Lockout/tagout is the #1 cited standard in general industry — year after year. 1910.147 requires more than just locks on the switch. It requires a written program, machine-specific procedures, authorized worker training documentation, and an annual periodic inspection.
Most LOTO citations aren't about someone being electrocuted. They're about paperwork inspectors ask for that isn't there — the written program, the machine-specific procedures, the training records, the annual inspection.
What OSHA Actually Requires
1910.147 requires three separate documented elements:
- Written LOTO program — the overall procedure your facility uses
- Machine-specific procedures — one for every piece of equipment with energy that could hurt someone
- Authorized worker training — with signatures, dates, and topic covered
Then annually, you need documentation of the periodic inspection — a review of each machine-specific procedure by an authorized worker other than the one who normally performs the LOTO on that machine.
Machine-Specific Procedures — The Part Most Contractors Skip
The generic "energy sources are locked out" language isn't compliant. Each machine needs its own procedure specifying:
- Equipment identification (make, model, location)
- Energy source types (electrical, hydraulic, pneumatic, mechanical, gravitational, thermal, chemical)
- Isolation points — where locks and tags actually go
- Verification steps — how to confirm energy is isolated
- Release of stored energy — capacitors, springs, hydraulic pressure, gravity
- Restart procedure
What's In The Forbes LOTO Program Pack
- Written LOTO program — customizable to your facility
- Machine-specific procedure template — fill in per equipment
- Authorized worker training record — with signatures and dates
- Affected worker awareness training log
- Annual periodic inspection form
- Group LOTO procedure — for maintenance requiring multiple workers
- Contractor LOTO coordination form
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Frequently Asked Questions
What does OSHA 1910.147 require in a LOTO program?
OSHA 1910.147 requires (1) a written LOTO program covering scope, purpose, and rules, (2) machine-specific procedures for equipment with hazardous energy, (3) authorized worker training with documentation, (4) affected worker awareness training, and (5) annual periodic inspection. Missing any one of these is a citation.
Do I need machine-specific procedures if my LOTO is simple?
OSHA has an exception under 1910.147(c)(4)(i) for machines where the energy source is a single, readily identifiable, easily isolated source (like unplugging a cord). But this applies to a small percentage of equipment. For anything with multiple energy sources, stored energy, or complex isolation, you need machine-specific procedures. When in doubt, write them.
How often does LOTO training need to be refreshed?
Retraining is required whenever there is a change in job assignment, machine, or procedure — or when an inspection reveals deficiencies. There's no mandated annual refresh unless the periodic inspection shows knowledge gaps. But best practice is annual refresh to satisfy periodic inspection requirements simultaneously.
What's an annual periodic inspection?
An annual review of each machine-specific procedure conducted by an authorized worker OTHER than the one who normally performs the LOTO on that machine. The inspector verifies that the procedure is being followed correctly, identifies any deficiencies, and documents the inspection. This is required by 1910.147(c)(6) and is one of the most commonly missed compliance elements.
Do we need LOTO for cord-and-plug equipment?
Cord-and-plug equipment IS exempt from 1910.147 IF the plug is under exclusive control of the worker doing service. If the plug is out of sight (like plugged into an outlet in another room), you need LOTO. Best practice: use plug locks and treat as LOTO.
What's the biggest LOTO citation risk?
Willful citation — 1910.147(c)(4)(ii). If OSHA proves you knew a machine-specific procedure was missing AND you had employees doing service anyway, that's willful. At 2026 rates, that's up to $161,323 per violation, per exposed employee. One machine, five workers = $806,615.