Federal OSHA construction lockout/tagout rules live in 29 CFR 1926.417, but many contractors adopt the 1910.147 framework to train authorized, affected, and other workers on every energy source.
Does OSHA's lockout/tagout standard apply to construction sites?
No. 29 CFR 1910.147, the Control of Hazardous Energy standard, explicitly excludes construction employment under 1910.147(a)(1)(ii)(A). On a construction site, the enforceable federal lockout and tagging duty comes from 29 CFR 1926.417 and Subpart K, plus equipment-specific standards.
Under 1926.417, controls to be deactivated must be tagged, deenergized equipment or circuits must be rendered inoperative with tags attached at all points where they can be energized, and tags must plainly identify the equipment or circuits being worked on. Because the construction standard is narrower, many contractors voluntarily adopt the 1910.147 framework as their own internal program. That approach gives you a defensible structure for training authorized employees, affected employees, and other workers.
Who on your crew needs lockout/tagout training?
Anyone who could be exposed to unexpected energization, startup, or release of stored energy. If you model your program on 1910.147, training breaks down by task, not job title. A worker can be authorized on one task and affected on another.
| Role | What they do | What training must cover |
|---|---|---|
| Authorized employee | Applies or removes lockout/tagout devices; performs servicing or maintenance | Recognition of hazardous energy sources; type and magnitude of energy; methods and means for energy isolation and control (29 CFR 1910.147(c)(7)(i)) |
| Affected employee | Operates or uses equipment being serviced, or works in the area where servicing occurs | Purpose and use of the energy control procedure (29 CFR 1910.147(c)(7)(i)(B)) |
| Other employee | Works in an area where energy control procedures are used | The procedure and the prohibition on attempting to restart or reenergize locked out or tagged out equipment (29 CFR 1910.147(c)(7)(i)(C)) |
Only authorized employees may apply or remove devices. An affected employee becomes authorized only when that employee's duties include performing servicing or maintenance covered under the program.
What must the training cover?
The content depends on the worker's role, but every program must address the specific energy sources and isolation devices present on your equipment.
Authorized employees need the deepest training. Under 1910.147(c)(7)(i), they must be able to recognize applicable hazardous energy sources, understand the type and magnitude of the energy available, and know the methods and means necessary for energy isolation and control. That includes identifying energy isolating devices—manually operated circuit breakers, disconnect switches, line valves, and blocks—and understanding that push buttons, selector switches, and E-stops are not energy isolating devices.
Affected employees must understand the purpose and use of your energy control procedure. They do not need the same technical depth as authorized employees, but they must know how to recognize lockout/tagout devices and understand that they are prohibited from removing or bypassing them.
Other employees need only awareness-level instruction. They must know that the procedure is in place and that they must not restart or reenergize equipment that is locked out or tagged out.
If your program uses tagout instead of lockout on equipment capable of being locked out, you must demonstrate that your tagout program provides a level of safety equivalent to lockout. That means additional measures such as removing an isolating circuit element, blocking a controlling switch, opening an extra disconnecting device, or removing a valve handle. A tag alone is a warning, not energy isolation.
How often is retraining required?
There is no fixed federal calendar interval for LOTO retraining in the benchmark standard, so most contractors use condition-based triggers.
Under the 1910.147 framework that many construction programs follow, retraining is required whenever there is a change in job assignments, a change in machines or equipment or processes that presents a new hazard, a change in energy control procedures, or whenever a periodic inspection reveals deviations or inadequacies in the employee's knowledge. The standard does not set a fixed annual retraining cadence.
Many employers default to a 12-month training cycle to stay ahead of turnover and drift. Separately, if you adopt the 1910.147 model, you must conduct an annual periodic inspection of your energy control procedures under 1910.147(c)(6)(i). This inspection is not the same as retraining, but it often reveals gaps that trigger retraining.
What records should you keep?
You need written procedures and inspection certifications that hold up during an audit.
If your program follows the 1910.147 structure, you must maintain machine-specific written energy control procedures under 1910.147(c)(4). Generic, plant-wide procedures are a top citation driver; each procedure must name the machine, list every energy isolating device, and give step-by-step instructions for shutdown, isolation, stored-energy dissipation, and verification.
For the annual periodic inspection, 1910.147(c)(6)(ii) requires a certification that records the machine or equipment inspected, the date, the employees included in the inspection, and the person performing the inspection. The inspector must be an authorized employee who is not using the procedure being inspected.
Your written program should also clearly designate which workers are authorized employees and which are affected employees. Role creep—an affected worker performing authorized tasks without proper training—is a frequently cited violation.
What are the most common compliance mistakes to avoid?
Never treat a control switch as an energy isolating device. Push buttons, selector switches, and PLC inputs do not physically block energy transmission. Using them as your only isolation method leaves the employer exposed to a serious citation.
In group lockout situations, a single supervisor lock covering an entire crew violates 1910.147(f)(3)(ii). Each authorized employee must attach their own personal lock to the group lockbox or hasp and keep personal custody of the key.
Only the authorized employee who applied a lock may remove it. The single exception—removal under employer direction when the applier is unavailable—requires documented procedures in your written energy control program. Verbal authorization is not enough.
Finally, notify affected employees before applying lockout or tagout and after removing it. Missing communication leads to restart attempts while service work is still underway.
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FAQ
Can an affected worker remove a lock if the authorized employee left the site?
No. Only the authorized employee who applied the lock may remove it. The single exception is removal under employer direction when the applier is unavailable, and that requires documented procedures in your written energy control program. Verbal authorization is not enough.
Is tagout acceptable if a lock cannot be applied?
Tagout-only programs are permitted only if you can demonstrate a level of safety equivalent to lockout. That requires additional safety measures such as removing an isolating circuit element, blocking a controlling switch, opening an extra disconnecting device, or removing a valve handle. A tag alone is a warning, not energy isolation.
Does 29 CFR 1910.147 apply to construction crews?
No. 1910.147 is a general industry standard that explicitly excludes construction under 1910.147(a)(1)(ii)(A). Construction LOTO obligations come from 29 CFR 1926.417 and Subpart K, plus equipment-specific 1926 standards. Many contractors voluntarily adopt the 1910.147 framework as best practice.
What is the difference between the annual inspection and retraining?
The annual periodic inspection of energy control procedures under 1910.147(c)(6) is a separate obligation from training. It must be performed by an authorized employee not using the procedure being inspected, and it must be certified in writing identifying the machine, date, employees, and inspector. Retraining is triggered by changes or deficiencies, not by the calendar alone.
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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.