Brady lockout tagout: hardware, software, and OSHA compliance explained

Last updated 2026-07-09

What is lockout tagout and why does OSHA require it?

Lockout/tagout (LOTO) is the process of physically isolating hazardous energy before any worker services or maintains equipment. Hazardous energy includes electrical, mechanical, hydraulic, pneumatic, chemical, and thermal sources. You lock out the energy isolating device (a switch, valve, breaker) and attach a tag so no one accidentally re-energizes the machine while someone is inside it.

OSHA's standard is 29 CFR 1910.147, titled "The Control of Hazardous Energy." It applies to general industry. Construction has a parallel rule at 29 CFR 1926.417, and maritime follows 29 CFR 1915.89. The standard covers every employer that has workers who perform servicing or maintenance on machines where unexpected energization could cause injury. ^[1]

Here's why it matters. OSHA estimates that LOTO compliance prevents roughly 120 fatalities and 50,000 injuries per year. ^[1] The Bureau of Labor Statistics consistently shows "caught in or compressed by" and "contact with objects and equipment" as leading mechanisms of serious nonfatal injuries, the exact scenarios LOTO is designed to prevent. ^[2]

The standard has teeth. 29 CFR 1910.147 is routinely in OSHA's top 10 most-cited standards. In fiscal year 2023, OSHA issued 2,554 violations of this standard, with penalty amounts that have risen since OSHA's maximum per-serious-violation cap hit $16,131 in 2023 and adjusts annually for inflation. ^[3]

New to the written program side of this? See our overview of what a safety and health program should be for how LOTO fits into a broader safety program structure.

What does 29 CFR 1910.147 actually require you to have?

The standard breaks into four obligations. Know all four, because auditors and compliance officers check each one independently.

1. A written energy control program. The standard at 1910.147(c)(1) says: "The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative." That's the core obligation in the agency's own words. The program must document the scope, rules, and techniques for controlling hazardous energy. ^[1]

2. Machine-specific written procedures. For each piece of equipment, you need a documented step-by-step procedure unless you can prove a single procedure covers all energy sources, all employees, all shifts, and there's no potential for stored energy. That exception is narrow. Most equipment needs its own procedure card.

3. Employee training. Authorized employees (workers who lock out) need training on recognizing hazardous energy, methods of isolation, and the means and methods for LOTO. Affected employees (workers who operate the equipment) need to know why they can't restart a locked-out machine. Other employees in the area need basic awareness training. Retraining is required when procedures change or when an inspection reveals deficiencies. ^[1]

4. Periodic inspections. At least annually, a designated authorized employee must inspect each energy control procedure and certify it in writing. The certification must include the machine name, date, employees involved, and the inspector's name. ^[1]

For the written program itself, our workplace safety training guide covers how to structure and document training that satisfies this kind of OSHA requirement across your whole program.

Who is Brady and what do they sell for lockout tagout?

Brady Corporation (NYSE: BRC) is a Milwaukee-based manufacturer of identification and safety products. They've sold LOTO hardware since the 1980s and are the largest dedicated LOTO product supplier in North America. That doesn't mean they're always the right choice. It does mean their product line is genuinely broad and their products are engineered to meet OSHA and ANSI standards. ^[4]

Brady's LOTO catalog breaks into several categories.

Locks: Brady sells padlocks specifically for LOTO in single-key and keyed-differently configurations. Their safety padlocks are typically aluminum or steel, with non-conductive bodies for electrical applications. Brady padlocks range from roughly $8 to $30 per lock depending on material and key configuration. Keyed-alike groups (where a supervisor holds a master) are also available.

Tags: Lockout tags are the printed warning tags that attach to the locked-out device. Brady sells pre-printed and blank tags. OSHA requires tags to warn against hazardous conditions and include a legend such as "Do Not Start," "Do Not Open," or "Do Not Operate." ^[1] Brady tags are typically printed on heavy-duty nylon or card stock with a cable tie.

Hasps: A hasp is the hardware that lets multiple workers apply their individual locks to a single energy isolating point. When six technicians work on one machine, all six locks go on one hasp. Nobody restarts the machine until all six locks come off. Brady's hasps run from about $10 to $45.

Lockout stations and kits: Brady sells wall-mounted lockout stations (basically a shadow board with organized hardware) and preassembled kits for specific equipment types (electrical panels, valves, cylinders, gate valves). Kits range from $50 for a basic starter kit to $400 or more for a full industrial station.

Procedure writing tools and software: This is where Brady has expanded a lot in the last decade, and it's where the "Brady lockout tagout software" search term comes from. More on that below.

Brady is not the only option. Master Lock (through its Safety division) and Zing Green Products are the most common alternatives. Master Lock's LOTO hardware is comparable in quality and price. For a small business with a handful of machines, the brand honestly matters less than having the right hardware in the right quantity.

What is Brady lockout tagout software and do you need it?

Brady sells two software products in the lockout tagout software category: LINK360 (their cloud-based LOTO procedure management platform) and an older desktop-based procedure writing tool. They also sell a Lockout Tagout Guide app for mobile procedure access.

LINK360 is the current flagship. It's a SaaS platform where you build machine-specific LOTO procedures using a guided template, attach photos of the actual energy isolating points, track procedure reviews, manage training records, and generate compliance reports. Brady markets it to manufacturers, utilities, and facilities managers who have dozens to hundreds of machines and need audit-ready documentation.

Pricing for LINK360 is not publicly listed. Brady quotes by site and machine count. Based on dealer quotes and industry discussion, expect somewhere in the $2,000 to $8,000 per year range for mid-sized facilities, though smaller packages may exist. The honest answer is you have to contact Brady or a distributor for a real number.

Do you need it? Depends on your operation. If you have more than 30 machines, multiple shifts, and you're struggling to keep procedure cards updated and training records in order, dedicated lockout tagout software makes real sense. The audit trail it generates is genuinely useful when OSHA shows up. If you have 5 machines and 8 employees, a binder with laminated procedure cards and a spreadsheet for training records satisfies the standard at a fraction of the cost.

Brady's software is not the only option. Beamex, SafetyCulture (iAuditor), and EHS Insight all have LOTO procedure modules. Some are cheaper. Some are more integrated with broader EHS management. Brady's edge is that the software is built specifically around LOTO procedure writing and talks to their label printers, which helps if you already run Brady hardware.

For small businesses that need a written energy control program but don't need full procedure-management software, SafetyFolio's safety program generator can produce an OSHA-compliant LOTO program in about 15 minutes. That gives you the written program foundation the standard requires before you decide whether to layer on hardware management software.

Our hazardous communication article covers a related written program requirement (HazCom / SDS management) that often gets handled alongside LOTO in small business compliance reviews.

How do you write machine-specific lockout tagout procedures?

This is where most small businesses fall short. They have a written program, maybe they have some locks and tags, but they don't have the individual machine procedures the standard actually requires.

A machine-specific LOTO procedure must include:

• The machine or equipment name and location
• Steps to shut down the equipment
• Each energy isolating device and its location (with photos when possible)
• Type and magnitude of energy (e.g., "480V 3-phase electrical, breaker CB-7 in panel E2")
• Steps to release or restrain stored energy after lockout
• The steps to verify the machine is de-energized (the "try" step)
• Steps to restore energy after work is complete

Brady's LINK360 software walks you through each of these fields with a guided form and lets you attach photos from a mobile device. Their older procedure writer does the same on the desktop and exports printable procedure cards.

Doing this without software? Walk each machine with a clipboard, take photos on your phone, fill in a template. OSHA's own LOTO small entity compliance guide has a sample procedure format you can follow. ^[5] The key is specificity. "Turn off the machine" is not an acceptable procedure. "Press red STOP button on control panel, rotate main disconnect handle on the east side of the machine to the OFF position, and apply personal lock to the disconnect hasp" is.

Brady sells pre-printed procedure card holders (ID-labeled, laminated card holders) that mount directly on equipment. That's a practical approach even if you write the procedures manually. Write them once, laminate them, mount them on the machine. Reusable and visible.

One place people get confused: OSHA's standard does allow a single general procedure to cover multiple machines if the employer can demonstrate the procedure applies without modification. OSHA's letter of interpretation from March 21, 1996 clarifies that the exception is narrow and hinges on whether all energy sources and all work tasks are truly identical across the machines covered. When in doubt, write separate procedures. ^[5]

What are the OSHA training requirements for lockout tagout?

Training under 1910.147(c)(7) splits into three categories based on employee role.

Authorized employees must understand and demonstrate the ability to recognize hazardous energy sources, know the type and magnitude of energy in the workplace, and know the methods and means to isolate and control that energy. These are the workers physically applying locks.

Affected employees need to know the purpose and use of LOTO. They need to understand why they cannot restart equipment that's locked out. They do not need to know how to apply locks themselves.

All other employees in areas where LOTO is used need awareness-level training. LOTO is used here, don't touch locked-out equipment, here's why.

The standard requires retraining when there's reason to believe an employee doesn't understand the procedures, when procedures change, or when the annual inspection reveals deficiencies. There's no calendar-interval retraining requirement beyond those triggers, though many employers run annual refreshers anyway as a practical matter. ^[7]

Brady sells LOTO training kits (interactive cards, sample lock stations, demonstration equipment) and licenses to online LOTO courseware. Their training materials are OSHA-compliant in format. Whether you use Brady's training products or build your own, the content has to cover the actual hazards and procedures specific to your workplace. Generic online courses alone rarely satisfy the site-specific expectation in OSHA enforcement.

For building a training framework that includes LOTO alongside other required topics, see our workplace safety training resource.

How often do you have to audit lockout tagout procedures?

The standard requires at least one inspection per energy control procedure per year. The inspection must be performed by an authorized employee other than the one using the procedure being inspected.

The certification must document the machine or equipment on which the procedure was used, the date of inspection, the employees included in the inspection, and the name of the person who performed it.

For lockout procedures (as opposed to tagout-only procedures), the review is a review of the procedure with each authorized employee. For tagout-only procedures, the inspection must also include a review of the limitations of tags. ^[1]

OSHA compliance officers will ask to see these certifications. They are not optional paperwork. If you're managing multiple machines across multiple shifts, keeping those certifications organized is genuinely hard without a system. This is one of the real use cases for lockout tagout software: it tracks when each procedure was last inspected and prompts you when the annual review is due.

A simple spreadsheet with columns for machine name, date of last inspection, inspector name, and next due date gets the job done for small facilities. Brady's LINK360 automates the tracking and generates the compliance report in a format ready for an OSHA audit.

Brady lockout tagout kits vs. building your own kit: which makes more sense?

Brady's preassembled kits are convenient and make sure you have compatible hardware. Their popular general-purpose kits typically include a mix of safety padlocks, hasps, tags, and a carrying case, and retail around $150 to $300 depending on configuration and distributor. ^[4]

Building your own kit from components usually costs about the same but takes more time and expertise to get right. The upside is you spec exactly what your equipment needs. If all your isolating devices are large-diameter gate valves, you need specific valve lockouts that may not be in a general kit.

Here's a practical breakdown of common components and rough pricing:

Component	Brady (approx.)	Generic/Other Brand
Safety padlock (keyed different)	$10-20 each	$5-15 each
Hasp (6-hole aluminum)	$15-30	$8-20
LOTO tags (100-pack)	$20-40	$10-25
Circuit breaker lockout (standard)	$8-15	$4-10
Gate valve lockout	$12-25	$7-18
Plug lockout (electrical cord)	$8-18	$5-12
Wall-mounted station with shadow board	$80-200	$40-120

The honest verdict: for locks and hasps, Brady's quality is good and the price premium over generics is modest. For tags, the OSHA requirements are simple enough that generic tags from any major supplier satisfy the standard. For machine-specific lockout devices (valve lockouts, breaker lockouts), the fit matters more than the brand, so buy whatever fits your equipment.

Nobody with a small operation needs Brady's most expensive full-facility kits. Start with a per-worker kit (one padlock per authorized employee, a hasp, and tags) and add machine-specific lockout devices as you inventory your equipment.

What are the differences between lockout and tagout, and when is tagout alone allowed?

Lockout means you physically prevent energy flow with a device you can lock (a circuit breaker lockout, a valve lockout, a plug lockout). Tagout means you attach a warning tag to the energy isolating device without a physical lock.

OSHA's standard has a clear preference. Lockout is the default. Tagout alone is only permitted when the employer can demonstrate that locking out the equipment is not feasible because the energy isolating device is not capable of being locked. ^[1]

When tagout alone is used, the standard requires additional safety measures to provide the equivalent protection of lockout. Those measures might include removing a valve handle, using a block, or other means of preventing operation.

The standard states: "Tagout devices, when used, shall be affixed to each energy isolating device by a means that limits removal, and shall be attached in a manner and location that would be immediately obvious to anyone attempting to operate the equipment or process." ^[1]

The practical implication: most modern equipment has lockable isolating devices. If you have equipment that genuinely can't be locked out, document that finding in writing and document the additional protective measures you're using. Compliance officers scrutinize tagout-only programs more carefully than lockout programs.

Brady sells tags in both lockout and tagout configurations, including heavy-duty tags rated for outdoor and wet environments.

How does group lockout tagout work when multiple workers service one machine?

Group lockout is required when servicing or maintenance is performed by more than one employee on the same machine or piece of equipment. The standard at 1910.147(f)(3) requires a group lockout device (typically a hasp) that gives each authorized employee equivalent protection to their own individual lock.

Here's the procedure. One authorized employee (often the primary or crew leader) is responsible for locking out the energy isolating devices. Each worker then applies their personal lock to the hasp. Nobody restores energy until everyone removes their lock. In a large facility with shift changes, the standard allows for a shift/personnel transfer procedure, but that procedure must be documented and followed consistently.

Brady's multi-lock hasps come in 6-lock, 13-lock, and larger configurations. For complex equipment with multiple energy sources, a Brady lockout station mounted on the machine (sometimes called a satellite station) holds the hasps and machine-specific procedure cards in one visible spot.

Group lockout is one of the areas where procedure gaps turn into fatalities. The most common failure is workers removing their locks before all hazards are controlled, or a supervisor removing a worker's lock without authorization. OSHA's guidance is clear: only the authorized employee who applied the lock can remove it, with a narrow exception for when that employee has left the facility and the employer can demonstrate a documented removal process was followed. ^[5]

What are the most common OSHA LOTO violations and how do you avoid them?

OSHA consistently cites 29 CFR 1910.147 in its top 10 most-cited standards. ^[3] The most frequent specific violations:

No written energy control program (1910.147(c)(1)): Many small businesses have locks and tags but no written program document. This is usually the first citation in any inspection.

Missing machine-specific procedures (1910.147(c)(4)): A general program exists but individual equipment procedures don't.

No annual inspections or missing certification records (1910.147(c)(6)): The audits happen informally but no one documents them.

Training not documented (1910.147(c)(7)): Employees were trained but there's no record.

Inadequate training (1910.147(c)(7)(i)): The training was generic and didn't cover site-specific hazards or procedures.

Improper application (1910.147(d)): Workers are observed servicing equipment without following LOTO procedures.

The fix for most of these is documentation. The physical hardware (locks and tags) is the cheaper part. The written program, the procedure cards, the training records, and the inspection certifications are what protect you in an OSHA inspection.

For employers who want a documented written program as the foundation, SafetyFolio's safety program generator walks you through building an OSHA-compliant LOTO written program in about 15 minutes, covering the required program elements without a safety consultant.

Our resource on workplace safety training covers how to structure and document training records for OSHA compliance across multiple program areas.

How does Brady LOTO software compare to other lockout tagout software programs?

If you're evaluating lockout tagout software, the field has gotten more crowded in the last five years. Here's an honest comparison.

Brady LINK360: Built specifically for LOTO procedure management. Integrates with Brady label printers. Strong procedure template library. Good audit trail and inspection scheduling. Best fit for Brady-hardware shops or facilities where LOTO is the primary EHS software need. Pricing is not transparent; requires a sales conversation.

SafetyCulture (iAuditor): A general inspection and audit platform with LOTO procedure templates. Much broader than just LOTO. Good mobile interface. More affordable for small businesses at around $24 per user per month for paid plans. Less purpose-built for LOTO.

EHS Insight: A broader EHS management platform with a LOTO module. Better fit for mid-to-large companies that want one system for incident reporting, training, inspections, and LOTO. Higher price point, typically $5,000 or more per year.

Beamex CMX or similar calibration-heavy tools: Sometimes used in facilities where LOTO is part of a maintenance management workflow. Niche fit.

Manual systems (binder + spreadsheet + laminated cards): Underrated. For a facility with under 20 machines and under 25 workers, a well-organized manual system satisfies the standard completely. The risk is human error in keeping it updated.

The question to ask before buying any software: what specific compliance problem are you trying to solve? If it's "I don't have a written program," software is the wrong first purchase. If it's "I have 80 machines across 3 shifts and my procedures are always out of date," software pays for itself.

No study has directly measured compliance outcomes between facilities using Brady LINK360 versus manual systems. The honest position is that the tool matters less than whether someone is actually responsible for maintaining it.

Frequently asked questions

Does OSHA require a written lockout tagout program for small businesses?

Yes. 29 CFR 1910.147(c)(1) requires a written energy control program for any employer with workers who perform servicing or maintenance on machines with hazardous energy. There is no small-business exemption. The written program must exist before workers do any LOTO work. Size affects how detailed your machine-specific procedures need to be, but the written program requirement applies to a 5-person shop the same as a 500-person plant.

What is Brady LINK360 and is it worth the cost?

LINK360 is Brady's cloud-based software for writing, storing, and managing machine-specific LOTO procedures. It tracks inspection schedules, stores training records, and generates audit-ready reports. It integrates with Brady label printers. It's worth the cost if you have 30 or more machines, multiple shifts, and you're struggling to keep procedures current and inspections documented. For a smaller operation, a binder and a spreadsheet satisfy the same standard at no software cost.

How much do Brady lockout tagout kits cost?

Brady's preassembled LOTO kits range from about $50 for a basic single-person kit to $400 or more for a full wall-mounted station with multiple locks, hasps, and machine-specific lockout devices. Individual safety padlocks run $10 to $20 each. Hasps run $15 to $30. Tags are cheap, usually $20 to $40 for a 100-pack. You don't need the Brady brand for tags to satisfy the OSHA standard; any OSHA-compliant tag from any supplier works.

Can you use tagout alone instead of lockout?

Only if the energy isolating device cannot physically be locked. OSHA's 1910.147 makes lockout the default and requires documented justification for tagout-only programs. When tagout alone is used, you must take additional measures (removing valve handles, blocking machine parts) to provide equivalent protection. Tagout-only programs get more scrutiny from OSHA compliance officers because tags alone can be removed or ignored in a way a physical lock cannot.

How often do LOTO procedures need to be reviewed or updated?

OSHA requires at least an annual inspection (audit) of each energy control procedure. The review must be documented with the machine name, date, employees involved, and inspector name. Beyond the annual requirement, procedures should be updated any time the machine is modified, the work tasks change, or an inspection reveals the procedure doesn't match actual practice. Brady LINK360 and similar software automate the tracking of when each procedure's annual review is due.

What information must a machine-specific LOTO procedure include?

A compliant procedure must include the machine's name and location, shutdown steps, the location of each energy isolating device, the type and magnitude of energy (e.g., 480V electrical, 200 PSI hydraulic), steps to lock or block each device, steps to release stored energy, verification steps to confirm de-energization, and steps to restore energy after work is complete. Photos of the actual isolation points are not required but strongly recommended and are a standard feature in Brady's procedure writing tools.

Who is an authorized employee versus an affected employee under OSHA LOTO?

An authorized employee is a worker who physically applies the lockout or tagout device to energy isolating equipment before servicing or maintenance. An affected employee is one who operates or uses the equipment being locked out. Authorized employees need full LOTO training including hazard recognition and isolation methods. Affected employees need training on why they cannot operate locked-out equipment. Both categories require documented training records.

What happens if a worker leaves before removing their lock during group lockout?

The standard says only the authorized employee who applied the lock can remove it. If that employee has left, OSHA allows an employer procedure for removing the lock only after the employer verifies the employee is not in the facility, makes reasonable effort to contact the employee, and ensures the employee knows the lock was removed before they return. That removal procedure must be documented in writing. Removing a co-worker's lock without that process is a violation.

Are there OSHA LOTO requirements specific to electrical work?

Yes. Electrical work also falls under 29 CFR 1910.333 (electrical safety-related work practices) in addition to 1910.147. For qualified electrical workers, de-energizing and locking out electrical systems is required before work within limited approach boundaries. Both standards apply; compliance with 1910.147 alone does not automatically satisfy 1910.333 for electrical tasks. NFPA 70E provides additional industry-recognized guidance for electrical LOTO procedures.

Can Brady lockout tagout software replace a written LOTO program?

No. OSHA requires a written energy control program as a standalone document. Software is a tool for managing procedures and records; it is not itself the required written program. A Brady LINK360 account does not satisfy 1910.147(c)(1) on its own. You still need a written program document that addresses scope, rules, and enforcement. Software then helps you manage the machine-specific procedures and training records that the standard separately requires.

What OSHA LOTO violations carry the highest penalties?

OSHA classifies LOTO violations as serious or willful. Serious violations carry up to $16,131 per violation (2023 figure, adjusted annually for inflation). Willful violations, meaning the employer knew about the hazard and deliberately ignored it, carry up to $161,323 per violation. Repeated violations also hit the higher tier. Multiple citation items in one inspection (missing written program plus missing procedures plus no training records) can stack into significant total penalties.

Does Brady make lockout tagout hardware for specific equipment types like valves and pneumatic lines?

Yes. Brady's catalog includes gate valve lockouts, ball valve lockouts, pneumatic fittings lockouts, electrical plug lockouts, circuit breaker lockouts for standard and large breakers, cable lockouts for unusual geometries, and pneumatic/hydraulic line plugs. The right device depends on your specific equipment. Brady's website has a selection guide by application. Competitors like Master Lock Safety and Zing make equivalent products, often at lower price points, with similar OSHA compliance.

What is the OSHA LOTO standard's exception for minor tool changes?

29 CFR 1910.147(a)(2)(ii) excludes minor tool changes and adjustments during normal production operations if the work is routine, repetitive, and integral to production, and if the alternative measures used provide effective protection. This exception is narrow and frequently misapplied. Replacing a blade, adjusting a feed mechanism, or clearing a jam generally requires full LOTO. When in doubt, apply LOTO. OSHA enforcement has consistently interpreted this exception narrowly.

How many locks does each worker need for a LOTO program?

Each authorized employee needs their own personal lock, uniquely keyed, that only they control. One lock per worker is the baseline. Workers who service multiple machines simultaneously may need additional locks. The hasp handles group situations by letting multiple locks secure a single isolation point. Brady and most LOTO suppliers sell employee LOTO kits that include a personal padlock, tags, and a carrying pouch as a starting package for each authorized employee.

Sources

1. OSHA, 29 CFR 1910.147 The Control of Hazardous Energy (Lockout/Tagout): Full text of OSHA's LOTO standard including program, procedure, training, and inspection requirements; tagout limitations; and group lockout rules
2. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program: Contact with objects and equipment and caught-in or -between are leading mechanisms of serious workplace injury and fatality
3. OSHA, Top 10 Most Frequently Cited Standards: LOTO (1910.147) is routinely a top-10 cited standard; 2,554 citations issued in FY2023
4. Brady Corporation, Lockout Tagout Products: Brady product line covers locks, tags, hasps, stations, kits, and LOTO procedure management software; pricing ranges for hardware
5. OSHA, Control of Hazardous Energy (Lockout/Tagout) Small Entity Compliance Guide (OSHA 3120): OSHA's sample LOTO procedure format and guidance on group lockout removal procedures when an employee has left the facility
6. OSHA, Hazardous Energy Control (Lockout/Tagout) eTool: OSHA guidance on authorized vs affected vs other employee training requirements under 1910.147(c)(7)
7. OSHA, 29 CFR 1910.333 Electrical safety-related work practices: Electrical LOTO requirements for qualified electrical workers that apply alongside 1910.147
8. OSHA, Penalties: OSHA maximum penalty per serious violation of $16,131 (2023) and willful violation maximum of $161,323, adjusted annually for inflation
9. OSHA, 29 CFR 1926.417 Lockout and tagging of circuits (Construction): Parallel OSHA LOTO requirement applying to construction industry