What Is Lockout/Tagout?
Lockout/Tagout (LOTO) is the procedure for isolating hazardous energy before anyone performs service or maintenance on machinery or equipment. "Hazardous energy" includes electrical, hydraulic, pneumatic, mechanical, thermal, chemical, and gravitational energy — essentially anything that could cause unexpected movement or release.
The governing OSHA standard is 29 CFR 1910.147 — "The Control of Hazardous Energy." It applies to general industry. Construction has a parallel standard under 29 CFR 1926.
Who Is Required to Have a Written Program?
The standard applies to any employer whose employees perform servicing or maintenance on equipment where unexpected energization or startup could cause injury. That includes:
- → HVAC contractors servicing commercial equipment
- → Electrical contractors working on panels, motors, or controls
- → Plumbers working on pressurized systems
- → Machine shops with CNC equipment, presses, or automated systems
- → Manufacturing plants with conveyor lines, robots, or process equipment
- → Facilities maintenance teams in office buildings, schools, or hospitals
The only exemption is cord-and-plug connected equipment where the plug is under the exclusive control of the employee doing the work. If your equipment is hard-wired, has multiple energy sources, or stores energy after being de-energized — the standard applies.
What Must a Written Program Include?
Per 29 CFR 1910.147(c)(1), an energy control program must include:
Purpose and Scope
What the program covers and which employees and equipment it applies to
Roles and Responsibilities
Who is authorized to apply locks, who is affected, and who administers the program
Energy Control Procedures
Step-by-step procedures for each piece of equipment, covering each energy source
Hardware Requirements
Locks, tags, hasps, and other devices — each employee must have their own lock
Training Requirements
Initial training for authorized and affected employees, retraining triggers
Periodic Inspections
Annual inspection of energy control procedures, certification documentation
What OSHA Actually Cites
In FY2024, OSHA issued 2,655 citations under 29 CFR 1910.147 — making it the fifth most cited standard across all industries. The most common specific violations:
- ✗ 1910.147(c)(4)(i) — No written energy control procedures for specific equipment
- ✗ 1910.147(c)(7)(i) — Employees not trained on energy control procedures
- ✗ 1910.147(c)(6)(i) — No annual inspection/audit of the energy control program
- ✗ 1910.147(d) — Employees not following the lockout/tagout procedure during servicing
Employers with 10–49 employees receive nearly 27% of all OSHA inspections — disproportionate to their share of the workforce. Small contractors are not flying under the radar.
The Fine Structure
OSHA penalty amounts as of 2024:
$16,131
Serious Violation
(per citation)
$16,131
Other-Than-Serious
(per citation)
$161,323
Willful or Repeat
(per citation)
Each piece of equipment without a written procedure can be a separate citation. A shop with 10 machines and no written LOTO program faces up to $161,310 in serious violations.
Why General Contractors Require It
Beyond OSHA inspections, many general contractors now require subcontractors to submit a site-specific LOTO program before work begins on commercial projects. This is driven by GC liability exposure — if a sub's employee is injured due to inadequate LOTO, the GC can face OSHA multi-employer citations. A documented written program is increasingly a contract requirement, not just a regulatory one.
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