What is lockout tagout used for? The complete OSHA guide

Last updated 2026-07-10

What is lockout tagout actually used for?

Lockout tagout keeps machines from starting, energizing, or releasing stored energy while a worker is servicing, cleaning, unjamming, or otherwise working on them. The name describes two physical tools: a lock that physically blocks an energy-isolating device from being operated, and a tag that warns other workers not to restore energy.

The problem LOTO solves is simple and brutal. A machine that is off is not safe. Capacitors store electrical charge. Hydraulic lines hold pressure. Springs stay loaded. A conveyor belt can restart the second someone hits the wrong button. Lockout tagout deals with every one of those energy forms, more than the obvious "turn it off" step.

The OSHA standard at 29 CFR 1910.147 covers "the control of hazardous energy" in general industry. ^[1] There are parallel standards for construction (29 CFR 1926.417) and maritime, but 1910.147 is the one most small businesses will deal with. OSHA estimates the standard protects roughly 3 million workers who service and maintain equipment. ^[1]

Here is the stake in one sentence. OSHA says proper LOTO prevents about 120 fatalities and 50,000 injuries every year. ^[1] The Bureau of Labor Statistics consistently shows caught-in and struck-by machinery events among the leading causes of workplace death. ^[10] Those are the deaths LOTO is built to stop.

What types of hazardous energy does LOTO control?

29 CFR 1910.147 defines hazardous energy broadly, covering six recognized energy types. Your written program has to account for every form present in your facility, more than the electrical panel you can see.

Energy type	Common examples in small business
Electrical	Motors, control panels, capacitors, wiring
Mechanical	Rotating shafts, flywheels, press rams
Hydraulic	Lift tables, forklifts, injection molding machines
Pneumatic	Air cylinders, accumulator tanks, nail guns
Thermal	Steam lines, ovens, heated platens
Gravitational	Suspended loads, elevated machine components

Chemical energy (pressurized process piping) and radiation sources can also come into play depending on the operation, though the main 1910.147 standard focuses on the mechanical and electrical side. Process piping in facilities subject to PSM (29 CFR 1910.119) carries extra requirements on top. ^[11]

Stored energy is the part people miss. Bleeding a hydraulic line, blocking a suspended ram, and discharging a capacitor are required steps before work starts, not optional extra caution. ^[1] A machine can be fully isolated from its electrical source and still kill someone because a spring-loaded component lets go. Your LOTO procedure for each piece of equipment has to map every stored energy source and how to neutralize it.

When can tagout be used in place of lockout?

Lockout is always the preferred method. Tagout alone is allowed only when the energy-isolating device is not capable of being locked out. ^[1] That is the whole rule, and most people get it backwards.

The standard puts it this way: "When a tagout device is used on an energy-isolating device which is capable of being locked out, the tagout device shall be attached at the same location that the lockout device would have been attached." If a device physically cannot accept a lock, tagout becomes the permitted method, with added conditions.

Those conditions are not trivial. When tagout is used instead of lockout, the employer has to show the tagout program "will provide a level of safety equivalent to that obtained by the use of a lockout program." ^[1] In practice that means extra protective measures: removing and isolating a circuit element, blocking a control switch, opening an additional disconnecting device, or removing a valve handle.

A warning tag by itself provides zero physical restraint. Anyone can pull a tag off. That is exactly why OSHA expects tagout-only programs to make up the difference with redundant physical measures. If your machines have hasp points and lock-accepting disconnect handles, use locks. Picking tagout for convenience instead of necessity is a citation waiting to happen.

OSHA has issued letters of interpretation on this point more than once. ^[3] When you audit your own program and catch yourself asking "could we just use a tag here?", answer the real question first: can this device accept a lock? If yes, use the lock.

What does a LOTO procedure actually include?

29 CFR 1910.147(c)(4) requires employers to develop, document, and use "energy control procedures" for each piece of equipment or type of equipment. ^[1] A generic "turn it off and tag it" instruction does not meet the standard. Not close.

A compliant machine-specific procedure usually covers:

1. The scope and purpose of the procedure, including the machine it applies to. 2. The steps to notify affected employees that servicing is starting. 3. The location of every energy-isolating device (breakers, valves, disconnect switches). 4. The type and magnitude of energy (e.g., 480V three-phase, 150 psi hydraulic). 5. The steps to shut down the equipment in the correct sequence. 6. The steps to isolate each energy source. 7. How to apply lockout or tagout devices to each isolation point. 8. How to release or restrain stored energy (bleed hydraulics, block components, discharge capacitors). 9. How to verify isolation before work begins, which OSHA calls "verification of de-energization." 10. Steps to restore equipment to service when work is complete.

The standard has one narrow exception for procedures that don't need to be written down: the equipment has a single energy source, the isolation point is easy to find and reach, locking out fully de-energizes the machine, the employee doing the work applies the lock, and no accumulated energy exists. ^[1] That exception covers fewer machines than people think. Most commercial equipment has multiple sources or stored energy, so write the procedure.

For small businesses building these without a full-time safety director, a structured template saves real time. SafetyFolio's safety program generator walks you through each required element machine by machine, so you're not reading the CFR and building from a blank page.

Who does OSHA require to be trained on LOTO?

The standard splits workers into two main categories, and the training differs for each. ^[1] Get the categories wrong and your training records won't hold up in an inspection.

"Authorized employees" are the workers who actually apply and remove locks and tags. They need training on recognizing hazardous energy sources, the methods to isolate that energy, and how to control it during servicing.

"Affected employees" operate equipment that gets serviced, or work in an area where LOTO is used. They need to know the purpose of the program and that they must never restart or re-energize locked-out equipment.

"Other employees" who simply work in areas where LOTO happens must be trained on the prohibition against restarting locked-out machines.

Retraining is required whenever the employer has reason to believe a worker doesn't understand or follow the procedures, or when a change in job assignment, equipment, or process brings a new hazard. ^[1] The standard sets no fixed retraining interval. OSHA's enforcement history shows inspectors look for documented retraining after a near-miss or incident, so an annual refresher is a sensible norm even though the calendar isn't mandated.

Training must be certified in writing: who was trained, the date, and what the training covered. ^[1] Keep those records. An OSHA training violation here, especially after an injury, often comes with a willful or repeat classification.

What equipment requires a lockout tagout procedure?

The standard applies to "servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could cause injury to employees." ^[1] If that describes your equipment, LOTO applies.

That covers a long list of common small-business equipment: conveyor systems, commercial HVAC units, industrial compressors, printing presses, food processing machines, metalworking equipment, injection molding machines, packaging lines, CNC machines, and commercial electrical panels. If a worker ever reaches into a machine past a guard, clears a jam, changes a blade, cleans internal components, or makes an adjustment that puts body parts near moving parts, LOTO applies.

Some situations are excluded. Normal production operations aren't covered if employees are protected by other safeguards. Cord-and-plug connected equipment is exempt if the cord stays in the exclusive control of the employee doing the work, meaning they plug it in, keep the plug in their possession, and plug it back when done. ^[1] Electrical safety during normal operations falls under 29 CFR 1910.331 through 1910.335, not 1910.147.

A forklift being refueled or getting its battery changed confuses a lot of people. The vehicle itself falls under forklift certification requirements in 29 CFR 1910.178, but the moment a mechanic services the hydraulic system, LOTO applies to that work.

What are the required elements of a written LOTO program?

29 CFR 1910.147(c)(1) requires an "energy control program" that documents the employer's procedures, rules, and requirements for controlling hazardous energy. ^[1] This written program is one of the first documents an OSHA inspector asks to see.

The written program must address:

• The scope of the program (which operations and which employees are covered).
• Rules and techniques for controlling hazardous energy.
• Means to enforce compliance.
• Specific procedures for each piece of equipment (or equipment type, with documented justification).
• How locks and tags are assigned and controlled (who owns which lock, how to handle multiple employees on one machine).
• The process for group lockout, where more than one worker services the same equipment at once.
• The process for shift changes, so outgoing worker locks come off and incoming worker locks go on with no gap in protection.
• How to handle situations where the authorized employee isn't available to remove their own lock.

Group lockout is where small programs tend to have gaps. When two or three technicians work on one machine, each worker puts their own personal lock on the energy-isolating device, usually through a hasp that accepts multiple locks. No lock comes off until the worker who applied it is done and clear. ^[1]

The written program also needs review and updates whenever equipment or procedures change. The standard sets no fixed review interval, but documenting an annual review is good practice and gives you a clean answer when OSHA asks.

How often does OSHA cite lockout tagout violations?

Constantly. Lockout tagout has ranked among OSHA's top 10 most frequently cited standards for more than two decades. In fiscal year 2023, 29 CFR 1910.147 was the fifth most cited OSHA standard, with over 2,500 citations issued. ^[4]

The most common citation items are failure to develop machine-specific energy control procedures, failure to train employees, and failure to run the required periodic inspection of energy control procedures. That last one, the periodic inspection, catches a lot of employers off guard.

29 CFR 1910.147(c)(6) requires each energy control procedure to be inspected at least annually by an authorized employee other than the one using the procedure. ^[1] The inspection must be certified in writing, and for tagout programs, it includes a review with each affected and authorized employee. This is more than a paper review. The inspector walks through the procedure with the equipment in front of them, confirms the steps are current and correct, and documents the date, the machine, and the employees involved.

Penalty amounts vary by citation type. A serious violation currently carries a maximum penalty of $16,550 per violation. Willful or repeat violations reach $165,514 per violation. ^[5] Those numbers get adjusted for inflation periodically under the Federal Civil Penalties Inflation Adjustment Act.

What is the difference between lockout and tagout devices?

A lockout device is a physical restraint. It holds an energy-isolating device in the safe position so the machine cannot be energized. Lockout devices include padlocks, hasps, lockout clamps for circuit breakers, valve lockout covers, and lockable disconnect handles. The lock must be individually keyed or combination-locked, with the key or combination in the possession of the authorized employee who applied it. ^[1]

A tagout device is a prominent warning label, usually a red-and-white tag reading "Do Not Operate" or similar, attached to the energy-isolating device with a non-reusable, non-releasable attachment rated to at least 50 pounds of force. ^[1] Tags communicate. They don't restrain.

OSHA's own language is worth quoting: "Tagout devices, when used by themselves, do not provide the physical restraint on those valves or switches that is provided by a lockout device." ^[1] That one sentence is the entire argument for defaulting to lockout.

The hardware is cheap. A basic padlock set with individually keyed locks runs roughly $3 to $10 per lock. Hasps cost $5 to $15 each. A full LOTO kit for a small shop, including a lockout station with locks, hasps, tags, and device covers, typically runs $100 to $300. The cost of not having them is catastrophically higher. An incident report for a caught-in machinery injury starts a chain of consequences no lock price can justify skipping.

What does a LOTO periodic inspection involve?

The annual inspection required by 29 CFR 1910.147(c)(6) is one of the most commonly missed elements of LOTO programs. ^[1] Here is what it actually involves.

An authorized employee, someone who uses the energy control procedures but not the same person whose procedure is under review, conducts a physical review of each energy control procedure. They walk it against the actual machine. They confirm the isolation steps are correct, that every energy source is identified, and that the written procedure matches the current equipment configuration.

For lockout procedures, the certification has to include the date of the inspection, the machines covered, the employees involved, and the name of the person who performed it.

For tagout procedures, the inspection goes deeper. Because tagout provides less physical protection, the inspector also reviews with each authorized and affected employee the reasons the tagout program is used instead of lockout, and the limitations of tags.

Keep the documentation. OSHA does not specify a retention period for inspection records in 1910.147 itself, but a three-year minimum is sound practice and matches the retention approach in 29 CFR 1910.1020 for other safety records.

One practical trick: tie the annual procedure inspection to the same calendar date as your annual hazard communication program review. One compliance calendar instead of two.

How does LOTO apply to complex or multi-energy situations?

Most real equipment has more than one energy source, and that is where LOTO procedures get genuinely complicated. A CNC machining center might have three-phase electrical, pneumatic coolant pressure, and a gravity-loaded tool changer arm. Each source needs its own isolation step, in the right order.

Sequence matters. OSHA does not mandate a universal sequence, but standard practice is to shut the machine down normally first, then isolate electrical power at the disconnect, then handle remaining energy sources in decreasing order of hazard. Stored energy, particularly gravity and hydraulics, often comes last, because blocking or bleeding those sources sometimes needs the machine partially active first.

For complex systems with many isolation points, OSHA lets a single energy control procedure cover a group of similar machines if they have identical energy sources, the same isolation points, and the same shutdown sequence. ^[1] If there are differences, you need separate procedures. Quick audit: print your single generic procedure and walk each machine. If any step doesn't apply or a step is missing, that machine needs its own documentation.

Shift changes on complex equipment need special attention. The outgoing shift's authorized employees must not remove their locks until incoming employees have applied theirs. OSHA allows "coordinated" transfer procedures, but the written program has to describe exactly how it's done. A gap in lock coverage, even for 30 seconds, wipes out the protection LOTO is designed to provide.

What OSHA standards apply beyond 29 CFR 1910.147?

29 CFR 1910.147 is the primary LOTO standard for general industry, but it isn't the only one that matters.

For electrical work specifically, 29 CFR 1910.333 ("Selection and use of work practices") covers lockout and tagging in the context of electrical safety, as distinct from the 1910.147 servicing and maintenance context. ^[7] The two standards work together: 1910.147 applies to non-electrical-trade workers doing maintenance, and 1910.333 applies to electricians working on or de-energizing live electrical equipment.

In construction, 29 CFR 1926.417 is the LOTO counterpart for temporary power and electrical installations on job sites. ^[8]

Maritime work is covered by 29 CFR 1915.89 for shipyard employment. ^[9]

Process Safety Management (29 CFR 1910.119) layers extra requirements on top of LOTO for facilities handling highly hazardous chemicals above threshold quantities. ^[11] If you run a PSM-covered facility, LOTO is one element inside a broader Management of Change and Process Hazard Analysis framework.

For employers writing safety programs that touch several of these standards, knowing which standard governs which task and which employee genuinely matters. The OSHA basics overview is a good starting point for mapping which standards touch your operation. A well-built written program documents both the procedures and which standard each procedure is designed to satisfy.

Frequently asked questions

What does LOTO stand for?

LOTO stands for lockout tagout. Lockout means applying a physical locking device to an energy-isolating device so it cannot be operated. Tagout means attaching a warning tag to the same location when locking isn't possible. Together, the two controls prevent accidental energization or energy release during equipment servicing and maintenance.

Is lockout tagout required by OSHA?

Yes. 29 CFR 1910.147 requires general industry employers to have a written energy control program, machine-specific procedures, trained employees, and an annual inspection of each procedure. Failure to comply is one of OSHA's most frequently cited violations. Penalties for serious violations reach $16,550 per citation, with willful or repeat violations up to $165,514.

When can tagout be used instead of lockout?

Tagout alone is permitted only when the energy-isolating device is not capable of being locked out. When tagout replaces lockout, the employer must add protective measures, such as removing a circuit element, blocking a control switch, or opening an extra disconnect, to reach a level of safety equivalent to lockout. A tag by itself provides no physical restraint.

What are the six types of hazardous energy covered by LOTO?

29 CFR 1910.147 covers electrical, mechanical, hydraulic, pneumatic, thermal, and gravitational energy. Stored energy in each form, such as charged capacitors, pressurized hydraulic lines, or suspended machine components, must be identified and neutralized in every machine-specific LOTO procedure before work begins.

Does LOTO apply to cord-and-plug equipment?

Cord-and-plug connected equipment is exempt from 1910.147 if the plug is the only energy-isolating device, the equipment has no stored energy, and the worker doing the service keeps the plug in their exclusive personal control throughout the task. If any of those conditions aren't met, the standard applies. The exemption is narrow; when in doubt, write a procedure.

How many workers are injured each year from inadequate LOTO?

OSHA estimates that proper LOTO procedures prevent approximately 50,000 injuries and 120 fatalities annually in the United States. These are caught-in, struck-by, and electrocution events that happen during servicing and maintenance when hazardous energy isn't adequately controlled. The Bureau of Labor Statistics tracks many of these under contact-with-object and electrocution fatality codes.

What is a group lockout procedure?

Group lockout applies when more than one worker services the same equipment at the same time. Each authorized employee applies their own personal lock to the energy-isolating device, usually through a hasp that accepts multiple locks at once. No lock comes off until the worker who applied it confirms they are done and clear of hazardous areas. 29 CFR 1910.147(f)(3) covers group lockout requirements.

How often do LOTO procedures need to be inspected?

29 CFR 1910.147(c)(6) requires at least one annual inspection of each energy control procedure. The inspection must be done by an authorized employee other than the one using the procedure, and the results certified in writing with the date, machine name, employees involved, and inspector's name. For tagout programs, the inspection also requires a face-to-face review with each affected and authorized employee.

Can one LOTO procedure cover multiple machines?

Yes, but only if the machines are the same type, have identical energy sources, the same isolation points, and the same shutdown sequences. If any machine differs in any of those ways, it needs its own procedure. 29 CFR 1910.147 allows grouping by equipment type with that justification documented. Many shops with similar motors or identical conveyor sections can use this.

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

The written LOTO program must include a specific shift-change procedure. Incoming workers apply their own locks before outgoing workers remove theirs, so there is never a gap in lock coverage. Leaving a lock in place at the end of a shift without a coordinated transfer does not meet the standard, because the worker who applied a lock should be the one to remove it unless the written program addresses transfer explicitly.

What training do employees need for LOTO compliance?

Authorized employees who apply and remove locks need training on recognizing hazardous energy sources, isolation methods, and energy control procedures for their specific equipment. Affected employees who work near locked-out machines need training on the program's purpose and the ban on restarting equipment. All training must be documented in writing with the employee's name, the date, and the content covered.

Does LOTO apply to forklifts?

Forklift operation and powered industrial truck safety fall under 29 CFR 1910.178. But when a mechanic or technician services a forklift's hydraulic, electrical, or mechanical systems, that servicing work falls under 29 CFR 1910.147. The fork's hydraulic pressure, battery energy, and any stored mechanical energy all have to be addressed before the maintenance begins.

What records does an employer need to keep for LOTO compliance?

Required records include the written energy control program, machine-specific procedure documents, training certifications (employee name, date, content), and annual procedure inspection certifications (date, machine, employees involved, inspector name). 29 CFR 1910.147 does not set a retention period for inspection and training records, but three years is a widely recommended minimum to cover any inspection or litigation window.

Sources

1. OSHA, 29 CFR 1910.147: The Control of Hazardous Energy (Lockout/Tagout): Full text of the general industry LOTO standard including definitions, written program requirements, training, periodic inspection, and tagout limitations
2. OSHA, Lockout/Tagout Safety Topics section: OSHA estimates proper LOTO prevents approximately 120 fatalities and 50,000 injuries each year; stored energy requirements
3. OSHA, Standard Interpretations letters on 1910.147 tagout in lieu of lockout: OSHA interpretation letters clarifying when tagout is permissible in lieu of lockout and required additional protective measures
4. OSHA, Top 10 Most Frequently Cited Standards FY2023: 29 CFR 1910.147 was the fifth most frequently cited OSHA standard in general industry in FY2023 with over 2,500 citations
5. OSHA, Penalties page: Maximum serious violation penalty of $16,550 per violation; willful or repeat violations up to $165,514 per violation (current adjusted amounts)
6. OSHA, Lockout/Tagout Standard Number 1910.147 (device and application requirements): Requirements for lockout and tagout device types, attachment strength, and application
7. OSHA, 29 CFR 1910.333: Selection and use of work practices (electrical safety): Electrical lockout and tagging requirements for electrical work distinct from the 1910.147 servicing and maintenance standard
8. OSHA, 29 CFR 1926.417: Lockout and tagging of circuits (construction): Construction-specific LOTO requirements for temporary power and electrical installations on job sites
9. OSHA, 29 CFR 1915.89: Control of hazardous energy (maritime/shipyard): Maritime sector LOTO standard for shipyard employment
10. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program: BLS data on contact-with-object and electrocution fatalities in U.S. workplaces, categories that include machinery caught-in events preventable by LOTO
11. OSHA, 29 CFR 1910.119: Process Safety Management of Highly Hazardous Chemicals: PSM standard that layers additional requirements on top of LOTO for facilities handling highly hazardous chemicals above threshold quantities