What is a proper practice for a lockout/tagout situation

Last updated 2026-07-10

What is lockout/tagout and why does OSHA regulate it?

Lockout/tagout (LOTO) is the set of procedures workers use to keep a machine from starting up while someone is servicing or maintaining it. OSHA's rule lives at 29 CFR 1910.147, titled "The Control of Hazardous Energy," and it applies to general industry. Construction has its own requirements at 29 CFR 1926.417, and maritime work sits under separate rules ^[1][6].

The hazard is real and it repeats. OSHA estimates that LOTO failures cause roughly 50,000 injuries and 120 deaths every year in the United States ^[2]. The agency also ranks 29 CFR 1910.147 among its ten most frequently cited standards year after year ^[8]. So employers aren't only watching people get hurt. They're getting fined too.

"Hazardous energy" covers more ground than most people expect. Electrical energy is the obvious one. It also includes hydraulic pressure, pneumatic pressure, mechanical energy like a spring under tension, thermal energy, chemical energy, and plain gravity. A press ram parked at the top of its stroke is storing gravitational energy. A hydraulic cylinder holds pressure that doesn't vanish when you cut power. Your procedures have to account for every form of energy in the machine, more than the electrical disconnect ^[1].

For background on how OSHA writes and enforces these rules, see our overview of lockout tagout and the broader OSHA compliance framework.

Who does the lockout/tagout standard cover?

29 CFR 1910.147 covers general industry employers and the employees who service or maintain machines where an unexpected startup could hurt someone. OSHA sorts the people involved into three groups, and each group gets a different level of training.

Authorized employees apply the locks and tags and do the actual servicing. They need the deepest training. Affected employees are the operators who run the equipment day to day. They need to know not to restart a machine wearing a lock, but they don't need to know how to run the full energy control procedure. Other employees are anyone else who works where LOTO is used. They need one thing drilled in: don't touch anything with a lock or tag on it ^[1].

The standard has a handful of carve-outs. Cord-and-plug equipment is exempt if you control the energy just by unplugging it and keeping the plug in your hand. Hot-tap operations on pressurized pipelines follow special rules. Minor tool changes during normal production are generally exempt when the machine's own design guards against a surprise startup ^[1]. Those exemptions are narrower than most employers think. When in doubt, treat it as a LOTO job.

Contractors are covered too. Bring in an outside crew and you're required to coordinate procedures with them and brief them on your site's energy control program ^[1].

What are the six steps of a proper lockout/tagout procedure?

This is the heart of the rule. The standard doesn't number the steps exactly this way, but 29 CFR 1910.147(d) lays out a sequence every authorized employee has to follow. Here it is in plain terms.

Step 1: Prepare for shutdown. Before you touch anything, find every energy source. Read the machine-specific written procedure (more on that below) and gather the right locks and tags. Tell the affected employees the equipment is going down.

Step 2: Shut down the equipment. Use the machine's normal stopping procedure. Turn it off at the controls. Sounds obvious. But jumping straight to isolating the power without a proper shutdown can create its own hazards on some equipment.

Step 3: Isolate all energy sources. Operate every energy-isolating device until the machine is cut off from its energy. Open circuit breakers, close valve shutoffs, block pneumatic lines, whatever the machine-specific procedure calls for. Five energy sources means five isolations ^[1].

Step 4: Apply lockout or tagout devices. Each authorized employee puts a personal lock on every energy-isolating device. The key stays with that one worker. If you use a tag instead of a lock, it goes on the same point a lock would, carrying a warning like "Do Not Operate" ^[1]. OSHA's position: lockout beats tagout every time, because a tag is a warning, not a wall.

Step 5: Release or restrain stored energy. This is where a lot of people get hurt. Even after you isolate the source, the machine can still hold energy. Bleed the hydraulic lines. Release or block the spring tension. Block any part that could drop under gravity. Let capacitors discharge. Let heat come down to a safe level. The job isn't done until every bit of residual energy is handled ^[1].

Step 6: Verify the equipment is dead. Test before you trust. Try to start the machine with its normal controls. Check voltage with a meter if it's electrical. Confirm zero energy with whatever test fits the energy type. Then put the controls back to off before you begin ^[1].

When the work's done, run it in reverse: inspect the machine, replace the guards, notify affected employees, remove your own lock (only you may remove yours), and allow restart.

What has to be in a written lockout/tagout program?

29 CFR 1910.147(c)(1) requires every covered employer to establish "a program consisting of an energy control procedure, employee training, and periodic inspections" to prevent the unexpected energization of machines ^[1]. The written program is mandatory even if you have fewer than ten employees.

At the program level, your document covers the scope, the rules for applying and removing devices, and the procedure for the rare case where a lock has to come off without the worker who applied it (there's a specific way to handle that).

At the equipment level, 29 CFR 1910.147(c)(4) requires a written, machine-specific procedure for each piece of equipment unless four things are all true: the machine has a single energy source, that source can be fully de-energized by locking one point, the machine holds no residual energy after isolation, and it's isolated and locked in one step ^[1]. Most industrial equipment fails at least one of those tests, so most machines need their own procedure.

A machine-specific procedure usually spells out the machine's identity, the types and magnitudes of energy present, the steps to shut down and isolate, the exact location of each isolating device, the stored energy and how to release it, and the method to verify a zero energy state.

Building these from scratch without a consultant? SafetyFolio's safety program generator helps you structure a compliant LOTO program in a fraction of the time it takes to draft one from a blank page.

What lockout/tagout devices does OSHA require?

29 CFR 1910.147(c)(5) says lockout and tagout devices have to meet real requirements. They must be durable enough for the environment they live in. They must be standardized inside your facility, so consistent in color, shape, or size that a worker knows one on sight. They must be substantial enough that you can't pull them off without a key, a combination, or excessive force. And they must name the employee who applied them ^[1].

For lockout, the lock is usually a personal padlock with a unique key. A hasp lets several workers each add a lock to a single isolation point during group work, so the equipment can't come back to life until every last person removes their own lock. That's the right way to run group lockout.

For tagout, OSHA requires a warning like "Do Not Start," "Do Not Open," "Do Not Close," "Do Not Energize," or "Do Not Operate" ^[1]. Tagout alone gives you less protection than lockout. If a machine can be locked, it has to be. Tagout-only is acceptable only when the isolating device physically can't take a lock.

Some lockout devices are built for one job. Valve lockouts, circuit breaker attachments, plug covers, and pneumatic line lockouts all exist for specific applications. One padlock on a disconnect switch does nothing for the pneumatic line or the hydraulic accumulator on the same machine.

What training do employees need for lockout/tagout?

Training under 29 CFR 1910.147(c)(7) scales by employee type. Authorized employees learn the type and magnitude of the hazardous energy, the methods to isolate and control it, and the exact steps of the energy control procedure. Affected employees learn why LOTO is used, what the procedures mean, and to leave locked or tagged equipment alone. Other employees learn one rule: don't restart or re-energize anything wearing a lock or tag ^[1].

Retraining kicks in whenever you have reason to think an employee doesn't get the procedure, when procedures change, or when an inspection turns up a gap. The federal standard sets no fixed annual refresher. But the required periodic inspections (see below) tend to expose training holes that trigger retraining anyway.

OSHA doesn't set a number of training hours for LOTO. What it wants is documented proof that employees understand the procedure and can run it right. A written test alone won't cut it. Hands-on demonstration is the part that matters.

For broader training context, see our guides on OSHA training and OSHA 30, which cover how authorized programs are built.

How often do lockout/tagout procedures have to be inspected?

At least once a year. 29 CFR 1910.147(c)(6) requires an annual inspection of each energy control procedure, done by an authorized employee other than the one who uses it ^[1]. The inspection confirms the procedure still works and that employees know how to follow it.

For lockout procedures, that means a hands-on review with each authorized employee who uses the procedure. For tagout procedures the bar is higher: you also have to walk through the limitations of tags with those employees, because a tag doesn't hold anything in place the way a lock does.

The employer certifies each inspection. The certification names the date, the equipment inspected, the employees involved, and the inspector ^[1]. Keep those records. OSHA compliance officers will ask for them.

Treat the annual inspection as more than paperwork. It catches drift. Machines get modified. Steps get skipped out of habit. New energy sources get added. An inspection done seriously finds the things that need fixing. One done as a box-check misses them and leaves people exposed.

What are the most common lockout/tagout violations OSHA cites?

OSHA's enforcement records keep pointing at the same handful of failures. Here they are.

No written energy control program at all. Smaller employers especially assume the rule skips them. It doesn't.

No machine-specific procedures. A general LOTO policy isn't enough. Every machine that doesn't qualify for the exception needs its own documented procedure.

Missing an energy source. The electrical disconnect gets locked, but stored hydraulic pressure, spring tension, or a second electrical circuit gets left live.

Improper tagout. Using a tag where a lock would fit, or using a tag without the required warning language.

No annual inspection, or no certification records. The inspection maybe happened, but nobody wrote anything down.

Thin training. Authorized employees can talk about LOTO but can't run the procedure on their own equipment.

Group lockout done wrong. One supervisor's lock covers a crew of five. Every worker needs a personal lock on every isolating device.

Contractor coordination failures. An outside crew brings procedures that clash with yours, and nobody sorts it out before work starts ^[1].

The money adds up. Serious violations run up to $16,131 per instance, and willful or repeated violations can hit $161,323 per violation, both figures adjusted annually for inflation ^[3]. OSHA can group related violations, so one inspection can pile up fast.

How does lockout/tagout apply to complex or multi-energy machines?

Most of the plain guidance in 29 CFR 1910.147 was written with single-machine, single-source scenarios in mind. Real equipment is messier than that.

Complex machines with several energy sources need procedures that walk through each source in sequence. Order matters. De-energizing in the wrong order can release stored energy or open a new hazard. The written procedure should name the exact sequence.

Group lockout, where several workers service the same machine, requires each worker to put a personal lock on each isolation point. When there are more workers than points, a lockout hasp or a lockout box (a locked container holding the keys to all the isolation locks) keeps the system tight. Each worker adds a personal lock to the hasp or box. Nobody restarts anything until every worker pulls their own lock ^[1].

When you're servicing several machines wired together on a line, the same logic scales up. Every energy source on every machine in the affected area gets isolated and locked. A procedure for a full production line can run several pages.

Electrical work carries an extra layer. 29 CFR 1910.333 covers electrical safety-related work practices and points to 1910.147 for the de-energizing requirements ^[5]. NFPA 70E, the electrical safety standard from the National Fire Protection Association, overlaps 1910.147 on several points. If your people do electrical work, they likely need both LOTO training and arc flash awareness.

Can you use tagout instead of lockout, and when is it acceptable?

Tagout-only programs are allowed under 29 CFR 1910.147 only when lockout isn't feasible, meaning the isolating device physically can't take a lock. That's a narrow door. If you can retrofit a lockout point, OSHA expects you to do it ^[1].

When tagout is your only option, the requirements tighten. You have to show the tagout program gives protection equal to what lockout would. That means extra measures: pulling a fuse, blocking an isolating valve, opening a second disconnect, or another step that physically blocks energization even without a lock.

Tags carry a limitation OSHA spells out in the standard's non-mandatory appendix: "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" ^[11]. Quote that sentence to anyone who treats a tag like a lock.

The practical read: design your equipment and your facility so lockout is always possible. Retrofit when you have to. A lockout attachment for a circuit breaker costs a few dollars. A tagout-only incident costs a great deal more.

What should a lockout/tagout procedure look like for a specific machine?

A machine-specific LOTO procedure is a written, step-by-step document for one piece of equipment. Here's what it needs, based on 29 CFR 1910.147(c)(4)(ii).

Machine identity. Equipment name, ID number, location, manufacturer if it matters.

Scope and purpose. What work this procedure covers, whether that's all service and maintenance or specific tasks.

Hazardous energy types and magnitudes. List every source: 480V three-phase electrical, 100 PSI hydraulic at accumulator A, spring-loaded carriage, and so on.

Steps in sequence. Numbered and specific. "Turn off Main Disconnect Switch D-1 on the east panel" beats "shut off power." Include any required order.

Location and method of isolation for each source. Don't assume the worker knows where the valve is.

Method for releasing stored energy. Bleed valve location, discharge steps, blocking method.

Verification method. How to confirm zero energy before work starts.

Here's a simplified comparison of lockout versus tagout:

Feature	Lockout	Tagout
Physical barrier to re-energization	Yes	No
When required	Whenever feasible	Only when lockout not feasible
Additional steps needed	Standard sequence	Additional protective measures required
Employee understanding of limitations	Standard training	Must specifically cover tag limitations
Preferred by OSHA	Yes	No

Keep procedures where the work happens. Some shops laminate them and hang them on the machine. Digital access works too, as long as a worker can pull it up before starting.

How do you handle a lockout/tagout situation in an emergency or shift change?

Shift changes are one of the trickiest LOTO situations. When work on a machine crosses shifts, the outgoing authorized employee can't just yank their lock at quitting time and hope the next crew figures it out. 29 CFR 1910.147(f)(4) requires a specific shift-change procedure that keeps protection continuous ^[1].

The usual method is an overlap: the incoming authorized employee applies their lock before the outgoing employee removes theirs. The machine stays locked the whole time. The incoming worker should verify the machine's energy state, more than take the outgoing worker's word.

Emergencies where a locked-out machine needs a restart and the authorized employee is gone are genuinely hard. 29 CFR 1910.147(e)(3) allows someone else to remove the lock, but only under a set procedure: the employer verifies the worker who applied it has left the facility, makes all reasonable efforts to reach them, and makes sure they know the lock was removed before they come back to work ^[1]. This isn't a shortcut. It's a last resort with documentation attached.

Never cut a lock off outside that procedure. The lock might be there because a worker is still inside a machine or a confined space. Cutting it without verification can kill someone.

What's the best way to build a lockout/tagout program from scratch?

Start with a survey. Walk every piece of equipment that gets serviced or maintained and list every energy source. For each machine, answer: electrical? hydraulic? pneumatic? thermal? mechanical? chemical? gravitational? That survey is the foundation for your machine-specific procedures.

Next, write the site-wide energy control program. It covers scope, definitions, responsibilities, the general LOTO sequence, device requirements, training requirements, and the shift-change and contractor procedures. OSHA's Small Business Safety and Health Handbook has guidance that helps here ^[4].

Then write the machine-specific procedures. One per machine, or one per group of identical machines. The survey data feeds straight into these.

Buy the right hardware. Personal padlocks for each authorized employee, hasps for group lockout, and application-specific devices for valves, breakers, and pneumatic lines.

Train everyone. Authorized employees first, then affected, then everyone else. Document it with sign-in sheets and a short competency check.

Run the first annual inspection before you call the program done. Fix whatever it surfaces.

Want a faster path through the written-program step? SafetyFolio's safety program generator produces a structured, OSHA-referenced LOTO program in about 15 minutes. You still have to walk your equipment yourself, but the document framework comes ready to customize.

For programs that usually sit next to LOTO in a compliance package, see our resources on hazard communication and how to file an incident report when something does go wrong.

Frequently asked questions

What is a proper practice for a lockout/tagout situation?

Proper practice means running the six-step energy control sequence in 29 CFR 1910.147: notify affected employees, shut down the machine, isolate all energy sources, apply personal locks or tags to every isolating device, release or restrain stored energy, and verify a zero energy state before touching the equipment. Each step happens in order. Skipping any step, even one that seems redundant, puts workers at risk and violates the standard.

What does OSHA say about lockout/tagout?

OSHA's lockout/tagout standard is 29 CFR 1910.147, "The Control of Hazardous Energy." It requires a written energy control program, machine-specific procedures for equipment that doesn't qualify for an exemption, training for authorized and affected employees, and annual inspections of each procedure. OSHA consistently ranks 1910.147 among its most frequently cited standards and estimates LOTO failures cause roughly 50,000 injuries and 120 deaths per year.

What is the correct order of steps in a lockout/tagout procedure?

The order is: (1) prepare for shutdown and notify affected employees, (2) shut down the equipment using normal controls, (3) isolate every energy source using its isolating device, (4) apply lockout or tagout devices to each isolation point, (5) release or restrain all stored energy such as hydraulic pressure, spring tension, or electrical charge, and (6) verify de-energization by attempting to start the machine and testing with instruments before work begins.

Who is required to apply a lockout device?

Only authorized employees may apply lockout devices. An authorized employee is someone trained and designated by the employer to run the energy control procedure on specific machines. In a group lockout, each authorized employee on the job applies their own personal lock to the isolating device or to a lockout hasp. One supervisor's lock cannot stand in for an entire crew.

Is tagout the same as lockout?

No. A lock physically stops a device from being operated. A tag is a warning label. OSHA's standard says tagout may only be used when the isolating device cannot physically take a lock. When tagout is the only option, extra protective steps are required, and the standard explicitly states that tags do not provide the physical restraint a lock does. If lockout is feasible, it is required.

Does lockout/tagout apply to small businesses?

Yes. 29 CFR 1910.147 applies to any general industry employer whose employees service or maintain equipment where unexpected energization could cause injury. There is no small-business exemption based on headcount. The written program, machine-specific procedures, training, and annual inspections apply regardless of company size. OSHA's Small Business Safety and Health Handbook offers guidance aimed at smaller employers.

How often must lockout/tagout procedures be reviewed or inspected?

At least once per year per procedure, under 29 CFR 1910.147(c)(6). An authorized employee other than the one who uses the procedure must conduct it. It has to be a hands-on review with the affected authorized employees, more than a document read. The employer certifies each inspection with the date, equipment, employees involved, and inspector's name. Those records must be available for OSHA review.

What are the OSHA penalties for lockout/tagout violations?

Under OSHA's current schedule, serious violations reach up to $16,131 per violation, and willful or repeated violations reach up to $161,323 per violation, both adjusted annually for inflation. Because LOTO citations often involve multiple deficiencies across multiple machines, a single inspection can generate large total penalties. Employers with documented programs and training records generally fare better than those with no written program at all.

What types of energy does lockout/tagout cover?

All of them. 29 CFR 1910.147 covers electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational energy. A machine that's powered off can still hold a spring under tension, a pressurized hydraulic accumulator, or a heavy part that could drop. Stored and residual energy must be identified in the machine-specific procedure and released or restrained before work begins. Missing any one source is a violation and a serious injury risk.

What happens during a shift change when a machine is locked out?

An ongoing lockout has to stay in place across shift changes. The standard method is an overlap: the incoming authorized employee applies their lock before the outgoing employee removes theirs. The machine stays locked at all times, and the incoming worker verifies the energy state independently. Simply handing over a key to the outgoing worker's lock is not an acceptable shift-change procedure under 29 CFR 1910.147(f)(4).

Can you remove someone else's lockout lock?

Only under a specific emergency procedure in 29 CFR 1910.147(e)(3). The employer must verify the employee has left the facility, make all reasonable efforts to contact them, and make sure they know their lock was removed before they return to work. This is a last resort, not a convenience. Cutting a lock without following this process is a serious violation and a potential fatality if the worker is still inside the equipment.

Do contractors have to follow your site's lockout/tagout program?

Yes. When outside contractors perform service or maintenance at your facility, you must inform them of your energy control program and coordinate procedures with them. 29 CFR 1910.147(f)(2) requires both the host employer and the contractor to understand and comply with each other's LOTO procedures. A contractor's non-compliant procedure doesn't shield the host employer from liability if an incident occurs.

What equipment is exempt from lockout/tagout?

Cord-and-plug equipment is exempt if you unplug it and hold the plug. Minor tool changes during normal production are exempt if the machine's design guards against unexpected energization. Hot-tap operations have special rules. A machine is also exempt from the written machine-specific procedure requirement if it has a single energy source, can be fully isolated in one step, holds no stored energy after isolation, and the worker can verify de-energization simply. Most industrial equipment fails at least one of those tests.

What should a lockout/tagout training record include?

At minimum, records should show the employee's name, the training date, what was covered, and who conducted it. For authorized employees, documentation should also reflect hands-on competency, more than attendance. OSHA doesn't prescribe a form, but compliance officers look for evidence that training was substantive. Sign-in sheets paired with a competency checklist or a short written quiz work well and take under an hour to prepare.

Sources

1. OSHA, 29 CFR 1910.147 The Control of Hazardous Energy (Lockout/Tagout): Full text of the LOTO standard including the six-step sequence, device requirements, training requirements, annual inspection requirements, and tagout limitations
2. OSHA, Control of Hazardous Energy (Lockout/Tagout) topic page: OSHA estimates LOTO failures cause approximately 50,000 injuries and 120 fatalities annually
3. OSHA, Penalties page: Current OSHA penalty levels: serious violations up to $16,131 per violation, willful or repeated up to $161,323 per violation (adjusted annually)
4. OSHA, Small Business Safety and Health Handbook: Guidance for smaller employers on building safety programs including energy control
5. OSHA, 29 CFR 1910.333 Electrical safety-related work practices: Electrical work de-energizing requirements reference 1910.147 for lockout/tagout procedures
6. OSHA, 29 CFR 1926.417 Construction lockout and tagging of circuits: Construction-specific lockout/tagout requirements separate from general industry 1910.147
7. Bureau of Labor Statistics, Census of Fatal Occupational Injuries: Federal data source for occupational injury and fatality statistics including those related to contact with machinery
8. OSHA, Top 10 Most Frequently Cited Standards: 29 CFR 1910.147 consistently ranks among OSHA's ten most frequently cited standards each fiscal year
9. OSHA, 29 CFR 1910.147 Appendix A (informational, non-mandatory): Appendix states: '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'