Which employees must receive lockout tagout training

Last updated 2026-07-09

What does OSHA actually require for lockout tagout training?

OSHA requires every employee touched by energy control to be trained, but the depth depends on their role. The governing standard is 29 CFR 1910.147, the Control of Hazardous Energy standard, usually called lockout/tagout or LOTO. Section 1910.147(c)(7) spells out who gets trained on what. ^[1]

The standard names three training categories by name. Each carries different content requirements, different documentation, and different retraining triggers. Miss a category and you are looking at a citation, because LOTO lands on OSHA's top-ten most-cited list year after year. ^[2]

The penalty stakes are real. As of 2024, willful or repeat violations of 1910.147 run up to $161,323 per violation, and serious violations up to $16,131. ^[3] The injury stakes are worse. BLS tracks amputations and crush injuries tied to uncontrolled energy release, and lockout tagout failures sit among the leading causes of the amputations reported in U.S. workplaces each year. ^[4]

Who are authorized employees and what training do they need?

Authorized employees are the people who physically lock out or tag out equipment before servicing it. Maintenance mechanics, electricians, HVAC technicians, and anyone else who applies the lockout device and restores energy when the work is done.

For these workers, 1910.147(c)(7)(i)(A) requires training on the recognition of hazardous energy sources, the type and magnitude of energy in the workplace, and the methods needed to isolate and control it. ^[1] That is specific knowledge, not a generic safety pep talk. An authorized employee at a sheet metal plant needs to know the exact voltage of the press they service, the exact way to bleed the pneumatic lines on that machine, and what happens if stored hydraulic energy is not released first.

So authorized employee training has to be job-specific and equipment-specific. A one-size-fits-all LOTO video does not satisfy the standard. OSHA has said in letters of interpretation that generic training falls short when hazards differ by machine or process. ^[5] Your written energy control procedures, required under 1910.147(c)(4), should map straight to what you train authorized employees on.

Here is a wrinkle worth remembering. The authorized employee is almost always also an affected employee on some machines, so their training has to cover both roles when that is the case. More on the affected category in the next section, and see our guide to OSHA 1910.147 affected employee training requirements for the detail.

Who are affected employees and what do they need to know?

Affected employees run the machinery being serviced, or they work in an area where LOTO is in use. A machine operator who runs a press all day but calls maintenance when it jams is affected. A shipping clerk whose station sits next to a conveyor being locked out is affected. They do not apply the locks. They just need to know why the locks are there and what they must never do. ^[1]

The content for affected employees under 1910.147(c)(7)(i)(B) is narrower. They have to understand the purpose and use of the energy control procedure, and they have to be trained never to try to restart or re-energize equipment that is locked or tagged out. ^[1] Simple, and yet this is where people die. A production worker who impatiently flips a switch while a mechanic is still inside the machine is not acting out of malice. Nobody ever told them what the lock means.

Affected training does not need the technical depth of authorized training. These workers do not need to know how to bleed a hydraulic system. They need one message, concrete and repeated: see a lock, do not touch the machine. That message should not be buried in the last ten minutes of a three-hour orientation.

One mistake small manufacturers make over and over is assuming production workers pick this up during general onboarding. OSHA does not accept that assumption. The training has to be documented, specific to LOTO, and tied to the actual procedures used in your building.

Who counts as an 'other employee' and what training do they get?

Other employees are workers whose jobs put them, or may put them, in an area where energy control procedures are used. That is the third category, spelled out in 1910.147(c)(7)(i)(C), and it is the one people forget. ^[1]

The requirement is light but real. These employees have to be instructed in the purpose and use of the energy control procedure. A quality auditor walking the production floor. A warehouse worker who ducks into the maintenance bay now and then. A supervisor who oversees both production and maintenance crews. All of them qualify. They need enough to recognize that a locked-out machine is off limits and to know who to ask if they have a question.

This is the category most often missing from written programs. Build a training matrix, then do an honest walk-through of your facility and ask who actually enters spaces where LOTO is active. The answer is almost always wider than maintenance and operations.

What training is required for tagout-only programs instead of lockout?

Tagout-only training is heavier than lockout training, not lighter. Lockout is the preferred method under 1910.147. Tagout is allowed only when equipment cannot be locked out, and even then OSHA makes the employer demonstrate that tagging gives equivalent protection. ^[1]

When you run a tagout system, 1910.147(c)(7)(ii) requires all employees to be trained on the limitations of tags. Tags are warning devices only. They do not physically stop energization. They must never come off without authorization. ^[1] OSHA's language here is blunt: employees must understand that tags are essentially warnings attached to energy-isolating devices and "do not provide the physical restraint on those devices that is provided by a lock." ^[1]

If any part of your facility runs tagout-only, document that you trained every employee on those limitations. An inspection that turns up a tagout program without that specific training element is a citation waiting to happen.

When must employees be retrained on lockout tagout?

Retraining is condition-based, not calendar-based. Under 1910.147(c)(7)(iii), you retrain when one of four things happens, and OSHA does not mandate an annual refresher by default. ^[1]

First, retrain when there is reason to believe an employee does not have the required knowledge or skills. An incident, a near-miss, or a periodic inspection showing someone off procedure all count. Second, retrain when job assignments change. Third, retrain when machines, equipment, or processes change in a way that introduces a new hazard. Fourth, retrain when the energy control procedures themselves change.

Notice what is not on that list: a fixed annual interval. Still, plenty of employers build in an annual refresher anyway, and it is a defensible call. The periodic inspections required under 1910.147(c)(6) tend to surface small deviations that trigger the retraining obligation regardless. ^[1] Do your annual procedure audits honestly and you will probably find retraining needs every year without trying.

The practical move is to build a trigger into your program. If someone moves from one production line to another with different equipment, that is a retraining event. Write that step into the program so it fires automatically, not only when someone happens to remember.

What do the required annual LOTO inspections have to do with training?

The annual inspection is the mechanism that keeps training honest. Under 1910.147(c)(6), employers must inspect each energy control procedure at least once a year, and an authorized employee other than the one using the procedure has to do it. ^[1] The point is to confirm the written procedure matches what workers actually do at the machine.

Inspection and training are wired together. If the annual review shows an authorized employee skipping a step in the isolation sequence, that finding triggers a mandatory retraining obligation under (c)(7)(iii). OSHA built these provisions to work as a pair. You do not get to note the deviation and move on. You retrain the employee.

You also have to certify the inspection in writing. The certification names the date, the equipment, the employees involved, and the person who did the inspection. ^[1] That is the paperwork an OSHA compliance officer asks for when they open a LOTO citation. No certification, no proof the inspection happened, and that gap is a separate citable failure.

Small businesses often treat the annual inspection as a formality to check off. It is not. It is the tool OSHA relies on to keep training current and procedures accurate as equipment changes.

Does lockout tagout training apply in construction and maritime as well as general industry?

1910.147 covers general industry only. Construction has its own energy control rules under 29 CFR 1926.417, which addresses electrical energy but lacks the broad multi-energy-source program structure of 1910.147. ^[6] Maritime operations fall under 29 CFR 1915.89, rewritten in 2019 to line up more closely with the general industry standard. ^[7]

Run a construction company and you are not off the hook for energy control, but the specific training structure in 1910.147(c)(7) does not apply to your crews directly. The principle holds regardless: anyone servicing energized equipment has to know how to control that energy safely, and supervisors have to make sure it happens.

Multi-employer worksites add another layer. Under OSHA's multi-employer citation policy, if a subcontractor does maintenance on-site and their employees are not trained on the host employer's LOTO procedures, both employers can catch exposure. ^[5] When your maintenance vendor shows up, you have every reason to verify their LOTO training matches your procedures for the equipment they are about to touch.

For how structured safety training works across other hazard categories, hazard communication training covers a parallel set of OSHA requirements that also sort employees by role and exposure.

How do you document lockout tagout training to satisfy OSHA?

The minimum is a certification with each employee's name and the dates of training, required under 1910.147(c)(7)(iv). ^[1] A single dated sign-in sheet may satisfy the letter of the standard, but it holds up poorly when OSHA wants to know whether the training actually covered the right topics.

Better records include the name and role of the trainer, the specific equipment or procedures covered, the training category (authorized, affected, or other), and a short description of content. Some employers add a brief written test at the end of authorized training. OSHA does not require it, but it helps during an inspection and it genuinely surfaces gaps you would otherwise miss.

Store records where you can pull them fast. An OSHA visit is not the moment to dig through filing cabinets. Digital records searchable by employee name are worth the five minutes it takes to set them up.

Building an energy control program from scratch? SafetyFolio's safety program generator produces a 29 CFR 1910.147-compliant written program, training requirements and procedure templates included, in about 15 minutes. You get a framework to customize instead of a blank page.

For another program with similar documentation demands, hazardous communication training and the requirements under 29 CFR 1910.1200 follow the same pattern: role-based content plus written certification.

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

The most common LOTO training violation is not training affected employees at all. 29 CFR 1910.147 has ranked in OSHA's top ten most-cited standards for at least a decade, and the training failures inside it follow a predictable script. ^[2]

Start with the affected-employee gap. Employers run a LOTO class for the mechanics and never tell the machine operators what a lock on their machine means. That is a straight violation of 1910.147(c)(7)(i)(B) and a routine finding in general industry inspections.

Second: weak authorized-employee training. A generic online course that explains the concept of energy control but never touches the specific energy sources and procedures at that facility does not meet the standard. OSHA has said in letters of interpretation that training must be relevant to the actual hazards the employee will face. ^[5]

Third: no retraining after a procedure change. Equipment gets modified, the procedure gets updated, and nobody retrains the mechanics who use it every day. The written procedure now says one thing and the workers do another. That is exactly what the annual inspection should catch, and it also shows up in incident investigations.

Fourth: missing or incomplete certification. The training happened, but nobody kept a record with the required elements. With no documentation, OSHA treats it as if the training never happened.

Does the size of your company affect who needs lockout tagout training?

No. 1910.147 has no size exemption. A five-person machine shop carries the same training obligations as a 500-person plant, as long as both have equipment that needs lockout during servicing. ^[1] The standard reaches every general industry employer whose people service or maintain machines where unexpected energization, startup, or release of stored energy could injure someone.

For small shops, the twist is that the owner is often the authorized employee, an affected employee, the supervisor, and the person documenting all of it. Wearing every hat does not shrink any of the obligations. It just means one person has to understand all of them.

Run a small crew where everyone does a little of everything, and you will likely find nearly all your employees land in the authorized or affected category. That is normal in small manufacturing, food processing, HVAC contracting, and similar trades. Document the categories honestly, train to the content each one requires, and keep your certifications current.

How does lockout tagout training connect to your broader written safety program?

Training rests on the written energy control program required under 1910.147(c)(1). ^[1] You cannot train employees on your LOTO procedures if you have no written procedures to train them to. The program comes first.

The written program has to document the scope, purpose, and rules for the program; the steps for shutting down, isolating, blocking, and securing machines; the rules for placing and removing lockout devices; and the requirements for testing machines after lockout. Authorized employee training should map exactly onto those written procedures.

This is where a lot of small employers stumble. They buy a generic LOTO course, run everyone through it, and figure they are covered. But if the course never references their actual written procedures, it misses the standard's intent, and it does nothing to prepare an employee to safely service the specific machine in front of them.

Think of it as three documents that have to agree: your written program, your machine-specific procedures, and your training records. A compliance officer who spots a gap between any two of them can cite all three.

For how LOTO training fits a full training structure, OSHA 10 Hour General Industry and OSHA 30 Hour General Industry courses both cover energy control as a topic, though neither substitutes for the machine-specific training 1910.147 demands.

What should a lockout tagout training program actually include?

A compliant LOTO program covers a defined set of elements, matched to the right employee categories. Here is what each group needs.

Authorized employees: the purpose of energy control; identification of every energy source on the equipment they service (electrical, hydraulic, pneumatic, thermal, chemical, gravitational, and stored mechanical energy); the magnitude of each source; step-by-step use of the facility's written procedures for each machine they work on; proper use and storage of lockout devices; how to verify a zero-energy state before starting; and how to restore equipment to service. ^[1]

Affected employees: what lockout and tagout mean; how to recognize a locked-out machine; the flat prohibition on restarting or removing energy-isolating devices; and who to contact with a question or concern. ^[1]

Other employees: a basic overview of the energy control program and what a tagged or locked-out machine means for access. ^[1]

Tagout-only situations: the limitations of tags versus locks, what a tag cannot do, and the rules for removing one.

Delivery can vary. Hands-on, in-person training works best for authorized employees because they have to demonstrate the procedure physically. Classroom or online delivery can work for affected and other employees as long as it covers the required content. Whatever format you pick, the certification requirements under (c)(7)(iv) still apply.

Frequently asked questions

Do part-time employees need lockout tagout training?

Yes. The obligation under 29 CFR 1910.147(c)(7) turns on job function and exposure, not employment status. A part-time machine operator who could try to restart locked-out equipment is an affected employee and needs affected-employee training. A part-time maintenance tech who applies lockout devices is an authorized employee and gets the full authorized-employee training.

Can a supervisor count as both an authorized and affected employee?

Yes, and it happens all the time. A working supervisor who both operates equipment and services it needs training that covers both roles. OSHA's categories are not mutually exclusive. Document both designations for that person and make sure the training record shows both content sets were covered.

Is there a required number of training hours for lockout tagout?

No. 29 CFR 1910.147 sets no minimum hours. The standard requires training that gives employees the knowledge and skills their role demands. OSHA judges adequacy by whether employees demonstrate the required understanding, not by time logged in a classroom. A short, sharp, equipment-specific session can outperform a long generic one.

Can employees receive lockout tagout training online?

Online training can cover the knowledge components for affected and other employees. For authorized employees, the standard implies the training has to be enough for them to safely perform the actual procedures. A pure online course with no hands-on practice on the specific equipment is unlikely to clear that bar. Pair online instruction with facility-specific, hands-on demonstration for authorized employees.

How often must lockout tagout training be repeated?

OSHA sets no fixed annual requirement. Retraining is required when a procedure changes, when job assignments change, when new equipment or hazards appear, or when an inspection shows an employee lacks required knowledge or skills. Many employers add annual refreshers as a buffer, since their annual procedure inspections regularly surface conditions that trigger mandatory retraining anyway.

What records must I keep to prove lockout tagout training happened?

Under 1910.147(c)(7)(iv), you must keep a certification with each trained employee's name and the dates of training. OSHA does not prescribe a form. In practice, records that also name the trainer, the content covered, and the employee's category (authorized, affected, or other) hold up far better in an inspection and are genuinely useful for tracking your own retraining.

Do contractors working at my facility need lockout tagout training?

Contractors servicing your equipment must be trained on your facility's energy control procedures. Under 1910.147(f)(2), you must inform them of your LOTO procedures, and their procedures must provide equivalent protection. You are responsible for making sure the outside employer and their people comply before they start work.

What happens if an OSHA inspector finds untrained affected employees?

Failure to train affected employees violates 1910.147(c)(7)(i)(B). OSHA typically classifies it as serious, which carries fines up to $16,131 per violation as of 2024. If the same violation was cited before, it becomes a repeat at up to $161,323. Willful violations carry the same upper limit. The employer has 15 working days to contest the citation.

Does 29 CFR 1910.147 apply to office workers in a facility that also has manufacturing?

Office workers who never enter production areas where LOTO is active, and whose work cannot be affected by energy control, likely fall outside the standard. But if those same workers occasionally cross through production areas where lockout may be in use, they qualify as other employees and need the basic awareness training under 1910.147(c)(7)(i)(C).

Is lockout tagout training required for employees in the food processing industry?

Yes. Food processing is general industry, so 29 CFR 1910.147 applies fully. Cleaning and sanitation workers matter especially here because they routinely service equipment. If sanitation workers reach into or clean machinery that could be energized, they are authorized employees and need the full authorized-employee training, not a basic awareness session.

What is the difference between lockout and tagout training requirements?

Authorized and affected employee training is required for both. When only tagout is used, 1910.147(c)(7)(ii) adds a requirement: all employees must be trained on the limitations of tags, including that a tag is a warning device only and cannot physically prevent energization the way a lock can. This added element is the one tagout-only programs most often miss.

Who is qualified to conduct lockout tagout training?

OSHA requires no specific trainer credential for LOTO. The trainer must know the energy control standard and the specific hazards and procedures at your facility. An experienced authorized employee, a safety professional, or a competent outside trainer with site-specific knowledge can all qualify. Content and documentation matter more than a trainer's certificate.

Can I use a third-party LOTO training course instead of writing my own?

Third-party courses can cover general knowledge, but you have to supplement them with facility-specific content. OSHA requires authorized employees to be trained on the energy sources, magnitudes, and actual written procedures at your specific facility. A generic course that never references your machines and procedures does not fully satisfy 1910.147(c)(7)(i)(A) for authorized employees.

What is the relationship between annual LOTO inspections and retraining?

The annual review of each energy control procedure, required under 1910.147(c)(6), must identify deviations or inadequacies. When it finds an employee not following the written procedure, retraining becomes mandatory under 1910.147(c)(7)(iii). The two are linked on purpose: the inspection is the mechanism that keeps training current as procedures and behaviors drift over time.

Sources

1. OSHA, 29 CFR 1910.147 Control of Hazardous Energy (Lockout/Tagout): Training categories (authorized, affected, other), content requirements, tagout limitations training, retraining triggers, and certification requirements under 1910.147(c)(7)
2. OSHA, Top 10 Most Cited Standards: 29 CFR 1910.147 consistently ranks among OSHA's top ten most-cited standards each year
3. OSHA, Penalties: Willful or repeat violations carry fines up to $161,323; serious violations up to $16,131 as of 2024
4. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities: BLS data on amputation and serious injuries in U.S. workplaces, including those linked to uncontrolled energy release
5. OSHA, Letters of Interpretation, 1910.147: OSHA letters of interpretation clarifying that generic training is insufficient when hazards differ by machine and that training must address specific energy sources and procedures at the facility
6. OSHA, 29 CFR 1926.417 Lockout and Tagging of Circuits (Construction): Construction industry energy control requirements under 1926.417, which address electrical energy differently from the general industry standard
7. OSHA, 29 CFR 1915.89 Control of Hazardous Energy (Maritime): Maritime industry energy control standard updated in 2019 to align more closely with 1910.147
8. OSHA, Control of Hazardous Energy (Lockout/Tagout) Overview: OSHA overview of hazardous energy control including the requirement for written energy control programs and trained employee categories
9. OSHA, Publications: OSHA publications, including the Control of Hazardous Energy materials describing lockout tagout requirements and hazards in general industry
10. OSHA, 29 CFR 1910.147(c)(6) Annual Inspection Requirement: Employers must conduct and certify annual inspections of each energy control procedure, performed by an authorized employee other than the one using the procedure