Lockout tagout (LOTO) is the OSHA-required procedure for de-energizing machinery before servicing it, governed by 29 CFR 1910.147. The six steps are: prepare, shut down, isolate every energy source, apply personal locks and tags, release stored energy, and verify zero energy by attempting a restart. Employers must also maintain a written program, machine-specific procedures, documented training, and an annual inspection of each procedure.
I spent 17 years helping blue-collar businesses get through OSHA audits before starting Safety Team Technologies, and lockout/tagout is the standard I worry about most. Not because it's complicated — the six steps fit on an index card. Because the injuries behind LOTO citations are the ones that end careers. Degloved hands. Crushed forearms. A maintenance tech inside a baler when someone hit the start button from around the corner.
Fall protection gets the headlines as OSHA's most-cited standard, but lockout/tagout sits in the top 10 every single year — and it carries a distinction inspectors talk about: LOTO violations are among the most likely to be classified Serious or Willful, because when the procedure fails, someone is almost always inside the machine.
What 29 CFR 1910.147 Actually Requires
The standard — formally 29 CFR 1910.147, The Control of Hazardous Energy — applies to servicing and maintenance of machines where the unexpected startup or release of stored energy could injure someone. That covers far more than electricity. OSHA's definition of hazardous energy includes six types:
| Energy Type | Examples | How It's Isolated |
|---|---|---|
| Electrical | Motors, panels, wiring, capacitors | Disconnect switch locked open; capacitors discharged |
| Mechanical | Flywheels, blades, rotating shafts | Motion stopped and blocked from restarting |
| Hydraulic | Presses, lifts, injection molders | Valves locked closed; pressure bled off |
| Pneumatic | Air-driven tools, cylinders, conveyors | Supply valve locked; lines vented to zero |
| Thermal | Steam lines, ovens, hot surfaces | Source isolated; components cooled before work |
| Gravity | Raised platens, counterweights, suspended loads | Blocks, pins, or cribbing installed |
This table is where most small-shop programs fall apart. Everyone remembers to kill the electrical disconnect. The press that crushes a hand is usually running on the hydraulic pressure or the raised platen nobody blocked — energy that was still in the machine after the power went off.
The 6 Lockout Tagout Procedure Steps
The sequence below is the one OSHA expects to see in your written procedure and the one your authorized employees should be able to recite. The order matters — verification is last for a reason.
- Preparation. Before touching anything, the authorized employee identifies every energy source feeding the equipment — not just the obvious one — and reviews the machine-specific written procedure. If your procedure is a generic photocopy that doesn't name the machine and its isolation points, this step can't happen, and an inspector will notice.
- Notification and shutdown. Tell every affected employee the equipment is coming down for service, then shut it down using its normal stopping procedure. No pulling the disconnect on a machine that's mid-cycle.
- Isolation. Physically isolate every energy source at its isolation point: open the disconnect, close the supply valves, block the lines. Emergency stops and control-circuit buttons do not count — they interrupt the control signal, not the energy.
- Lockout/tagout application. Each authorized worker attaches their own personal lock and their own tag to each isolation point. One lock per person, no exceptions, no borrowed locks. For multi-person jobs, use a group lockout hasp or lockbox so that every worker's lock must come off before anything can be re-energized.
- Stored energy release. Bleed hydraulic and pneumatic pressure to zero. Discharge capacitors. Block or crib anything held up by gravity. Let hot components cool. Spin-down time counts too — a flywheel coasting to a stop is still stored energy.
- Verification. Try the start controls. Press the buttons, cycle the switches, confirm nothing moves and nothing reads live. Then return every control to neutral or off. Only now does maintenance begin. This is the step that catches the mislabeled breaker and the second feed nobody knew about — and it's the step most often skipped by workers who "know" the machine.
The most common LOTO failure I saw in the field wasn't a missing lock. It was a worker assuming the machine was safe because it looked off. A machine that is off and a machine at zero energy are two different things, and the gap between them is exactly where the amputations happen.
Your Written LOTO Program: What Inspectors Check
The six steps are what workers do. The written energy control program is what your company must maintain — and it's the first document an OSHA compliance officer requests after a machine-related injury. Under 1910.147(c), the program needs four pieces:
| Program Element | Requirement | Where Shops Get Cited |
|---|---|---|
| Machine-specific procedures | A written procedure for each piece of equipment naming its energy sources, isolation points, and verification steps — 1910.147(c)(4) | One generic procedure covering the whole shop |
| Employee training | Authorized employees trained on the procedures; affected employees trained to recognize when LOTO is in use — 1910.147(c)(7) | No documentation proving training happened |
| Periodic inspection | Each procedure inspected at least annually by someone not using it, with the machine, date, employees, and inspector documented — 1910.147(c)(6) | Skipped entirely; most common paperwork citation |
| Hardware | Standardized, durable, substantial locks and tags used for nothing else — 1910.147(c)(5) | Personal padlocks from the hardware store, shared between workers |
A serious LOTO citation runs $4,000 to $16,550 per violation in 2026. But the number that should worry you more: OSHA estimates compliance with 1910.147 prevents roughly 120 fatalities and 50,000 injuries a year. When a LOTO failure injures someone, the citation is rarely one item — the inspector writes up the missing procedure, the missing training record, and the missing annual inspection as separate violations on the same visit. Our small business compliance checklist covers how these documentation requirements stack across standards.
Lockout vs Tagout — and When a Tag Alone Is Legal
A lock physically prevents the disconnect from being operated. A tag is a warning label — it stops nobody. That's why the standard has a clear preference: if the energy-isolating device can accept a lock, you lock it. Tagout alone is permitted only when the device physically cannot be locked out, and the employer must show the tagout program provides protection equivalent to a lock — extra verification steps, removal of a circuit element, blocking of a controlling switch.
Two exemptions come up constantly in small shops, and both are narrower than people think:
Cord-and-plug equipment is exempt only while the plug is under the exclusive control of the person doing the work. In their hand, their pocket, or within arm's reach and line of sight. A plug dangling by an outlet across the room, where a helpful coworker can reconnect it, is not exclusive control.
Minor servicing during production — clearing a jam, a quick adjustment — is exempt only when it's routine, repetitive, integral to production, and performed with alternative protections like interlocked guards. "We were just clearing a jam" is what gets written in the incident report after a hand goes into an unguarded pinch point; it is not, by itself, an exemption.
Training: Authorized vs Affected Employees
The standard splits your workforce into two groups, and each needs different training. Authorized employees — the people who apply locks and perform the service — need training on hazardous energy types, the isolation methods for each machine they touch, and the full six-step sequence. Affected employees — the operators and anyone working in the area — need to recognize when lockout is in use and understand one absolute rule: never touch another person's lock, never attempt a restart.
Retraining triggers whenever job assignments change, machines change, or the annual inspection catches a worker deviating from the procedure. For crews with Spanish-speaking workers, that training has to land in a language they actually understand — the same OSHA language requirement that applies to all safety training applies to LOTO, and a signed English-only training record for a Spanish-speaking maintenance tech will not survive an inspection interview.
This is also a place where regular reinforcement matters more than the annual formality. A five-minute toolbox talk on stored energy before a maintenance-heavy week does more for real compliance than a yearly slideshow. Safety Team Technologies delivers those refreshers by SMS and keeps the training records inspection-ready automatically — the documentation side of 1910.147(c)(7) without the binder.
The Annual Inspection Nobody Does
Buried in 1910.147(c)(6) is the requirement that trips up more small manufacturers than any other: at least once a year, someone other than the person using the procedure must watch it being performed, correct any deviations, and document the inspection — machine, date, employees included, inspector's name.
In 17 years of pre-audit walkthroughs, this was the document missing most often. Shops had procedures. They had locks. They had training sign-offs from onboarding. What they didn't have was a single record proving anyone had verified the procedure still matched the machine — and machines change. A rewired panel, a new air line, a replaced motor with a different disconnect location, and last year's procedure is now wrong in a way nobody will discover until verification fails or someone gets hurt.
Put the annual inspection on a recurring schedule with a named owner. If you can't say today which month your baler's procedure gets inspected and by whom, it isn't going to happen.
Frequently Asked Questions
What are the 6 steps of lockout tagout?
Preparation, shutdown with notification, energy isolation, lock and tag application, stored energy release, and verification by attempted restart. The order is mandatory — verification comes last because it tests every step before it.
Who can remove a lockout device?
Only the employee who applied it. If they've left the facility, 1910.147(e)(3) allows removal under a documented exception: confirm they're not on site, make a reasonable attempt to contact them, and guarantee they know the lock is gone before they return to work. Anything less — a supervisor with bolt cutters — is a citable violation even if nothing goes wrong.
Does LOTO apply to cord-and-plug equipment?
Only when unplugging removes all hazardous energy and the plug stays under the worker's exclusive control the entire time. Exclusive control means in hand, in pocket, or within arm's reach and sight — not merely unplugged.
How much are lockout tagout fines?
In 2026, serious violations run up to $16,550 each, and willful or repeated violations reach $165,514. LOTO citations typically arrive in clusters — procedure, training, and inspection violations written up together — so a single incident routinely produces a five-figure total even before the workers' comp claim.
What is a group lockout?
When multiple workers service the same equipment, each must attach a personal lock. A group lockout device — a hasp or lockbox — holds the isolation in place while giving every worker a personal attachment point. The equipment cannot be re-energized until the last worker removes the last lock. One lock "covering" a three-person crew is a violation for all three.
Running LOTO training and records on paper? Safety Team Technologies schedules the refresher training, delivers it to your crew by text in English or Spanish, and files the signed records automatically — so when the compliance officer asks for your 1910.147 documentation, it's a download, not a scavenger hunt.
