Lockout/Tagout (LOTO) Requirements: A Practical Compliance Guide
Quick answer: OSHA's Control of Hazardous Energy standard (29 CFR 1910.147) requires a written energy-control program, machine-specific procedures, a lock and tag for every energy source, training for authorized and affected employees, and a documented periodic inspection at least once a year. Its purpose is to protect workers from the unexpected start-up of machines or the release of stored energy during servicing and maintenance.
Why Lockout/Tagout Exists
During servicing and maintenance, the unexpected energization of equipment — or the release of stored energy in springs, hydraulics, capacitors, or raised parts — can cause crushing, amputation, electrocution, and death. LOTO is the set of practices that makes equipment verifiably safe to work on. It is consistently among OSHA's most-cited standards (see our breakdown of OSHA's Top 10 violations).
Who's Involved: Three Types of Employees
| Role | Definition | Training needed |
|---|---|---|
| Authorized | Performs the lockout/tagout to service equipment | Full training on energy types, hazards, and procedures |
| Affected | Operates or works near equipment being serviced | Trained to recognize LOTO and not to restart locked-out equipment |
| Other | Works in an area where LOTO may be used | Made aware of the procedure and the prohibition on removing locks |
The Written Energy-Control Program
Your program must document, for each machine, how energy is controlled. Machine-specific procedures should identify every energy source, the steps to shut down and isolate it, and the method to verify isolation. Generic, one-size-fits-all procedures are a frequent source of citations.
The Six Steps of Lockout/Tagout
Devices and Locks
- Lockout devices must be durable, standardized, substantial, and identifiable.
- Each authorized employee applies their own lock, and holds the only key.
- Tags (when used alone) are warning devices only and must be supplemented by a lock wherever possible.
- Never remove another employee's lock — there is a strict, documented procedure for the rare exception.
Training and Retraining
Authorized and affected employees must be trained on the program. Retraining is required whenever there is a change in job assignment, machines, or procedures, or whenever an inspection reveals deviations or inadequacies.
The Annual Periodic Inspection
At least once a year, a designated authorized employee (other than the one using the procedure) must inspect each energy-control procedure to confirm it is being followed correctly, and the employer must certify the inspection. This is the calendar item LOTO programs most often miss.
Frequently Asked Questions
How often is LOTO training required?
There's no fixed annual training interval, but retraining is required whenever procedures, equipment, or job assignments change, or when an inspection finds problems. Separately, the energy-control procedures must be inspected at least once a year.
Is a tag enough, or do I need a lock?
Wherever an energy-isolating device can accept a lock, you must lock it out. A tag alone is permitted only when the device cannot be locked, and it must provide protection equivalent to a lock.
Does LOTO apply to cord-and-plug equipment?
If unplugging the equipment fully controls the energy and the plug stays under the exclusive control of the person servicing it, LOTO generally does not apply. Otherwise, it does.
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