Lockout/Tagout Procedures: The Complete OSHA Compliance Guide

Understanding OSHA's Lockout/Tagout Standard

The Control of Hazardous Energy standard — commonly known as Lockout/Tagout or LOTO — is one of OSHA's most critical safety regulations. Codified under 29 CFR 1910.147, this standard addresses the practices and procedures necessary to disable machinery or equipment during servicing and maintenance, preventing unexpected startup or release of stored energy that could cause injury.

Failure to properly control hazardous energy accounts for an estimated 120 fatalities and 50,000 injuries per year in the United States. LOTO violations consistently rank among OSHA's top 10 most-cited standards.

Types of Hazardous Energy

Your lockout/tagout program must address all forms of hazardous energy present in your operations:

• Electrical — Power supply to motors, circuits, lighting systems
• Mechanical — Moving parts, gears, belts, conveyor systems
• Hydraulic — Pressurized fluid systems in presses, lifts, and cylinders
• Pneumatic — Compressed air systems and tools
• Chemical — Stored chemicals in pipelines and vessels
• Thermal — Steam systems, heat exchangers, hot surfaces
• Potential (gravitational) — Elevated components, springs, suspended loads

Key Components of a LOTO Program

Written Energy Control Procedures

OSHA requires documented procedures for controlling hazardous energy. These procedures must be developed for each specific piece of equipment or machinery and must include:

1. Intended use of the procedure
2. Steps for shutting down and isolating the machine
3. Steps for applying lockout/tagout devices
4. Steps for verifying isolation — The most critical step. Workers must verify that the machine is truly de-energized before beginning work.
5. Steps for releasing the machine from lockout/tagout

Authorized vs. Affected Employees

OSHA defines two key employee categories in LOTO operations:

• Authorized employees — Workers who lock out or tag out machines in order to perform servicing or maintenance. They attach their own personal lock and are the only ones who may remove it.
• Affected employees — Workers whose jobs require them to operate or work in an area where servicing is being performed. They must be notified before LOTO is applied and before the machine is returned to service.

Lockout/Tagout Devices

Devices used for energy isolation must be:

• Durable — Capable of withstanding the environment
• Standardized — Consistent in color, shape, or size across the workplace
• Substantial — Not easily removable without excessive force (locks, not twist-ties)
• Identifiable — Clearly showing who applied the device

The 6-Step LOTO Procedure

1. Preparation — Identify all energy sources, notify affected employees, gather lockout devices
2. Shutdown — Turn off the machine using normal operating controls
3. Isolation — Operate the disconnect switch, close valves, block movable parts
4. Apply LOTO devices — Each authorized employee applies their personal lock to the energy isolation device
5. Verify isolation — Attempt to restart the machine to confirm it's de-energized. Release any stored energy. This is the most important step.
6. Perform the work — With energy isolated and verified, servicing can begin safely

Periodic Inspections

OSHA requires that energy control procedures be inspected at least annually to ensure they remain effective. The inspection must:

• Be performed by an authorized employee other than the ones using the procedure being inspected
• Include a review between the inspector and authorized employees
• Correct any deviations or inadequacies identified
• Be documented with the date, equipment inspected, employees included, and the person performing the inspection

Common LOTO Violations

Based on OSHA citation data, the most frequent LOTO violations include:

• Failing to develop machine-specific energy control procedures
• Not conducting annual periodic inspections
• Inadequate training for authorized and affected employees
• Using tags without locks when lockout is feasible
• Not verifying energy isolation before beginning work
• Allowing one worker to remove another's lock without proper procedures

A comprehensive LOTO program template addresses all of these requirements and provides machine-specific procedure forms. For related compliance needs, see our confined space entry guide and safety inspection checklists.