Lockout Tagout (LOTO) Procedures: Stay compliant & safe for Hazardous Energy Control

8 Apr 2025

When it comes to workplace safety, one of the most crucial procedures for preventing accidents and fatalities is Lockout Tagout (LOTO). This essential safety measure ensures that machinery and equipment are properly shut down and isolated from hazardous energy sources before maintenance or servicing activities take place. In this blog, we will dive deep into the fundamentals of LOTO, highlight key OSHA regulations, discuss common violations, and outline best practices for implementing an effective LOTO program in your workplace.

Understanding Lockout Tagout: The OSHA Standard

The Occupational Safety and Health Administration (OSHA) regulates Lockout Tagout under 29 CFR 1910.147, which covers the control of hazardous energy. According to OSHA, the standard applies to all general industry workplaces where the unexpected startup of machines or equipment, or the release of stored energy, could cause injury to employees. However, certain industries—such as construction, agriculture, maritime operations, and oil and gas drilling—fall under different energy control regulations.

Key Differences Between Lockout and Tagout

Although often used together, Lockout and Tagout represent two distinct yet crucial steps in the Lockout/Tagout (LOTO) safety procedure outlined by OSHA’s standard (29 CFR 1910.147). These procedures are essential for controlling hazardous energy and preventing unexpected machine startups during maintenance or servicing.

Lockout: Physical Isolation of Hazardous Energy

Lockout involves the use of a lockout device, such as a padlock, hasp, or other positive locking mechanism, to physically isolate energy sources. This step ensures that machinery, equipment, or electrical systems remain in a de-energized state by securing the energy control devices in the neutral or off position. The lockout mechanism prevents accidental reactivation, effectively safeguarding workers performing maintenance or servicing tasks. According to OSHA, lockout should be the primary method of energy isolation whenever feasible (29 CFR 1910.147(c)(1)).

Tagout: Warning Labels to Prevent Accidental Activation

Tagout refers to the placement of a prominent warning tag that serves as a visual deterrent, alerting employees that the equipment has been isolated for maintenance. Tags typically include:

Warning statements such as “Do Not Operate” or “Danger: Locked Out.”
Employee details, including the name or photo of the individual who applied the lock.
Date and reason for the lockout and expected duration of maintenance.
Clear instructions indicating that the equipment must not be restarted or energized.

Unlike lockout devices, tagout devices do not provide a physical restraint but serve as an additional safeguard to notify workers of ongoing servicing. OSHA requires that when a tagout system is used in place of a lockout system, additional safety measures must be taken to ensure that the tagout procedure provides the same level of protection as lockout (29 CFR 1910.147(c)(3)).

Best Practice: Combining Lockout and Tagout for Maximum Safety

For optimal energy control and workplace safety, OSHA recommends using both lockout and tagout together whenever possible. While lockout ensures physical isolation, tagout reinforces awareness and compliance among all employees. However, if lockout is not feasible, tagout alone may be used only if the employer can demonstrate that the alternative safety measures provide full protection equivalent to lockout (29 CFR 1910.147(c)(3)(ii)).

By following OSHA’s LOTO standard, companies can significantly reduce workplace injuries caused by hazardous energy and comply with regulatory safety requirements.

Key Elements of OSHA’s LOTO Standard

To remain compliant with 29 CFR 1910.147, employers must establish and enforce a LOTO program that includes the following core elements:

Energy Control Procedures – Employers must develop written procedures outlining how to properly shut down, isolate, and lock out equipment before servicing. Follow OSHA's 1910.147 App A - "Typical minimal lockout procedures" to standardize machine specific lockout tagout procedure. https://www.oshepro.com/solution-traci.php
Periodic Inspections – OSHA mandates that organizations conduct at least annual audits to verify that LOTO procedures are correctly implemented and followed.
Training Requirements – Employees must be trained according to their specific roles:
- Authorized employees: Those responsible for implementing LOTO procedures.
- Affected employees: Those who work near locked-out equipment but do not perform servicing.
- Other employees: Individuals who must be aware of LOTO safety but do not work directly with hazardous energy.

Why Lockout Tagout is Critical for Workplace Safety

LOTO is a fundamental element of workplace safety, preventing serious injuries and fatalities caused by accidental machine start-ups or the uncontrolled release of hazardous energy. According to OSHA, failure to control hazardous energy accounts for nearly 10% of serious workplace injuries each year. Some of the most common injuries associated with hazardous energy include:

Electrocution from live wires or energized circuits.
Amputation due to unexpected machine activation.
Burns and crushing injuries from pressurized systems.

Implementing an effective LOTO program minimizes these risks and helps businesses comply with OSHA regulations, ultimately reducing the likelihood of costly fines and legal liabilities.

Common OSHA Violations and Industry Impact

Despite clear regulatory requirements, LOTO violations remain one of the most frequently cited OSHA infractions. In the fiscal year 2023-2024, OSHA reported: