Which of the following applies in a lockout tagout procedure

Last updated 2026-07-10

What does OSHA's lockout tagout standard actually require?

The rule is 29 CFR 1910.147, "The Control of Hazardous Energy (Lockout/Tagout)." OSHA published it in 1989 and has not substantially revised it since. It covers general industry. Construction, agriculture, and maritime run under separate rules, so if your crews work in those sectors, 1910.147 is the wrong citation, though most of its logic still carries over.

The standard's stated purpose, quoted straight from 1910.147(a)(1)(i), is to "establish minimum performance requirements for the control of such hazardous energy." Read that word "minimum" twice. You can always do more than the standard demands. You can never do less.

Strip it down and every covered employer owes four things. A written energy-control program. Documented procedures for each piece of equipment. Training for every employee who touches or works near equipment during servicing. And an annual inspection of those procedures. Miss any one and you have a citable violation. Lockout tagout lands in OSHA's top ten most-cited standards year after year ^[1].

Before you build procedures from a blank page, see how the broader lockout tagout standard fits into the rest of your safety program.

Which employees does lockout tagout apply to?

1910.147 sorts workers into three buckets, and the bucket decides what training and protection each person gets.

"Authorized employees" apply the lock or tag. They do the servicing and maintenance. They need the deepest training: the types and magnitude of hazardous energy at each machine, the methods to isolate and control it, and the full energy-control sequence.

"Affected employees" run or use machinery that gets locked out, or they work in the area where lockout happens. They never apply locks. But they have to know a procedure is in place, why the equipment is off-limits, and that they must never try to restart locked-out equipment.

"Other employees" are everyone else who happens to work where lockout is used. Their training is the thinnest slice: don't touch locked-out equipment, and don't try to restart it.

Contractors get their own rule. Under 1910.147(f)(2), when you bring in an outside contractor to service your equipment, you and the contractor have to compare energy-control procedures. If the contractor's meet or beat yours, fine. But you cannot hand over the keys and walk off. The communication runs both directions.

Here's what trips up small shops. If an operator adjusts, sets up, or unjams a machine while it is still energized, and that work exposes them to unexpected energization, they are doing "servicing and maintenance" under the standard's definition. Doesn't matter what their job title says. The task decides coverage, not the title ^[2].

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

This is the real question behind the title. OSHA's Appendix A to 1910.147 gives a model energy-control sequence, and nearly every compliance program builds off it. Here it is, with the details inspectors actually check.

1. Prepare for shutdown. Identify all energy sources: electrical, hydraulic, pneumatic, mechanical, thermal, chemical, gravitational. Know the type, magnitude, and hazard of each. This is the step most employers under-document.

2. Notify affected employees. Tell everyone in the area the equipment is going down, why, and for how long. Not optional, not casual. Write down the notification.

3. Shut down the equipment. Use the machine's normal stopping procedure. Don't skip steps because the clock is running.

4. Isolate energy sources. Operate each isolating device so every source is physically disconnected. Open the breaker. Close the valve. Set the mechanical block. Every source, more than the obvious one.

5. Apply lockout or tagout devices. Each authorized employee puts their own personal lock on each isolating device. The lock goes on the device itself, never on a nearby pipe or housing. If the device can't take a lock, a tag can substitute, but the standard treats tagout as the weaker option because it gives no physical restraint ^[3].

6. Release or restrain stored energy. Bleed down hydraulic lines. Discharge capacitors. Block gravity-loaded parts. Release or block coiled spring tension. This step kills people when it gets skipped.

7. Verify isolation. Before any work starts, test that the equipment can't run. Hit the start button. Meter the electrical circuit. Required, not optional.

Some trainers compress this into six steps by folding notification into shutdown, or split it into eight by breaking out verification. The count moves around. The content doesn't. All seven elements above have to happen.

When the job is done, run the sequence in reverse to re-energize: clear tools and parts from the machine, confirm all employees are clear, remove the lockout devices (only the employee who applied a lock removes it, with narrow exceptions), notify affected employees, and restore power.

Does lockout tagout apply when tagout alone is used instead of a lock?

Yes. Tagout is allowed under 1910.147, but with strings attached. 1910.147(c)(3) says tagout devices "shall be used only when the energy isolating device is not capable of being locked out." Plain version: if the equipment can take a lock, you use a lock. Tagout alone is a fallback, never a preference.

When tagout is your only option, you have to show the tag gives equivalent protection. That usually means bolting on extra steps: pulling a valve handle, blocking a breaker in the open position, or adding another means to prevent energization. The tag, which has to read something like "Do Not Operate" or "Do Not Energize," is a warning. It is not a barrier.

OSHA letters of interpretation have held the line: a tagout program passes only when the equipment physically cannot be locked. An inspector will want to see that you actually evaluated that question, not that you reached for tags because locks felt like a hassle.

Say your shop runs tagout-only because some isolating devices are old toggle switches with no hasp holes. The fix is to retrofit those devices with lockable handles. Not to wrap a whole tagout program around outdated hardware ^[4].

What must a written lockout tagout program include?

1910.147(c)(1) requires a written program whenever employees service or maintain machinery where unexpected energization could hurt them. That's nearly every general industry employer. The written program has to spell out the scope, rules, and techniques, plus how you'll enforce them.

Past the program document, 1910.147(c)(4) requires a written procedure for each machine unless you can show all of the following: the equipment has a single energy source, that source fully isolates and de-energizes in one action, locking it out completely de-energizes the machine, the employee has sole control of the lock, the work creates no new hazards, and there's no uncertainty about the control method. That's a narrow exception. Most machines carry more than one energy source, or hold stored energy that needs extra steps.

For any machine that misses even one of those six conditions, a written procedure is required. Each one has to name the equipment, list the steps to shut down and isolate it, state the type and magnitude of energy, describe how to control it, and describe how to verify isolation.

Writing these documents takes real time. If you want a shortcut that still clears the standard, SafetyFolio's safety program generator walks you through the written program requirements in about 15 minutes and produces documents formatted for OSHA compliance, no consultant required.

Here's what auditors actually open the binder to check:

• Is there a list of every energy-isolating device and its location?
• Does the procedure give each step in order, more than describe the concept?
• Is the type and magnitude of energy listed (e.g., 480V three-phase, 150 psi pneumatic)?
• Is the person responsible for the annual inspection named, by name or title?
• Are group lockout and shift-change procedures covered when they apply?

What training is required under lockout tagout?

Training lives at 1910.147(c)(7). Authorized employees train to recognize hazardous energy sources, understand the type and magnitude of energy in their workplace, and know the isolation and control methods. Affected employees learn the purpose and use of the procedure and why they can't restart equipment. Other employees get awareness-level training only.

Retraining kicks in when a supervisor has reason to believe an employee doesn't grasp the procedures, when a procedure changes, or when the annual inspection turns up a gap. OSHA sets no minimum interval beyond those triggers, but most compliance attorneys run annual refreshers as a practical matter.

Training has to be certified in writing. That means records showing who trained, the date, and what the training covered. Verbal training with nothing on paper is citable as a recordkeeping violation under 1910.147(c)(7)(iv).

For the wider picture on what OSHA expects from training documentation, see our guide to osha training.

What is the annual periodic inspection requirement?

1910.147(c)(6) requires an annual inspection of the energy-control procedure for each machine or type of machine. An authorized employee other than the one using the procedure has to perform it. In a small shop, that math means you need at least two trained authorized employees to satisfy the independent-review requirement.

The inspection has to be certified in writing and name the machine or equipment, the date, the employees involved, and the person who did the inspection. For a lockout procedure, the review can be an observation of the employee running it. For a tagout procedure, the certification has to include a review with each authorized employee.

Small businesses miss this one constantly. The annual inspection is not a drill. It's a documented review confirming the written procedure is still accurate and the employee understands it. Change a machine, add an energy source, or rewire a control panel, and the procedure has to be updated and re-inspected ^[5].

Does lockout tagout apply to electrical work specifically?

This is where it gets messy. Electrical work in general industry runs mainly under 29 CFR 1910.333 (electrical safety-related work practices), not 1910.147. The two standards overlap and can both hit the same task, which confuses even experienced safety managers.

OSHA has clarified through letters of interpretation that when an electrical hazard exists during servicing or maintenance, both standards can apply. 1910.147 governs the broader energy-control process. 1910.333 adds requirements specific to exposed live parts: qualified persons, arc flash boundaries, and personal protective equipment.

For most non-electrical machines that also carry electrical energy (motors, control panels), 1910.147 is the primary standard. For work on electrical distribution equipment itself, and for electricians doing similar tasks, read 1910.333 and NFPA 70E alongside 1910.147. They work together. They don't swap in for each other ^[6].

What are the exemptions and exceptions to lockout tagout?

1910.147 carries several exemptions that catch employers off guard.

The standard doesn't touch normal production operations unless the employee has to remove or bypass a guard, or put part of their body into a point of operation or danger zone. Press a button to run a machine, and 1910.147 doesn't apply to that act. Reach into the power zone to fix that same machine, and it does.

Plug-and-cord equipment is exempt when the cord stays under the exclusive control of the employee doing the work, the plug is out, and plugging it back in is the only way to re-energize. The words that matter are exclusive control. Unplug a drill, but if a coworker could plug it back in while you work, the exemption doesn't cover you.

Hot tap operations on pressurized lines get their own treatment. The standard lets certain hot tap work continue on an energized line, but only when the employer can show shutdown is infeasible, hot tap procedures are established, and special equipment is used. This is a narrow carve-out for utilities and pipeline operators.

Minor tool changes and adjustments during normal production can qualify for an alternative method when a specific set of conditions under 1910.147(a)(2)(ii) is met. People call these "minor servicing" exemptions, and inspectors scrutinize them. "Minor" has nothing to do with how long the task takes. It turns on whether the employee is exposed to unexpected energization ^[7].

What do OSHA citations for lockout tagout violations actually cost?

Lockout tagout has sat in OSHA's top ten most-cited standards every year for decades. In fiscal year 2023, OSHA issued 2,554 lockout tagout violations, and the penalty total across all cited employers runs well into the millions ^[1].

As of January 2024, OSHA's maximum penalty for a serious violation is $16,131 per violation. Willful or repeat violations top out at $161,323 per violation ^[8]. Inspectors don't have to stop at one violation per inspection. A facility with no written program, no employee training, and no annual inspections can catch three separate citations, each carrying its own penalty.

The fines are only the start. Injured workers drive workers' compensation costs, litigation exposure, and in fatality cases a possible criminal referral under Section 17(e) of the OSH Act. OSHA estimates about 3 million workers service and maintain energized equipment each year, and that the standard prevents roughly 120 fatalities and 50,000 injuries annually ^[2].

Current OSHA penalty tiers:

Violation Type	Max Penalty Per Violation
Other-than-serious	$16,131
Serious	$16,131
Willful	$161,323
Repeat	$161,323
Failure to abate	$16,131 per day

Penalties adjust for inflation every year. The figures above are effective January 2024 ^[8].

How does lockout tagout apply to group work and shift changes?

When more than one authorized employee works on the same equipment, group lockout applies. 1910.147(f)(3) requires each authorized employee to attach a personal lock to a group lockout device (usually a hasp or a lockout box) so the equipment can't be re-energized until every employee pulls their lock. No single person controls the group lock. Each person controls their own.

Shift changes open a specific gap. If the first-shift electrician removes their lock before the second-shift electrician applies theirs, you get a window of uncontrolled energy. 1910.147(f)(4) requires a procedure that keeps protection continuous through shift or personnel changes. In practice that means overlapping locks: the incoming employee locks out before the outgoing employee removes their lock.

This is one spot where a written procedure earns its keep. "We always hand off to the next shift" is not a procedure. A procedure names the steps, the sequence, and who owns each one ^[5].

What are the most common lockout tagout mistakes small businesses make?

A handful of patterns show up over and over in citation data and incident reports.

The biggest is a generic written program with no machine-specific procedures. Inspectors know the difference on sight. A program that says "employees will isolate energy before servicing equipment" is not a procedure. A procedure names the machine, lists each energy source, gives the isolation step for each one, and specifies how stored energy gets released.

Second: reaching for tagout when lockout is feasible. Owners pick tags because they're cheaper and faster. That reasoning does not satisfy 1910.147(c)(3).

Third: skipping or not documenting the annual inspection. It's easy to overlook in a small operation where the same two people run every maintenance task. But the standard requires it, and OSHA asks for the certification during an inspection.

Fourth: assuming a main power switch means a single procedure covers the machine. Plenty of machines carry secondary sources, from spring-loaded mechanisms to residual hydraulic pressure to charged capacitors in control circuits. A procedure that skips a source is incomplete.

Fifth: no training records. An employer who trained people verbally and wrote nothing down sits in the same spot, from OSHA's enforcement view, as one who never trained at all ^[3].

Starting your lockout tagout program from scratch? Our lockout tagout overview is the place to begin, and SafetyFolio's program generator turns your equipment list into compliant written procedures without a safety consultant.

Frequently asked questions

Which of the following must be done before removing a lockout device?

Before removing any lockout device, the authorized employee has to confirm all work is complete, all tools and materials are clear of the machine, all employees stand safely away from the equipment, and affected employees are notified that power is coming back. Only the employee who applied the lock may remove it, except in rare employer-override situations documented under 1910.147(e)(3).

Does lockout tagout apply to cord-and-plug equipment like power tools?

Not always. Under 1910.147(a)(2)(iii)(A), cord-and-plug equipment is exempt if the plug stays under the exclusive control of the employee doing the work, meaning they keep it in hand or within sight and control at all times. If another worker could re-energize the tool by plugging it back in, the exemption falls away and full lockout is required.

How often must lockout tagout training be conducted?

1910.147(c)(7) sets no fixed retraining interval. Retraining is required when an employee's knowledge or skills look deficient, when procedures change, or when the annual inspection reveals a gap. Most compliance professionals run annual refresher training as a best practice. Initial training has to happen before an employee is assigned to service or maintenance work the standard covers.

Can a supervisor remove an employee's lockout device if the employee is unavailable?

Yes, but only by following a specific employer procedure. 1910.147(e)(3) lets a supervisor or employer representative remove a lock when the employee who applied it is unavailable, but only after verifying the employee is out of the danger zone, making a reasonable effort to contact them, and making sure they know their lock was removed before they return to work. The override has to be documented.

What is the difference between lockout and tagout?

A lockout physically stops an energy-isolating device from being operated by putting a keyed lock right on the device. A tagout hangs a warning tag on the device but adds no physical restraint. 1910.147 requires lockout whenever the equipment can take a lock. Tagout alone is permitted only when the device can't be locked, and even then the employer must add extra protective measures.

Does lockout tagout apply to construction sites?

Not directly. 29 CFR 1910.147 applies to general industry. Construction runs under 29 CFR 1926 Subpart K for electrical work. Construction employers often follow 1910.147's principles voluntarily, and when a general industry employer's workers do construction-type tasks, the applicable standard depends on the nature of the work and the OSHA directorate covering the site.

What counts as a hazardous energy source under lockout tagout?

1910.147 covers electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational energy. Any source capable of causing unexpected movement, shock, burn, or release of hazardous material counts. Employers must identify every energy source for each machine and document how each gets isolated. Missing even one source, like a spring-loaded part or a charged capacitor, is a citable violation.

What records does OSHA require for a lockout tagout program?

OSHA requires three record types under 1910.147: written energy-control procedures for each covered machine, training certifications showing who trained, when, and on what, and annual inspection certifications for each procedure. The inspection record has to name the machine, the date, the employees involved, and the inspector. The standard sets no retention period, but three to five years is common industry practice.

Does lockout tagout apply to tasks that take only a few minutes?

Duration is not the test. If the task exposes a worker to unexpected energization or startup, 1910.147 applies no matter how short it is. A 30-second unjamming task that puts a hand in a pinch point is covered. The only question that matters is whether an unexpected energy release could cause injury.

What happens if you do not have a written lockout tagout program?

OSHA can cite you under 1910.147(c)(1) for a serious violation, with penalties up to $16,131 per violation as of 2024. Because no written program usually means no machine-specific procedures, no training records, and no annual inspections, one inspection can produce several citations at once. The written program is the foundation everything else rests on.

How does group lockout work when multiple employees are servicing one machine?

Under 1910.147(f)(3), each authorized employee attaches a personal lock to a group lockout hasp or lockout box. The machine can't be re-energized until every employee removes their own lock. No single person controls the group device. The employer needs a written group lockout procedure, and if shifts change mid-job, a shift-change procedure has to keep protection overlapping before any lock comes off.

Are there OSHA-approved lockout tagout training courses?

OSHA does not certify or approve specific lockout tagout courses the way it does for OSHA 10 and OSHA 30 outreach programs. The standard requires training that meets 1910.147(c)(7), and it's the employer's job to make sure the training is adequate. Training can happen in-house, through a third party, or online, as long as it covers all required content and is documented with certifications.

Sources

1. OSHA, Top 10 Most Cited Standards FY2023: Lockout tagout (1910.147) is consistently among OSHA's top ten most-cited standards, with 2,554 violations cited in FY2023.
2. OSHA, Control of Hazardous Energy (Lockout/Tagout) - Standard 1910.147 overview: OSHA estimates the lockout tagout standard prevents approximately 120 fatalities and 50,000 injuries annually, and about 3 million workers perform covered service and maintenance tasks.
3. OSHA, 29 CFR 1910.147 - Control of Hazardous Energy (Lockout/Tagout): The standard states that tagout devices shall be used only when the energy isolating device is not capable of being locked out, per 1910.147(c)(3).
4. OSHA, Letters of Interpretation - Lockout/Tagout: OSHA letters of interpretation confirm that tagout-only programs are acceptable only when equipment physically cannot be locked, and employers must evaluate this genuinely.
5. OSHA, 29 CFR 1910.147(c)(6) - Periodic Inspections: 1910.147(c)(6) requires an annual inspection of each energy-control procedure, certified in writing, conducted by an authorized employee other than the one using the procedure.
6. OSHA, 29 CFR 1910.333 - Selection and use of work practices (electrical): Electrical safety-related work practices are governed by 1910.333, which applies alongside 1910.147 when electrical hazards exist during equipment servicing.
7. OSHA, 29 CFR 1910.147(a)(2) - Application: 1910.147(a)(2)(iii)(A) provides the cord-and-plug exemption: the plug must be under exclusive control of the employee performing the work.
8. OSHA, Penalties: As of January 2024, OSHA's maximum penalty for serious violations is $16,131 per violation and $161,323 per violation for willful or repeat violations.
9. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities: BLS injury data tracks fatalities related to contact with objects and equipment, the category that includes most lockout tagout-preventable fatalities.
10. OSHA, Lockout/Tagout eTool: OSHA's eTool provides the model energy-control sequence and machine-specific procedure templates consistent with 1910.147 Appendix A.