by most well-written energy control programs and strongly recommended by OSHA compliance guidance. Omitting the authorized employee's name is a citable Serious violation.

Tags used for lockout tagout procedures must clearly identify whom?

The authorized employee who applied the tag. That means the specific named person, not a department, job title, shift, or badge number. 29 CFR 1910.147(c)(5)(ii)(C) requires that tagout devices identify the employee applying the devices. Any coworker who walks up to that machine should be able to read the tag and know immediately who to contact.

Can you use a tag alone without a lock for lockout tagout?

Only if the energy-isolating device cannot be locked out. OSHA's default rule is that lockout must be used whenever equipment can accommodate a lock. If you use tagout alone, you must demonstrate the program provides safety equivalent to lockout, typically by adding measures like blocking a switch or removing a circuit element. Tagout-only programs face higher scrutiny during inspections.

How durable do lockout tagout tags need to be?

Durable enough to withstand the environmental conditions at your facility without deteriorating. Paper tags fail in oily, wet, or chemically exposed environments. Polyester film or rigid plastic tags are standard in most industrial settings. OSHA's non-mandatory Appendix A to 1910.147 suggests tag attachments withstand a minimum 50-pound pull force, which is a practical benchmark for nylon cable ties or equivalent.

What is the OSHA penalty for non-compliant lockout tagout tags?

Violations of 29 CFR 1910.147 tag requirements are typically Serious citations, with penalties up to $16,550 per violation as of January 2024. Willful or repeat violations can reach $165,514 per violation. Lockout/tagout was the fifth most cited OSHA standard in fiscal year 2023, with 2,554 citations issued. The cost of proper compliant tags is under $2 each.

Do lockout tagout tags need to be standardized across the whole facility?

Yes. 29 CFR 1910.147(c)(5)(ii)(B) requires tags to be standardized within the facility in at least one of these ways: color, shape, or size. You choose your standard, but it must be consistent. Using different tag formats in different departments or on different equipment types is a citable violation, even if each individual tag is otherwise compliant.

What language do lockout tagout tags need to be in?

The standard requires tags to be "understandable to all employees who may be exposed to the hazard." If your workforce includes employees who are not English-proficient, English-only tags may not satisfy the understandability requirement. Bilingual tags (English and Spanish are most common in U.S. facilities) are inexpensive and widely available. OSHA compliance officers have cited employers for this specifically.

Who can remove a lockout tagout tag?

Only the authorized employee who applied it, and only after the work is complete, all tools and personnel are clear, and any affected employees have been notified that equipment is about to be re-energized. If that employee is unavailable, a specific procedure in your written program (involving management verification and documentation) must govern tag removal. Unauthorized removal is a serious violation and a genuine safety hazard.

How do group lockout tagout situations affect tag requirements?

Each authorized employee working in a group lockout must apply their own personal tag to the group hasp or lockout device. One tag with a supervisor's name does not cover four technicians. 29 CFR 1910.147(f)(3) is specific about this. In tagout-only group situations, the individual tagging requirement is equally firm. Every person's presence must be independently identified and tracked.

Does a written lockout tagout program need to describe the tag requirements?

Yes. Your written energy control program under 29 CFR 1910.147(c)(1) should specify the approved tag type, required fields (name, date, equipment ID), approved attachment hardware, and the procedure for handling tags with missing or illegible information. If your written program and your actual field practice do not match, OSHA can issue separate citations for the program deficiency and the field deficiency.

Are there specific OSHA-approved lockout tagout tag designs or brands?

No. OSHA does not certify or approve specific brands or catalog numbers. The standard specifies performance criteria (durable, standardized, legible, substantial, understandable, warning legend, employee ID) and you choose hardware that meets them. Major suppliers like Brady, Master Lock, and Panduit offer compliant tags, but buying from a recognized brand does not itself guarantee compliance if the tag is used incorrectly.

How often should lockout tagout tag procedures be reviewed?

29 CFR 1910.147(c)(6) requires an annual periodic inspection of each energy control procedure. That inspection must be performed by an authorized employee other than the one using the procedure, and it must be certified with the machine name, inspection date, employees involved, and name of the inspector. If your inspection finds tag practices drifting from your written program, correct it before an OSHA visit does.

Can a QR code or digital system replace a physical lockout tagout tag?

No. OSHA has not authorized digital-only tagout. A physical tag must be present on the energy-isolating device. Digital systems (maintenance software, QR code links) can supplement physical tags with additional information, but they cannot substitute for the warning device that needs to be immediately visible to anyone approaching the equipment without access to a phone or computer.

Sources

1. OSHA, 29 CFR 1910.147 - The Control of Hazardous Energy (Lockout/Tagout): Tags must be durable, standardized, substantial, legible, understandable, carry a warning legend, and identify the authorized employee; lockout preferred over tagout when equipment can be locked.
2. OSHA, Letters of Interpretation - Lockout/Tagout: OSHA interpretation letters confirm that employee identification on tags must be specific enough for any coworker to identify the individual, and that bilingual tags may be required for non-English-speaking workers.
3. Bureau of Labor Statistics, National Census of Fatal Occupational Injuries: BLS reports approximately 1,800 fatal occupational injuries per year in industries covered by LOTO requirements, though LOTO-specific fatalities are not isolated in a single BLS table.
4. OSHA, Lockout/Tagout - Overview: OSHA estimates proper lockout/tagout programs prevent approximately 50,000 injuries and 120 fatalities annually.
5. OSHA, Top 10 Most Frequently Cited Standards FY2023: Control of Hazardous Energy (1910.147) was the fifth most cited OSHA standard in fiscal year 2023, with 2,554 citations issued.
6. OSHA, Penalties: As of January 2024, Serious OSHA violations carry penalties up to $16,550 per violation; Willful or Repeat violations up to $165,514 per violation.
7. OSHA, 29 CFR 1910.147 Appendix A - Typical Minimal Lockout Procedure (Non-Mandatory): Appendix A describes a non-releasable tag attachment with a minimum unlocking strength of no less than 50 pounds as a guidance benchmark.
8. OSHA, 29 CFR 1910.147(c)(7) - Training and Communication: Employers must train authorized employees, affected employees, and all other employees in the LOTO program; training must be certified with employee name and date.
9. OSHA, 29 CFR 1910.147(f)(3) - Group Lockout or Tagout: Each authorized employee in a group lockout must affix their own personal lockout or tagout device to the group lockout device.
10. OSHA, 29 CFR 1910.147(c)(6) - Periodic Inspections: Employers must conduct an annual periodic inspection of each energy control procedure, certified with machine name, inspection date, employees involved, and inspector name.