OSHA 1910.147 Compliance Requirements Summary

29 CFR 1910.147 — the Control of Hazardous Energy (Lockout/Tagout) standard — applies to all industries where workers perform servicing or maintenance on machinery where unexpected energization could cause injury. Consistently ranked in OSHA's Top 10 most-cited standards.

2026 penalty schedule: up to $16,550 per serious violation · up to $165,514 per willful/repeat violation

Step-by-Step LOTO Procedure Checklist

Use this checklist for every lockout/tagout event. Each authorized employee should verify all steps before beginning servicing or maintenance work.

• 1. Prepare for shutdown — identify all energy sources Survey the machine to identify all energy forms: electrical, hydraulic, pneumatic, mechanical, thermal, chemical, and gravity. Consult equipment-specific LOTO procedure before starting.
• 2. Notify all affected employees Inform all employees in the area who operate or work with the equipment that it will be shut down for service. Explain why and expected duration.
• 3. Shut down equipment using normal stopping procedure Turn off the machine using its normal operating controls (e.g., stop button, switch, valve) — do NOT use energy isolation as the first step.
• 4. Isolate all energy-isolating devices Activate every energy isolation point (circuit breakers, valve handles, disconnect switches) to their safe/open/closed position. Include ALL sources — verify against written procedure.
• 5. Apply personal lockout/tagout devices Each authorized employee applies their own personal lock to every energy-isolating device. Lock must be individually keyed — no master keys except for emergency and tryout. Apply tagout device if lockout isn't feasible.
• 6. Release, restrain, or dissipate stored/residual energy Safely release or control ALL residual energy: bleed pneumatic/hydraulic pressure, block gravity loads, discharge capacitors, relieve spring tension, allow thermal cool-down, ground electrical equipment.
• 7. Verify isolation — test for zero energy state Attempt to start the equipment using its normal operating controls to verify it cannot be energized. Use a meter to verify electrical equipment is de-energized. Return operating controls to neutral after testing.
• 8. Perform the authorized service or maintenance work Only authorized employees may work on the isolated equipment. Verify isolation remains intact throughout the work. If any isolation point must be temporarily re-energized, follow the re-energization protocol.
• 9. Prepare to restore equipment to service Ensure all tools, materials, and components are removed from the machine. Reinstall all guards and safety devices. Verify work area is clear and all employees are in safe positions.
• 10. Remove personal lockout/tagout devices Each authorized employee removes ONLY their own lock. Verify no employee remains in a hazardous position. If original authorized employee cannot remove their lock, follow the established procedure for lock removal with supervisor.
• 11. Notify affected employees before re-energization Inform all affected employees that lockout/tagout has been removed and the machine is being restored to service. All affected employees must be notified before energy is restored.
• 12. Re-energize and return to normal operation Restore energy sources in the reverse order of isolation. Verify all energy sources are re-established and equipment operates normally before returning to regular production.

Annual Inspection Requirements

29 CFR 1910.147(c)(6) requires periodic inspection of energy control procedures at least once per calendar year. This is one of OSHA's most commonly cited deficiencies in LOTO programs.

• Inspection performed by an authorized employee other than the one using the procedure The inspector must be qualified as an authorized employee under the program, but cannot be the employee who regularly uses that specific procedure.
• All equipment-specific procedures reviewed at least annually Every written LOTO procedure in the facility must be reviewed — not just a sample. Track by procedure number and inspection date.
• Lockout procedure inspection: performed with authorized employee present For lockout procedures, conduct the inspection while the authorized employee is performing servicing or maintenance, OR conduct a walkthrough review with the employee.
• Tagout procedure inspection: expanded review required Tagout procedure inspections must additionally include a review of tagout limitations and review of the effectiveness of using tagout devices vs. lockout devices.
• Inspection documentation completed Record: date of inspection, equipment or machinery inspected, employees involved in the inspection, and name of inspector. Retain records per your record retention schedule (recommend minimum 3 years).
• Deficiencies identified and corrected before next use Any deviations, inadequacies, or deficiencies found during inspection must be corrected and employees retrained before the procedure is used again.

Training Documentation Requirements

Three employee categories require training under 1910.147(c)(7), each with different scope and retraining triggers.

• Initial training records documented for all three employee categories Records must include employee name, training date, content covered, and trainer. Must demonstrate employees can recognize applicable energy sources.
• Retraining triggered when: procedures change, new equipment introduced, or inspection reveals deviations Retraining must occur whenever there is reason to believe employees do not follow, or do not have knowledge of, the energy control procedures.
• New employee LOTO training completed before unsupervised LOTO work Employees cannot perform lockout/tagout procedures independently until they have completed training and demonstrated competency. New hire orientation must include LOTO.
• Contractor LOTO coordination documented Per 1910.147(f)(2), when outside contractors perform energy control work, the facility employer must inform them of the LOTO program and obtain confirmation of equivalent protection for host employees. Document the exchange.
• Group lockout training completed for multi-employee servicing When two or more employees are involved in servicing the same equipment, all employees must be trained in the group lockout procedure with equivalent protection (lockbox system).

Top OSHA LOTO Citations & How to Avoid Them

These are the violations OSHA inspectors look for first. Each can trigger penalties per machine or per employee — a single audit can result in citations for every piece of equipment without compliant documentation.