What is an affected employee's responsibility during a lockout tagout?

Last updated 2026-07-09

Who exactly is an "affected employee" under OSHA's LOTO rule?

An affected employee is anyone whose job puts them on or near a machine that's been locked out, even if they never touch the lockout process itself. OSHA defines it in 29 CFR 1910.147(b) as "an employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed." ^[1]

That definition is broader than most small business owners think. It's more than the person who runs the machine every day. It covers anyone whose work area overlaps with a locked-out machine, even if that machine isn't theirs. A packaging worker who walks past a locked-out conveyor to reach their station qualifies. So does a janitor mopping near a de-energized press.

The LOTO standard splits your workforce into three categories, and those categories drive how you train people and how you write your program:

Category	OSHA definition (summary)	Training depth required
Authorized employee	Performs the actual lockout/tagout	Full energy control procedure training
Affected employee	Operates or works near locked-out equipment	Recognition + non-interference rules
Other employee	Works in areas where LOTO may occur	Awareness that LOTO is in use

Mixing up these categories is one of the most common written-program mistakes. Treat affected employees like authorized employees and you've built a training burden the regulation never asked for. Treat them like "other employees" and you've probably left a compliance gap that an inspector will find. ^[1]

For how the broader lockout tagout standard works, including the authorized employee side, that's a good next read.

What are the specific responsibilities of affected employees during a lockout tagout?

The core duty is one sentence: don't restart, re-energize, or remove any lock or tag an authorized employee applied. ^[1] That's the whole job in a line. But unpack it and you find several concrete behaviors OSHA expects.

First, an affected employee has to recognize when a lockout or tagout is in effect. Sounds obvious. It isn't, without training. Somebody who doesn't know what a lockout hasp looks like, or doesn't grasp that a tag means "this machine is intentionally disabled," can't reliably stay clear of it. OSHA's training rule at 29 CFR 1910.147(c)(7)(i)(B) says affected employees must be instructed in "the purpose and use of the energy control procedure." ^[1]

Second, they must not operate any equipment with a lockout or tagout device on it. This prohibition is absolute. There's no exception for "I just needed it for one second" or "my supervisor told me to." An affected employee who removes a lock or restarts locked-out equipment has broken the standard, no matter who told them to do it.

Third, they should report trouble. Equipment that looks locked out but is running. A lock that seems tampered with. Pressure from a co-worker or boss to bypass a tag. The standard doesn't write a whistleblower protocol into 1910.147 itself, so that's where your written program has to step in.

Fourth, they need to know their part in a handoff. If a maintenance team is about to lock out a machine an operator is currently running, the operator has a role. In some procedures the affected employee shuts down and clears the machine before the authorized employee applies the lock.

None of this requires an affected employee to know how to perform the lockout. That stays with the authorized employee. The affected employee's job is awareness and restraint. Two things. That's it.

Why does OSHA single out affected employees separately from other workers?

Because affected employees are the people most likely to accidentally restart a locked-out machine. It's their machine. When it sits idle and a production schedule is bearing down, the pull to just flip the switch is real. OSHA's numbers on this are grim. The agency estimates the lockout/tagout standard prevents roughly 120 fatalities and 50,000 injuries a year, and a big share of those incidents involve workers who fired up equipment while maintenance was still underway. ^[2]

That's the whole reason for the category. An "other employee" walking past a locked-out machine has little reason to touch it. An affected employee has the habit and the access. The rule targets that exact risk.

The distinction also decides citations. If OSHA inspects your facility and your affected employees got no training, that's a citable violation of 29 CFR 1910.147(c)(7). A serious violation runs up to $16,550 per instance as of 2024, and willful violations reach $165,514. ^[3] One inspection that finds untrained affected employees at a shop with 20 machine operators can turn into a stack of citations, not one.

What training do affected employees actually need?

Affected employees need three things: recognition, reason, and one hard rule. OSHA sets the requirement at 29 CFR 1910.147(c)(7)(i)(B), which says affected employees must be instructed "in the purpose and use of the energy control procedure." ^[1] They must recognize when the procedure is in use and understand why they can't restart or re-energize equipment that's locked or tagged out.

That's narrower than authorized-employee training, and deliberately so. Affected employees don't need to learn how to identify energy sources, apply locks, or verify a zero energy state. They need:

1. Recognition: what does a lockout or tagout look like on their equipment? 2. Reason: why is the machine disabled, and how does that protect them and others? 3. Rule: never remove, override, or bypass a lock or tag.

OSHA doesn't set a minimum number of hours for this. It doesn't require certification or a written test for affected employees. What it requires is that training be adequate, be documented, and be repeated whenever there's reason to think an employee doesn't understand the rules. Common retraining triggers: new equipment, changed procedures, or an incident or near-miss. ^[1]

Documentation matters. Your records have to show who was trained, when, and what the training covered. Inspectors ask to see these during a LOTO inspection, and "we told everyone at onboarding" doesn't hold up without paper behind it.

If you need to build a written LOTO program with proper affected-employee documentation, the SafetyFolio program generator walks you through the required elements in about 15 minutes, including the employee-category sections programs most often get wrong.

For OSHA training requirements more broadly, see the overview of osha training.

Can an affected employee ever touch a lockout device?

No. An affected employee cannot remove, bypass, or work around a lockout or tagout device, ever. The only time they interact with the lockout process is if your written program assigns them a specific role in the shutdown sequence before the lock goes on, or in a group lockout where each exposed employee applies a personal lock to a hasp. In that second case, though, the person applying a personal lock is acting as an authorized employee for that step, not as an affected employee.

Some employers muddy this with "awareness" training that says something like, "never touch a lock unless your supervisor says it's okay." That's wrong, and it's dangerous. OSHA's standard has no supervisor-permission exception for affected employees removing locks. The authorized employee who applied the lock is the one who removes it. ^[1]

There is a narrow provision in 29 CFR 1910.147(e)(3) for when the authorized employee who applied a lock is gone and the lock has to come off. That path requires the employer to verify the authorized employee isn't in the facility, to notify that employee before they return, and to get management authorization. It's a controlled last resort, not a general override for a supervisor who wants a machine running again.

What's the difference in responsibility between affected and authorized employees?

An authorized employee does the lockout. An affected employee stays out of the way. That's the plainest version of a distinction that tangles up a lot of programs.

The authorized employee identifies energy sources, shuts down the equipment in a controlled sequence, isolates energy, applies the lock or tag, verifies the zero energy state, and releases stored energy. They're the ones going into or near the hazardous area to do the service work. Their training is deep and specific to each machine.

The affected employee operates or works near the equipment being serviced. Their responsibility during a lockout is passive: recognize the lockout is in place, don't interfere. They don't need to know how the authorized employee verified zero energy. They don't need to know every energy source on the machine. They need to know the lock or tag means stay out and don't restart.

The same person can be authorized for some equipment and affected for other equipment. A maintenance tech who performs lockouts on presses is authorized for those presses. Walk that same tech near a locked-out conveyor they have no role in servicing, and they're an affected employee for it. Your written program has to document both roles clearly. ^[1]

Here's the quick reference:

Responsibility	Authorized employee	Affected employee
Shut down the machine	Yes	Sometimes (if part of procedure)
Apply locks/tags	Yes	No
Verify zero energy	Yes	No
Recognize LOTO in use	Yes	Yes
Refrain from restarting	Yes	Yes
Remove their own lock	Yes	No
Receive equipment-specific training	Yes	No
Receive awareness training	Yes	Yes

What should affected employees do if they see something wrong with a lockout?

Stop, don't touch the equipment, and tell a supervisor or safety officer right away. That's the path most programs should spell out, and it's the piece a lot of small business LOTO programs leave out. The regulation tells affected employees what they can't do. Your written program has to tell them what to do when something looks off.

A machine that should be locked out but isn't. A lock that looks tampered with. A co-worker or supervisor leaning on them to restart tagged equipment. In each case the affected employee needs a clear route, and "stop, don't touch, report" is it.

That sounds easy on paper. In a production environment with schedule pressure, affected employees sometimes need explicit permission to slow things down. Your written program should state plainly that anyone who reports a LOTO concern in good faith won't face retaliation. That's more than good manners. Section 11(c) of the OSH Act prohibits retaliation against employees who report safety concerns, and an affected employee who flags a LOTO violation is engaged in protected activity. ^[4]

If an injury ties back to a LOTO failure, you'll also need to file an incident report with the right documentation. Getting that right after the fact matters. Catching the problem before anyone gets hurt matters more.

Does tagout-only equipment change what affected employees need to do?

Yes, and the change raises the bar. When equipment can't be physically locked out (no lockout point exists on the energy isolation device), OSHA allows tagout-only procedures under specific conditions. The employer has to demonstrate that tagout gives full employee protection. The tag has to carry a warning that the equipment may not be operated, and affected employees have to understand what the tag means.

Here's the problem tagout creates. A tag is no physical barrier. A lock stops a restart. A tag only warns against one. OSHA's standard requires that employees in the immediate area be notified that the equipment is under tagout when the tagout doesn't provide protection equivalent to a lockout. ^[1]

So for affected employees working near tagout-only equipment, the awareness duty is higher, not lower. They have to understand that a tag carries the same legal weight as a lock, even though it doesn't look as serious. Tagout-only equipment is exactly where accidental restarts happen, because a strip of cardstock reads as less final than a padlock. Your written program for tagout situations should say, in plain words, that the tag means the same thing as a lock: do not touch, do not restart, do not remove.

How do group lockout procedures affect affected employees?

Group lockout comes up when several authorized employees work on the same equipment at the same time. Affected employees mostly stay outside that mechanism, and their duty doesn't change: don't touch the hasp, don't remove any lock, don't restart the equipment. The standard at 29 CFR 1910.147(f)(3) requires each exposed authorized employee to apply their own personal lock to a group lockout device, so no single person can energize the equipment while others are still inside. ^[1]

Where group lockout touches affected employees is at shift changes. If a maintenance crew is mid-procedure at the end of a shift, the incoming shift's affected employees need to know the equipment is still locked out. Protection has to carry across the handoff. Your written program should address shift-change communication directly, because this is where gaps open up in real facilities.

OSHA's 1910.147(f)(4) requires continuity of lockout or tagout protection when shifts change, with the outgoing authorized employee coordinating with the incoming crew. ^[1] Affected employees on the incoming shift should hear the lockout status from their supervisor, not be left to work it out on their own.

How should a small business document affected employee training and responsibilities?

Inspectors expect three things on paper: who was trained, when, and what was covered. ^[1] OSHA doesn't dictate a form, so you have room to keep it simple.

The approach that actually holds up is a sign-in sheet tied to a training outline. The outline lists the three core topics (recognition, purpose, and the non-interference rule) and notes which equipment or work areas the training covered. Trainer and employee both sign.

Keep those records for the length of employment plus whatever your state requires afterward. Some state OSHA plans set longer retention than federal OSHA. California's Cal/OSHA and Washington's L&I both run state plans with requirements that can exceed federal minimums, so check your own state's rules rather than assuming the federal floor applies. ^[5]

Retraining records carry as much weight as initial ones. Change a procedure, add a machine, or work through a near-miss, and you document the retraining. An inspector who finds a four-year-old training record and a machine you added two years ago with no matching retraining record will cite you.

If you're building or updating a LOTO written program and want a template that handles affected-employee documentation correctly, SafetyFolio's generator produces one with the right employee-category structure built in.

For a wider look at how a compliant written safety program is structured, the hazard communication article shows how a similar documentation framework works for another standard that also splits workers by type.

What OSHA citations are common for affected employee LOTO failures?

The most cited piece of the whole LOTO standard is 29 CFR 1910.147(c)(1), the requirement to have an energy control program at all. ^[6] Affected-employee violations cluster around two provisions underneath that.

29 CFR 1910.147(c)(7)(i)(B): inadequate or undocumented training for affected employees. Inspectors ask affected employees what they know about LOTO. If the answers show they've never been told what a lock means or that they should never remove one, that's a citation.

29 CFR 1910.147(c)(1) with 1910.147(c)(4): a written program that never identifies affected employees or their responsibilities. If your energy control program talks only about the authorized-employee procedure and never mentions affected employees, that's a program deficiency an inspector can write up.

Lockout/tagout stays near the top of OSHA's most cited standards for general industry year after year. In fiscal year 2023, OSHA issued 2,554 LOTO violations. ^[6] That's a high rate for a standard most small manufacturers assume they've handled with a padlock and a one-line mention at onboarding.

Penalty size tracks the classification. A serious violation (the employer knew or should have known of the hazard) runs up to $16,550 per violation as of 2024. A willful violation, where the employer intentionally disregarded the standard, reaches $165,514 each. ^[3]

What does a solid affected-employee section of a LOTO program actually look like?

Most written LOTO programs pour 90% of their words into the authorized-employee procedure and then hand the affected-employee section a single vague sentence, or nothing. Here's what a section that actually works needs.

First, a clear definition of who qualifies as an affected employee in your specific facility. Don't copy OSHA's generic definition and stop. Name the job titles or work areas that put people in the category. "All production operators, packaging line workers, and QC inspectors who work in the manufacturing area" is useful. "All affected employees" is circular and useless.

Second, a specific description of what locked-out equipment looks like in your building. Which machines get locked out? What color are the locks? Where do tags hang? The more specific your program, the better prepared your people are.

Third, the explicit prohibition: no affected employee may remove, bypass, or restart any machine with a lockout or tagout device applied, for any reason, without explicit authorization from the safety officer under the procedures in Section X.

Fourth, the reporting path. Who do affected employees contact when they see a problem? Name the person or position. Not a generic "supervisor."

Fifth, the retraining trigger list. What events send affected employees back for retraining before they return to their work area?

Five elements. Most programs in small manufacturing shops carry maybe two of them. Getting all five in place is what separates a compliant program from a document that only looks compliant.

Frequently asked questions

Can an affected employee remove a lock if a supervisor tells them to?

No. A supervisor's verbal instruction does not override 29 CFR 1910.147. Only the authorized employee who applied a lock may remove it, with one narrow exception: the employer's written procedure for removing a lock when that authorized employee is unavailable, which requires management sign-off and documented steps, not a verbal order. An affected employee who removes a lock at a supervisor's request is still in violation of the standard.

How is an affected employee different from an authorized employee under LOTO?

An authorized employee actually performs the lockout or tagout, applies locks or tags, verifies the zero energy state, and does the service work. An affected employee operates or works near the equipment being serviced but has no role in the lockout procedure itself. Their only duty during a lockout is to not interfere with it. The same person can be authorized for some equipment and affected for other equipment, depending on their job.

Does an affected employee need to attend LOTO training every year?

OSHA's 29 CFR 1910.147 does not require annual retraining on a fixed schedule. It requires retraining when there's reason to believe the employee lacks knowledge of their responsibilities, when procedures change, or when new equipment arrives. Some employers run annual refreshers anyway as a best practice, and that's reasonable, but the obligation is competency-based, not calendar-based. Document whatever training you do provide.

What should an affected employee do if they see a machine running that should be locked out?

Don't touch the equipment. Alert a supervisor or safety officer immediately. If your facility has a stop-work authority policy, this is the moment to use it. Your written LOTO program should specify exactly who affected employees report to and what happens after the report. Document the near-miss afterward, because OSHA expects you to investigate close calls and use them to improve your program.

Does OSHA require affected employees to have their own personal locks?

No. Personal locks are for authorized employees. In group lockout situations, each exposed authorized employee applies a personal lock to the hasp. Affected employees do not apply or carry locks as part of their role. Giving an affected employee a personal lock without also training them as an authorized employee creates confusion and potential liability.

What's the penalty for an employer whose affected employees weren't trained on LOTO?

A serious OSHA violation under 29 CFR 1910.147(c)(7) carries a penalty of up to $16,550 per violation as of 2024. If multiple employees in the same facility received inadequate training, OSHA may cite each instance separately. Willful violations reach $165,514 each. The employer, not the untrained employee, bears the legal penalty, though the worker bears the physical risk.

Is an operator who shuts down their own machine before maintenance an affected employee or an authorized one?

It depends on what your written procedure assigns them. If the operator's role is only to shut down and step away before the authorized employee applies the lock, they're functioning as an affected employee. If the procedure requires them to apply a personal lock to a group hasp, that step makes them an authorized employee for that portion of the work. Your written program must define each role clearly. Ambiguity here is a common citation trigger.

Do affected employees in offices or remote areas need LOTO training?

Only if their work area overlaps with areas where lockout or tagout procedures happen. A purely office-based employee who never enters the production floor falls under the "other employee" category and needs only general awareness that LOTO exists, not full affected-employee training. Document why you've categorized workers the way you have, especially if OSHA asks.

What if an affected employee works near a locked-out machine and doesn't know the lockout is in place?

That's a program failure, not an employee failure. Your written LOTO program and your communication procedures need to make sure affected employees in the area are informed when a lockout is in effect. For group lockouts and shift changes, 29 CFR 1910.147(f)(3) and (f)(4) require continuity of protection and coordination. A worker who unknowingly works near energized equipment because nobody told them is a preventable incident waiting to happen.

Is LOTO required for all machines, or only certain equipment?

OSHA's 29 CFR 1910.147 applies to machines and equipment where unexpected energization, startup, or release of stored energy could cause injury. There are exclusions: normal production operations covered by a separate standard, cord-and-plug equipment where unplugging is adequate, and hot-tap operations on live pipelines. But for most industrial and manufacturing equipment, LOTO applies. When in doubt, apply it.

How does a tagout-only procedure change what an affected employee must do?

The core rule is the same: don't remove the tag, don't restart the equipment. But because a tag provides no physical barrier, affected employees need to take it more seriously, not less. OSHA requires that when tagout is used instead of lockout, employees in the area be notified. Your training for tagout situations should emphasize that the tag carries the same legal and safety weight as a lock, even though it looks less imposing.

What records does OSHA expect to see for affected employee LOTO training?

At minimum: employee names, training dates, and evidence of what was covered. A signed attendance sheet tied to a training outline is standard. There's no mandated format, but records must be available for OSHA inspection. Retain them for the length of employment, and document any retraining events separately. If an inspector finds employees whose training records are missing or predate a major equipment change, expect a citation.

Can a small business with fewer than 10 employees skip formal affected employee LOTO training?

No. The LOTO standard in 29 CFR 1910.147 applies to all general-industry employers with at least one employee, regardless of size. There's no small-business exemption for the training requirement. The practical difference is that smaller shops may find it easier to train everyone together, but the legal obligation is identical to a facility with 500 workers.

Sources

1. OSHA, 29 CFR 1910.147 - The Control of Hazardous Energy (Lockout/Tagout): Definitions of affected employee, authorized employee, training requirements, group lockout procedures, and tagout conditions under OSHA's lockout/tagout standard.
2. OSHA, Control of Hazardous Energy (Lockout/Tagout) overview page: OSHA estimates the lockout/tagout standard prevents approximately 120 fatalities and 50,000 injuries per year.
3. OSHA, Penalties: Serious violations carry up to $16,550 per violation; willful violations reach $165,514 per violation as of 2024.
4. OSHA, Whistleblower Protection Programs (Section 11(c) of the OSH Act): Section 11(c) of the OSH Act prohibits retaliation against employees who report safety concerns, including LOTO violations.
5. OSHA, State Plans overview page: State OSHA plans (e.g., California's Cal/OSHA, Washington's L&I) may have requirements that exceed federal OSHA minimums.
6. OSHA, Top 10 Most Cited Standards, Fiscal Year 2023: OSHA issued 2,554 LOTO (29 CFR 1910.147) violations in fiscal year 2023, making it one of the top cited standards in general industry.
7. OSHA, Enforcement Directives (LOTO Compliance Directive CPL 02-00-147): OSHA compliance directive providing enforcement guidance and clarification on lockout/tagout requirements, including employee category distinctions.
8. Bureau of Labor Statistics, Census of Fatal Occupational Injuries (CFOI): BLS fatal occupational injury data used to contextualize the risk associated with energy control failures in general industry.
9. OSHA, Publications (Lockout/Tagout fact sheet, OSHA 3120): OSHA fact sheet on LOTO confirming that affected employees must be trained in the purpose and use of energy control procedures.
10. OSHA, Standard Interpretations - 1910.147, Energy Control: OSHA letters of interpretation clarifying employee categories, tagout-only conditions, and program documentation requirements under 29 CFR 1910.147.