Lockout/Tagout — Control of Hazardous Energy (29 CFR 1910.147)
Lockout/Tagout (LOTO) violations under 29 CFR 1910.147 require employers to establish procedures for isolating machines from energy sources during maintenance and servicing. LOTO violations are among the most heavily penalized because failure to control hazardous energy causes approximately 120 fatalities per year.
What 29 CFR 1910.147 Requires
Lockout/Tagout (LOTO) is one of the most documentation-intensive OSHA standards. It requires machine-specific written procedures for every piece of equipment that could release hazardous energy during servicing. The standard also mandates distinct training for authorized employees (who perform LOTO) and affected employees (who work near locked-out equipment):
- Written energy control procedures (lockout/tagout procedures) for each piece of equipment
- Locks and tags must be provided by the employer and must be durable, standardized, and substantial
- Authorized employees must be trained on specific energy control procedures for equipment they service
- Affected employees must be trained to recognize when energy control procedures are in use
- Periodic inspections of energy control procedures at least annually
- Group lockout/tagout procedures when multiple workers are servicing the same equipment
Most Common Violations
LOTO violations are almost entirely documentation-based — the most common citation is simply not having written energy control procedures. Generic procedures that are not specific to individual machines are also frequently cited. The annual periodic inspection requirement is the second most missed element:
- No written energy control procedures for specific machinery
- Failure to train authorized and affected employees on LOTO procedures
- Using tags only without locks where lockout is possible (tagout alone is insufficient)
- No periodic inspection of energy control procedures
- Failure to verify energy isolation before beginning maintenance work
- Inadequate group lockout/tagout procedures when multiple workers are involved
Penalty Exposure
Penalty range: $1,190–$16,550 per serious violation; up to $165,514 per willful violation
LOTO violations carry severe penalties because failure to control hazardous energy causes approximately 120 fatalities per year. A single serious LOTO citation can cost up to $16,550 in 2026. Because the standard requires machine-specific procedures, OSHA can cite a separate violation for each piece of equipment lacking documented procedures — creating substantial cumulative penalties.
The annual periodic inspection is a unique requirement that many contractors miss. Its absence alone generates a citation regardless of how well the day-to-day LOTO program operates.
Documentation You Need
LOTO documentation is extensive but structured. The key requirement is that procedures must be specific to each machine — not generic templates applied broadly:
- Written machine-specific energy control procedures for every piece of equipment requiring LOTO
- Training records for authorized employees (those who perform LOTO) with specific procedures covered
- Training records for affected employees (those who work near locked-out equipment)
- Periodic inspection records conducted at least annually by an authorized employee
- Lock and tag inventory and assignment records
- Group lockout/tagout procedure documentation for multi-worker servicing
What Inspectors Look For
During an OSHA inspection, LOTO compliance is evaluated primarily through document review. Inspectors will request written procedures and training records, then verify that workers can describe the procedures for their specific equipment:
- Written energy control procedures — machine-specific, not generic templates
- Training records distinguishing authorized vs. affected employees
- Annual periodic inspection records with inspector name, date, and findings
- Physical locks and tags — are they durable, standardized, and assigned to individuals?
- Evidence of energy isolation verification before maintenance begins
- Worker awareness — can authorized employees explain the LOTO procedure for their equipment?
Build Your LOTO Documentation Before an Inspector Asks for It
The OSHA Defense Documentation System includes lockout/tagout procedure templates, training documentation forms, and periodic inspection logs — covering every LOTO documentation requirement under the Control of Hazardous Energy standard.
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