Forklift lockout tagout: the complete OSHA compliance guide

Last updated 2026-07-09

What is forklift lockout tagout and does OSHA actually require it?

Yes, OSHA requires it. No ambiguity there.

The standard is 29 CFR 1910.147, the Control of Hazardous Energy standard, commonly called LOTO. It applies any time an employee services or maintains equipment where an unexpected startup, energization, or release of stored energy could hurt them. A forklift hits every one of those triggers. It runs on a battery or an internal combustion engine, it holds hydraulic pressure in the mast and lift cylinders, and it has potential energy any time a load sits up in the air ^[1].

The standard has been in place since 1989. OSHA estimates it prevents roughly 120 fatalities and 50,000 injuries each year across all industries ^[2]. For forklifts specifically, the Bureau of Labor Statistics consistently records 80 to 100 fatalities per year involving forklifts, with caught-in and struck-by events during maintenance among the leading causes ^[3].

Some employers assume that because a forklift is mobile equipment, the general industry LOTO standard doesn't apply and they can just rely on the operator controls. That assumption is wrong. OSHA's 1910.147 covers "the servicing and maintenance of machines and equipment in which the unexpected energization or startup... could cause injury to employees" ^[1]. A forklift is a machine. Changing a tire under a raised carriage, servicing the hydraulic system, or working on the electrical components all require full LOTO procedures.

For a broader look at how lockout tagout works across all equipment types, see our guide to lockout tagout.

What energy sources on a forklift need to be controlled?

A forklift carries several kinds of stored energy at once, and you have to control all of them before work starts. That's where forklift LOTO gets harder than people expect. This isn't an on/off machine.

For electric forklifts, the main sources are:

• Electrical energy from the battery pack (typically 24V, 36V, 48V, or 80V DC systems)
• Hydraulic pressure stored in the lift cylinder and tilt cylinder circuits
• Gravitational potential energy from a raised mast or load
• Residual capacitor charge in some electronic control systems

For propane or LP gas forklifts, add:

• Chemical/combustion energy from the fuel system (propane tank, fuel lines, carburetor)
• Mechanical energy from the engine if it was recently running (residual heat and pressure)
• Hydraulic pressure (same as electric)
• Gravitational potential energy (same as electric)

For internal combustion (diesel or gas) forklifts, the list is similar to LP but includes the diesel fuel system.

The hydraulic energy point catches a lot of people off guard. Even after the forklift is shut off and the battery is disconnected, a raised mast holds real stored energy. OSHA's standard explicitly requires that "all energy sources" be de-energized and all stored energy be restrained, released, or made otherwise safe before work begins ^[1]. Lowering the forks to the floor before starting LOTO is standard practice precisely because it kills that gravitational hazard. If the mast has to stay raised during work, it gets mechanically blocked.

Energy Type	Source on Forklift	Control Method
Electrical	Battery pack or ignition	Disconnect battery, apply lockout device to battery connector or disconnect switch
Hydraulic	Lift/tilt cylinders	Lower forks to ground, relieve residual pressure via control valve cycle
Gravitational	Raised mast/load	Lower forks; if mast must stay raised, install approved mast support block
Pneumatic	Some older models	Release pressure at service valve
Chemical/Combustion	Propane tank, fuel lines	Close tank valve, lock in closed position
Kinetic	Running engine	Shut off, allow to coast to full stop

How do you lockout tagout a forklift, step by step?

Here is a practical sequence that meets 29 CFR 1910.147's requirements. Your written procedure has to be equipment-specific, but this is the correct framework for most sit-down counterbalanced forklifts.

Step 1: Notify affected employees. Anyone working near the forklift needs to know it's coming out of service. This isn't just courtesy. It's an explicit requirement under 1910.147(d)(1) ^[1]. Post a sign on the seat or steering wheel if other operators use that aisle.

Step 2: Identify all energy sources. Review the machine-specific LOTO procedure before you touch anything. The procedure should be posted at or near the equipment or immediately accessible to the authorized employee.

Step 3: Shut down the equipment using normal stopping procedures. For electric forklifts: turn the key to off, remove the key. For LP or IC forklifts: turn the key to off, let the engine stop completely.

Step 4: Lower the forks (or load) fully to the ground. Do this before disconnecting power. Most manufacturers require it, and it eliminates the hydraulic and gravitational energy hazard.

Step 5: Isolate the energy source. For electric forklifts: disconnect the battery connector. The battery connector is the isolation point on most electric lifts. Apply a lockout hasp directly to the battery connector. If the forklift has a key-type battery disconnect switch, lock that. For LP forklifts: close and lock the propane tank valve with an approved valve lockout device.

Step 6: Apply your lockout device and your lock. The authorized employee applies their own personal lock, with their name on it or a tag attached. One person, one lock. Never share a lock or have a supervisor lock for a worker.

Step 7: Apply a tagout tag if a lockout device isn't feasible. This is the exception, not the rule. Tagout alone provides less protection, and OSHA requires that tagout-only procedures include additional safety measures like removing a component or blocking a control ^[1].

Step 8: Release or restrain stored energy. Cycle the lift and tilt controls to bleed residual hydraulic pressure. On LP units, open a downstream valve briefly to release line pressure, then close and lock. Let any hot surfaces cool if a burn hazard exists.

Step 9: Verify de-energization. Try to start the forklift. Check that the lift controls don't actuate. This is the "verify" step that many programs skip, and it's required under 1910.147(d)(6) ^[1]. If the machine moves or energizes, stop immediately and reassess your isolation.

Step 10: Perform the work.

Step 11: Restore energy (in reverse order). Remove tools and materials from the work area, confirm all guards are back on, alert affected employees, take your lock off last, reconnect the battery or open the fuel valve, then test the machine before returning it to service.

What does a written forklift LOTO procedure need to include?

Equipment-specific written procedures are not optional. 29 CFR 1910.147(c)(4)(ii) requires a written procedure for each piece of equipment unless the employer can show that the machine has no potential for stored energy and meets several other conditions that virtually no forklift meets ^[1]. Write the procedure.

OSHA's regulation spells out the minimum content. The procedure must include:

• The scope and purpose of the procedure
• The authorized steps for shutting down, isolating, blocking, and securing the specific forklift
• The specific steps for placement, removal, and transfer of lockout or tagout devices
• The requirements for testing or positioning the equipment to verify that lockout/tagout devices worked

A good forklift-specific procedure goes further than the minimum. Include the make, model, and serial number of the equipment. Add a photograph or diagram showing exactly where the battery connector or fuel shutoff sits. Note the type of lockout device required (hasp, valve lockout, cable lockout) and who's authorized to perform LOTO on that unit.

One common mistake is writing a single "forklift LOTO procedure" for a fleet with both electric and LP models. They have different energy sources and different isolation points. They need separate procedures, or at minimum a procedure with clearly separated sections for each power type.

If you want to build your written LOTO program without hiring a consultant, SafetyFolio's written program generator can produce an equipment-specific procedure in about 15 minutes.

Keep the written procedures readily accessible to employees. OSHA doesn't require them to be laminated and bolted to the forklift (though that's common practice and genuinely useful), but employees have to be able to get them without hunting.

Who is allowed to perform lockout tagout on a forklift?

OSHA draws a clear line between three categories of people.

An authorized employee is the person who actually performs the LOTO. This is the mechanic, technician, or operator who locks out the forklift and does the service work. They must be trained specifically on the energy sources and the procedures for the equipment they'll be locking out ^[1].

An affected employee is an operator or other worker who uses the equipment or works in the area where LOTO is happening. They must be trained to understand the purpose of LOTO and to never attempt to restart or re-energize locked-out equipment.

An other employee is anyone else in the area who might come across the locked-out machine. They need awareness-level training: know what a lockout device looks like, and know not to touch it.

Training has to be specific, not generic. OSHA requires that each authorized employee be trained in the "recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control" ^[1]. A 10-minute video about lockout tagout in general does not satisfy that requirement for a forklift technician who'll be working on 80-volt battery packs.

Retraining is required whenever there's reason to believe the employee isn't following the procedures, or when equipment or procedures change. Document the training. OSHA doesn't specify a format, but in an inspection you need to prove who was trained, on what, and when.

See our forklift certification guide for related operator training requirements, which are separate from LOTO training.

What are the most common OSHA violations for forklift LOTO?

Control of Hazardous Energy (1910.147) has landed in OSHA's top 10 most-cited standards almost every year for decades. In fiscal year 2023, it ranked fifth, with over 2,500 violations cited ^[4]. Forklifts generate a big share of those.

The violations that show up most in forklift operations:

No written procedures (1910.147(c)(4)(ii)). This is the single most common forklift LOTO citation. Inspectors ask to see the equipment-specific procedure. Hand them a generic lockout form and you can expect a citation.

Inadequate training documentation (1910.147(c)(7)). Training records are either missing or show only that an operator watched a general safety video. Nothing equipment-specific on paper.

Failure to verify de-energization (1910.147(d)(6)). Workers lock out the battery but never try the controls to confirm the machine is truly dead. This step is easy to skip under time pressure and easy for inspectors to catch through interviews.

Using tagout alone when lockout is feasible (1910.147(c)(3)). Tagout-only programs on equipment where a lockout device clearly could be applied. Battery connectors on electric forklifts are built to accept a lock. There's no excuse for tagout-only on most modern forklifts.

Failure to control all energy sources. Locking out the battery but leaving the propane tank valve open on an LP forklift, or skipping the fork-lowering step before disconnecting power.

OSHA can issue serious violations at up to $15,625 per violation, and willful or repeated violations go up to $156,259 each ^[5]. A single inspection of a forklift fleet can produce multiple violations across multiple units, and those stack.

For context on how OSHA inspections work and what to expect, our OSHA basics overview covers the inspection process.

Does forklift LOTO apply to battery charging and tire changes?

Yes to tire changes. It's more nuanced for battery charging.

Tire changes are unambiguously covered. Changing a forklift tire, especially on pneumatic-tire models, means working under the forklift. The machine has to be locked out and physically supported (rated jack stands, more than a floor jack) before anyone gets under it. The gravitational energy from the machine's weight plus stored hydraulic pressure makes this one of the higher-risk forklift maintenance tasks.

Battery charging on electric forklifts sits in a gray zone. Routine battery swaps done by trained operators, where the operator disconnects the dead battery and connects a charged one without performing any service on the forklift itself, are generally treated as normal operation, not "servicing or maintenance" under 1910.147. OSHA's standard defines "servicing and maintenance" to include lubrication, cleaning, unjamming, and adjusting, but routine battery exchange that operators do as part of normal operations is typically handled under 1910.178, the powered industrial truck standard, rather than 1910.147 ^[7].

But if a technician is working on the charging system, replacing battery cells, or opening the battery compartment for repairs, that's maintenance, and LOTO applies.

The honest answer: if you're unsure whether a task crosses the line from "operation" to "maintenance," ask whether an unexpected startup or energy release during the task could injure the employee. If yes, do LOTO. That's the test the standard actually uses.

OSHA has addressed this in letters of interpretation over the years. The relevant guidance is that the "normal production operations" exclusion in 1910.147(a)(2)(ii) is narrow and doesn't cover most forklift maintenance tasks ^[1].

How does group lockout work when multiple technicians service the same forklift?

When more than one authorized employee works on the same locked-out forklift at the same time, each person applies their own personal lock. That's the group lockout requirement under 1910.147(f)(3) ^[1].

The mechanics usually work like this: a lockout coordinator (often the lead technician) isolates the energy and applies a group lockout hasp to the battery connector or disconnect switch. Each technician on the job then adds their own personal padlock to that hasp. The forklift can't be re-energized until every lock comes off, which means every technician has finished and pulled their own lock.

Hasps that accept six or more locks are common for group LOTO. Some operations use a lockout box: the key to the isolated energy source goes into a lockbox, and each technician puts a personal lock on the box.

Shift transfers require a formal handoff. If maintenance starts on one shift and continues on the next, the outgoing technician and the incoming technician physically exchange the lockout. The outgoing tech can't simply leave their lock on and tell the next person it's locked out. 29 CFR 1910.147(f)(4) covers shift or personnel changes and requires that "continuity of lockout or tagout protection" be maintained ^[1].

Contractors are a common problem area. When outside service techs come in to work on your forklifts, your LOTO program has to address them. 1910.147(f)(2) requires the on-site employer and the outside employer to inform each other of their LOTO procedures and make sure employees understand and comply with the restrictions ^[1].

What equipment and devices do you need for forklift LOTO?

You don't need much hardware, but what you buy has to be right.

For electric forklifts, the key device is a battery connector lockout. Most electric forklifts use a multi-pin SB (sometimes called "SB50" or "SB350") or Anderson-style connector between the battery and the truck. Connector-specific lockout devices come from safety suppliers (Brady, Master Lock, and others make them) and cost roughly $15 to $40 each. If the forklift has a key-type battery disconnect switch instead of a plug connector, a circuit breaker lockout or cable lockout works.

For LP forklifts, a valve lockout device that fits over the propane tank valve handle is required. These run $10 to $25.

Every authorized employee needs three things: their own keyed-different padlock (nobody shares a key), a durable standardized LOTO tag attached to that lock, and access to the equipment-specific written procedure.

OSHA's standard says lockout devices must be "durable, standardized, substantial and identifiable" ^[8]. Durable means they hold up in the environment (a forklift shop is not a clean-room). Standardized means they match a consistent color, shape, or size across your program. Identifiable means each lock traces back to the specific employee who applied it.

One thing to skip: the temptation to buy one "universal" LOTO kit and share locks from it. Shared locks defeat the purpose of individual lockout. Every authorized employee gets their own lock that only they hold the key to.

A basic per-employee LOTO kit (one padlock, one hasp, tags, and a procedure card) runs about $30 to $60. For a fleet of five forklifts with three technicians, you're looking at under $300 in hardware. The cost of a single OSHA citation dwarfs that many times over.

How often do you need to audit and update your forklift LOTO program?

29 CFR 1910.147(c)(6) requires a periodic review of the energy control program at least annually ^[10]. The audit has to be done by an authorized employee other than the one using the procedure being reviewed. The point is to confirm that the written procedure matches the actual steps taken and that employees understand those steps.

The audit has to be documented. You need records showing the date of the audit, the machine(s) reviewed, the employees involved, and the name of the person who ran it. OSHA inspectors ask for these records.

Update procedures when equipment changes. Replace an electric forklift with a new model that has a different battery connector location or a different disconnect design, and the written procedure needs a revision before the first technician uses it. Same goes for adding a new fuel type to your fleet.

Many small operations tie the annual LOTO audit to their annual safety program review. That works fine, as long as it actually happens and gets documented. Building the audit into the maintenance calendar ("first week of January, audit LOTO procedures") beats treating it as a floating task.

For broader program documentation and how it fits into your overall written safety program, our OSHA training article covers what records you need and how long to keep them.

What happens if a forklift operator (not a technician) needs to clear a jam or adjust a load?

This is one of the most-asked questions in forklift LOTO, and the answer isn't simple.

OSHA's standard includes a limited exception in 1910.147(a)(2)(ii) for "minor tool changes and adjustments, and other minor servicing activities" that happen during normal production operations, if they are routine, repetitive, and integral to production, and if the employer provides alternative measures that give equivalent protection ^[1].

The key word is "equivalent." Turning the ignition off and removing the key before reaching under the carriage to free a jammed pallet beats nothing. But it does not lock out hydraulic energy. It does not stop someone else from walking up and restarting the truck. OSHA's position, stated in multiple letters of interpretation, is that key removal alone does not satisfy the alternative protection requirement for most forklift jam-clearing tasks ^[1].

The practical guidance: if the operator has to put any part of their body into a zone where a moving forklift component (mast, carriage, tines) could catch them, that task is not minor servicing, and full LOTO applies. Picking up a dropped item from the floor next to the forks is not servicing. Reaching between the tines to free something is.

Some operations solve this with a defined procedure for "operator jam clearing" that keeps the operator outside the pinch-point zone entirely. If the task can't be done from outside the hazard zone, it's a maintenance task, and a technician needs to do it under full LOTO.

When an incident does happen during a jam-clearing event, you'll need to file an incident report. The OSHA recordkeeping rules treat those separately from ordinary injuries.

What should a small business do to get a forklift LOTO program in place quickly?

If you don't have a program yet, here's the honest shortest path.

Start with your equipment list. Write down every forklift you have: make, model, serial number, and power type. That list drives everything else.

For each unit, write an equipment-specific LOTO procedure. Take photographs of the battery connector, the disconnect switch, the propane valve, wherever the isolation point actually sits on that specific machine. The procedure doesn't need to be long. A one-page document with photographs, a numbered step list, and the energy types covered is plenty.

Buy hardware. Each authorized employee needs their own padlock with a unique key. Buy connector-specific lockout devices for each forklift type. For most small operations, the total hardware cost stays under $200.

Train your people. Authorized employees need equipment-specific training. Document it. Have them sign a training record. Affected employees (operators who don't do maintenance) need awareness-level training. Document that too.

Conduct your first audit. Once the program is running, do the 1910.147(c)(6) annual audit within the first year. Treat the first audit as a chance to catch gaps, not a box to check.

If writing the procedures from scratch feels like a wall, SafetyFolio's program generator walks you through the equipment-specific questions and produces a ready-to-use written LOTO procedure in about 15 minutes.

The whole thing, hardware plus written program plus first training session, is realistically a one-day project for a small operation with fewer than five forklifts. There's no reason to pay a safety consultant thousands of dollars for what is fundamentally a documentation and training task.

Frequently asked questions

Does OSHA require lockout tagout for forklifts?

Yes. OSHA 29 CFR 1910.147, the Control of Hazardous Energy standard, applies to forklifts because they hold multiple energy sources (electrical, hydraulic, gravitational, chemical) that can cause injury during service or maintenance. The standard requires written equipment-specific procedures, trained authorized employees, personal lockout devices, and verified de-energization before any maintenance work begins.

Can I use tagout only instead of lockout on a forklift?

Almost never. Tagout-only is allowed under 1910.147 only when the equipment cannot be locked out, meaning it has no isolation point that can accept a lockout device. Most modern forklifts have battery connectors or disconnect switches that accept lockout hasps. If a lockout device can physically go on, you must use it. Tagout-only on equipment that can be locked out is a citable violation.

What lockout devices do I need for an electric forklift?

You need a battery connector lockout device sized for the specific connector on your forklift (SB50, SB175, SB350, or Anderson-style are common) and a personal padlock keyed only to the authorized employee. Hasps for group lockout are needed when more than one technician works on the same unit. Total hardware cost per authorized employee runs roughly $30 to $60.

Do forklift operators need lockout tagout training?

Yes, but the level differs. Operators who perform service or maintenance (authorized employees) need full equipment-specific LOTO training covering all energy sources and the written procedure. Operators who only drive the forklift (affected employees) need awareness-level training: understanding what LOTO is, why locked-out equipment must never be restarted, and what lockout devices look like. Both levels must be documented.

How do you lockout tagout a propane forklift?

Shut down the engine using the normal stopping procedure. Lower the forks fully to the ground. Close the propane tank valve, then apply a valve lockout device over the handle and secure it with your personal padlock. Cycle the engine starter once to confirm it won't start and to relieve residual fuel pressure in the lines. Apply your LOTO tag. For hydraulic work, also cycle the lift controls to bleed residual pressure.

What is the OSHA penalty for failing to have a forklift LOTO program?

Serious violations under 1910.147 carry penalties up to $15,625 per violation as of 2024. Willful or repeated violations go up to $156,259 each. A single inspection of a multi-forklift operation can produce several violations (no written procedure, no training records, inadequate devices) that stack. Total penalties from one inspection routinely reach five figures for small businesses without documented programs.

Does lowering the forks and turning the key off count as lockout tagout?

No. Lowering the forks is a required step in the LOTO process because it eliminates the gravitational and hydraulic energy hazard, but it is not a substitute for isolating the electrical or fuel energy source and applying a physical lockout device with a personal padlock. Removing the key alone does not lock out the battery on an electric forklift or the fuel system on a propane unit.

How often do forklift LOTO procedures need to be reviewed?

At least once per year, per 29 CFR 1910.147(c)(6). The review must be conducted by an authorized employee other than the one using the procedure, and it must be documented with the date, the machine reviewed, and the names of employees involved. Procedures also need updating whenever equipment changes or when an incident reveals a gap.

Who can remove a lockout device from a forklift?

Only the authorized employee who applied the lock. Under 1910.147(e)(3), if that employee is unavailable, a specific emergency removal procedure can be used, but it requires supervisor authorization, documented verification that the absent employee is not in the machine's hazard zone, and notification to the employee before they return to work. A supervisor removing a worker's lock without following this procedure is a serious violation.

Is forklift battery charging considered a lockout tagout situation?

Routine battery swapping by trained operators, as part of normal operations, is generally considered operation rather than maintenance under 1910.147. Full LOTO is required any time a technician services the battery, charging system, or battery compartment. The line is whether unexpected energization during the task could injure the employee. When in doubt, apply LOTO. OSHA's letters of interpretation confirm the normal-operations exception is narrow.

What records do I need to keep for forklift LOTO compliance?

You need written equipment-specific LOTO procedures for each forklift type, training records showing who was trained, what they were trained on, and when, plus documentation of the annual program audit including date, equipment reviewed, and employees involved. OSHA does not specify a retention period in 1910.147, but general practice is to keep training records for the duration of employment plus three years.

Does forklift LOTO apply to tire changes?

Yes. Changing a forklift tire requires working in or near the equipment's hazard zone and involves the forklift being raised off the ground. Full LOTO is required before any technician gets under or immediately next to the machine. The forklift must also be physically supported by rated jack stands, more than a floor jack, because jacks can fail and the stored energy of the machine's weight must be controlled.

Can a forklift operator clear a jammed pallet without doing full lockout tagout?

Only if the task truly keeps the operator entirely outside the machine's pinch-point and crush zones, and the employer has a documented alternative protection procedure. OSHA's minor-servicing exception is narrow. Any task that requires reaching between the tines, under the carriage, or into the mast area is not minor servicing and requires full LOTO by a trained authorized employee. When in doubt, treat it as maintenance.

Sources

1. OSHA, 29 CFR 1910.147 Control of Hazardous Energy (Lockout/Tagout): OSHA requires written energy control procedures, trained authorized employees, and verified de-energization before servicing or maintenance on equipment where unexpected startup or energy release could cause injury
2. OSHA, Control of Hazardous Energy (Lockout/Tagout) overview page: OSHA estimates the LOTO standard prevents approximately 120 fatalities and 50,000 injuries annually
3. Bureau of Labor Statistics, Injuries, Illnesses, and Fatalities program: BLS records 80 to 100 forklift-related fatalities per year, with caught-in and struck-by events during maintenance among leading causes
4. OSHA, Top 10 Most Cited Standards: Control of Hazardous Energy (1910.147) ranked fifth in OSHA's most-cited standards in fiscal year 2023 with over 2,500 violations
5. OSHA, Penalties: Serious OSHA violations carry penalties up to $15,625 per violation; willful or repeated violations up to $156,259 each
6. OSHA, 29 CFR 1910.178 Powered Industrial Trucks: 1910.178 governs forklift operator safety and training, including battery charging procedures, as distinct from 1910.147 servicing requirements
7. OSHA, Publication 3120 Control of Hazardous Energy (Lockout/Tagout): Lockout devices must be durable, standardized, substantial and identifiable; each authorized employee must have their own personal lock
8. NIOSH, Powered Industrial Trucks / Forklift Safety topic page: Forklifts are involved in tens of thousands of serious workplace injuries and roughly 85 fatal accidents in U.S. workplaces annually, according to NIOSH
9. OSHA, 29 CFR 1910.147(c)(6) Periodic inspections of energy control procedures: 1910.147(c)(6) requires at least annual documented review of energy control procedures, conducted by an authorized employee other than the one using the procedure