A compliant LOTO program requires written machine-specific procedures, trained authorized and affected employees, annual periodic inspections, and certified documentation — here is what each obligation demands.
What the OSHA Lockout/Tagout Standard Actually Requires
The federal standard is 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout). It applies to servicing and maintenance of machines and equipment where unexpected energization, startup, or release of stored energy could injure an employee.
The standard covers every energy type — electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and other energy — including stored or residual energy such as energy held in capacitors, springs, elevated machine members, hydraulic accumulators, and rotating flywheels. If your crews service or maintain equipment, this standard applies to you.
> Scope note: 29 CFR 1910.147 is a general-industry standard. Construction-specific LOTO obligations come from equipment-specific 29 CFR 1926 standards and the General Duty Clause. Confirm which standards govern your specific work before assigning training.
Requirement 1: A Written Energy Control Program
You must establish, document, and enforce an energy control program. The written program must cover the scope, purpose, authorization rules, and techniques your crews will use to control hazardous energy.
This is not a one-page policy statement. The written program is the parent document that ties together your machine-specific procedures, hardware standards, training records, and inspection certifications.
Requirement 2: Machine-Specific Written Procedures
For every covered machine, you need a written procedure — unless all eight narrow conditions in 29 CFR 1910.147(c)(4)(ii) are met simultaneously. Those conditions include a single readily identifiable energy source, no stored or residual energy, and no prior incidents of unexpected activation. If even one condition is not met, a written procedure is mandatory.
In practice, the exception rarely applies to real construction or manufacturing equipment. Treat it as the exception it is, not the rule.
What each machine-specific procedure must contain
Per 29 CFR 1910.147(c)(4)(ii), each procedure must include:
- A specific statement of the intended use of the procedure
- Step-by-step instructions for shutting down, isolating, blocking, and securing the machine
- Steps for placement, removal, and transfer of lockout or tagout devices, and who is responsible
- Requirements for testing the machine to verify the zero-energy state
Generic language that restates the standard without naming the machine, listing every energy isolating device, and specifying the exact isolation sequence is a top citation driver. Each procedure must be written for one specific piece of equipment.
Requirement 3: Standardized, Employer-Provided Hardware
You are required to provide locks, tags, chains, hasps, and other isolation hardware. You cannot ask workers to supply their own.
Per 29 CFR 1910.147(c)(5)(ii), all lockout and tagout devices must be standardized within the facility by at least one of the following: color, shape, or size. Tagout devices must also be standardized by print and format.
Additional hardware requirements:
- Locks must be substantial enough to prevent removal without excessive force or unusual techniques such as bolt cutters
- Locks must identify the individual who applied them
- Tag attachment means must be non-reusable, self-locking, non-releasable, and rated for a minimum unlocking strength of no less than 50 pounds
- Tags must carry a legend such as "Do Not Start," "Do Not Energize," or "Do Not Operate"
- Lockout and tagout devices must be used exclusively for energy isolation — not for toolboxes, lockers, or gates
Requirement 4: Training for Every Employee Role
The standard creates three distinct training tiers, and each carries different content requirements.
Authorized employees
Per 29 CFR 1910.147(c)(7)(i), authorized employees — those who apply and remove locks or tags — must 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.
Affected employees
Per 29 CFR 1910.147(c)(7)(ii), affected employees — those who operate machines being serviced, or who work in areas where LOTO is in use — must be trained in the purpose and use of the energy control procedure. This training does not authorize them to apply or remove devices.
Other employees
Per 29 CFR 1910.147(c)(7)(iii), any other employee whose work may bring them into an area where energy control procedures are used must be instructed about the procedure and the prohibition against attempting to restart or reenergize locked-out or tagged-out equipment.
Retraining triggers
Retrain when there is a change in job assignment, a change in machines or processes that presents a new hazard, a change in energy control procedures, or whenever a periodic inspection reveals deviations or inadequacies in an employee's knowledge.
Requirement 5: The Six-Step Application Sequence
Per 29 CFR 1910.147(d), authorized employees must follow a mandatory sequence every time they apply energy controls. The steps cannot be abbreviated or reordered.
1. Notify affected employees before applying lockout or tagout devices, per 29 CFR 1910.147(c)(9) 2. Know the energy — identify the type, magnitude, and control method for every energy source on the machine before shutdown, per 29 CFR 1910.147(d)(1) 3. Shut down the machine using an orderly shutdown that avoids creating additional hazards, per 29 CFR 1910.147(d)(2) 4. Isolate every energy source by operating all energy isolating devices — disconnect switches, line valves, blocks — to their safe or off position, per 29 CFR 1910.147(d)(3) 5. Apply lockout or tagout devices to each energy isolating device, per 29 CFR 1910.147(d)(4) 6. Release or restrain stored energy — bleed down pneumatic and hydraulic lines, discharge capacitors, block elevated parts, restrain springs — then verify the zero-energy state by attempting to operate the machine using normal controls, per 29 CFR 1910.147(d)(6) and (d)(7)
Push buttons, selector switches, and other control-circuit devices are not energy isolating devices under 29 CFR 1910.147(b). Locking out a control circuit is not lockout.
Requirement 6: Group Lockout Protects Every Worker Individually
When a crew works on the same equipment, a single supervisor lock covering the whole group violates 29 CFR 1910.147(f)(3)(ii). Every authorized employee must attach their own personal lock to the group hasp or lockbox and retain personal custody of their own key.
Per 29 CFR 1910.147(f)(3)(ii)(A), primary responsibility must be vested in one authorized employee for coordinating the group. When multiple crews are involved, per 29 CFR 1910.147(f)(3)(ii)(C), an authorized employee must be designated to coordinate all work forces and ensure continuity of protection.
Shift changes
Per 29 CFR 1910.147(f)(4), protection must transfer without any unprotected gap. Incoming authorized employees apply their locks before outgoing employees remove theirs. A transition lock is the standard mechanism for maintaining continuity during the swap.
Requirement 7: Tagout-Only Programs Require Additional Safeguards
Lockout is the preferred method. Per 29 CFR 1910.147(c)(2), if your program relies on tagout devices instead of locks, you must supplement every tag with at least one additional safety measure that provides protection equivalent to lockout.
A tag is a warning device. It does not physically restrain energy. Relying on a tag alone is a serious citation.
Requirement 8: Annual Periodic Inspection of Every Procedure
Per 29 CFR 1910.147(c)(6)(i), you must inspect each energy control procedure at least once every 12 months. The inspection must be conducted by an authorized employee other than the one who uses the procedure being inspected — self-inspection is not permitted.
For lockout procedures, the inspection must include a one-on-one review with each authorized employee of their responsibilities under that procedure.
For tagout procedures, the review must include both authorized employees and affected employees.
What you must certify
Per 29 CFR 1910.147(c)(6)(ii), you must produce a written certification for every inspection that records:
- The machine or equipment inspected
- The date of the inspection
- The employees included in the inspection
- The name of the person who conducted the inspection
Signing off without actually observing lockout steps being performed — pencil-whipping the form — is a widespread compliance failure that OSHA enforcement officers detect by interviewing workers and cross-checking inspection dates. Deficiencies found during the inspection must be corrected and documented before the inspection is considered complete.
Requirement 9: Emergency Lock Removal and Contractor Coordination Procedures
Emergency lock removal
Per 29 CFR 1910.147(e)(3), only the authorized employee who applied a lock or tag may remove it. The one documented exception — removal when the applier is unavailable — requires a written procedure developed, documented, and incorporated into your energy control program before any emergency occurs. Verbal authorization is not enough. Before removing the device, you must verify the employee is not on-site and make all reasonable efforts to notify them.
Contractor coordination
Per 29 CFR 1910.147(f)(2), when outside contractors perform work covered by the standard on your site, both you and the contractor must inform each other of your respective energy control procedures. Your employees must understand and comply with the contractor's restrictions, and the contractor's employees must comply with yours. Document this exchange. Mismatched lock colors or styles between host and contractor crews are a recurring near-miss source — group lockboxes are the standard field solution.
What Happens When You Get This Wrong
Lockout/Tagout is consistently one of OSHA's most-cited standards. The most common violations are:
- Machine-specific procedures that are missing or generic
- Push buttons or selector switches used as energy isolating devices
- Authorized employees skipping the stored-energy dissipation and verification steps
- Supervisor locks substituted for individual worker locks on group jobs
- Annual periodic inspections that are signed off without live observation
- No written procedure for emergency lock removal
Each violation can carry a serious citation and penalty — and more importantly, each has a direct path to an amputation or fatality.
Jobsite's Lockout/Tagout training suite covers all three employee roles — authorized, affected, and other — with role-specific courses mapped to 29 CFR 1910.147. Assign the right course to the right worker and track completion from one dashboard.
FAQ
Does 29 CFR 1910.147 apply to my construction crews?
No — 29 CFR 1910.147 is a general-industry standard and does not directly apply to construction work. Construction LOTO obligations come from equipment-specific standards under 29 CFR 1926 and the General Duty Clause. Confirm which standards govern your specific operations before assigning this training to construction-only crews.
What is the difference between an authorized employee and an affected employee under LOTO?
An authorized employee is trained to apply and remove lockout or tagout devices and perform the energy control procedure. An affected employee operates or uses equipment being serviced, or works in an area where LOTO is in use, but does not apply or remove devices. The classification is task-based, not job-title-based — a worker can be authorized on one task and affected on another. Only authorized employees may apply or remove locks and tags.
Can a supervisor remove a worker's lock if that worker is unavailable?
Only under a very specific documented process. Per 29 CFR 1910.147(e)(3), the lock may be removed under the employer's direction only if specific procedures and training for such removal have been developed, documented, and incorporated into the written energy control program before the situation arises. You must first verify the employee is not on-site and make all reasonable efforts to notify them. Verbal authorization from a supervisor is not sufficient.
How often must energy control procedures be inspected?
At least once every 12 months per 29 CFR 1910.147(c)(6)(i). The inspection must be performed by an authorized employee other than the one who uses the procedure being reviewed. You must produce a written certification recording the machine, the date, the employees included, and the inspector's name. Signing off without observing the procedure being performed does not satisfy the requirement.
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About the author
The Jobsite Editorial Team — Construction safety & OSHA compliance
The Jobsite Editorial Team writes the safety and compliance library behind Jobsite, the construction safety, OSHA compliance, and training platform for contractors. Every article starts from the primary regulatory text — the CFR section itself, not a summary of it — and is fact-checked against that source before it publishes, so what you read here is what the standard actually requires of small and mid-size contractors in the field.