Which Employees Must Receive Lockout Tagout Training?

Authorized employees, affected employees, and other employees whose work may take them into areas where energy control procedures are used must receive lockout tagout training appropriate to their roles. Grace Technologies’ 2024 State of Electrical Safety Report analyzed more than 300 electricity-related accident reports from 2021 to 2024 and identified contact with energized parts, inadequate LOTO procedures, and insufficient supervision and training among the contributing issues. A separate analysis in the report found that LOTO violations rose 29% from 2022 to 2023, with manufacturing accounting for most citations and penalties.

Drew Allen, President of Grace Technologies, commented, “This data analysis reveals a compelling trend in LOTO violations, suggesting not just a shortfall in current safety practices but a clear directive for the future. Proactive measures are becoming essential, not optional, in averting severe safety breaches.”

Job titles alone do not determine who needs LOTO training. A machine operator who could restart equipment, a cleaner assigned to work in a servicing area, or an employee whose duties take them into an area where energy control procedures are used may require instruction even if they never apply a lock. The appropriate training depends on their responsibilities under OSHA’s energy control standard.

So, who actually needs LOTO training, and what kind of training do they need?

Key Takeaways

• OSHA defines three groups of employees who must receive LOTO training: authorized employees, affected employees, and other employees.

• Each group requires a different level of instruction based on their interaction with hazardous energy and energy control procedures.

• Employers must retrain authorized and affected employees when job assignments or energy control procedures change, equipment or process changes introduce a new hazard, or inspections or other evidence reveal gaps in knowledge or procedure use.
  

• The on-site employer and outside servicing employer must inform each other of their LOTO procedures. The on-site employer must make sure its employees understand and follow the outside employer’s restrictions and prohibitions.
  

 

Who Needs LOTO Training?

Under OSHA’s general-industry lockout/tagout standard, training requirements depend on an employee’s duties and involvement with energy control procedures. Section 29 CFR 1910.147(c)(7) identifies three groups that require role-appropriate instruction: authorized employees, affected employees, and other employees whose work may take them into areas where energy control procedures are used.

Authorized Employee

A lockout tagout authorized employee has been given the responsibility, training, and authority to implement lockout tagout procedures on particular equipment. Their training must cover the hazardous energy and isolation methods for the equipment they will service. An authorized employee’s responsibilities include:

• • Completing all the training required to become authorized to perform lockout tagout on a specific machine, tool, or equipment

  • Performing lockout tagout that conforms to the company’s program

  • Retaining hazardous energy control of the machine or equipment while servicing it, when LOTO is in progress

  • Applying their own personal lockout or tagout device as required, including during group procedures, and following OSHA’s requirements for device removal

  • Maintaining lockout tagout devices in good and working condition

💡 Expert Tip

“The safety of employees will increase greatly when you have an effective authorized employee training program in place. Be sure to include all necessary information that OSHA requires, as well as any other additional information specific to the site.” – Jake Thatcher, Senior Safety Project Engineer at Rockwell Automation

The employer must either develop and provide training or outsource this from independent training providers. Either way, the following must be considered:

• • The applicable hazardous energy sources

  • Magnitude and type of energy in the workplace

  • Means and methods for energy control and isolation

  • Removal of devices that control hazardous energy

The employer must certify that employee training has been completed and is kept up to date. The record must include each employee’s name and training dates.

A company may assign supervisors to maintain its authorized-worker list, coordinate training, and help develop equipment-specific procedures. Those assignments do not replace the employer’s responsibility to provide effective training and the equipment needed for energy control.

Affected Employee

Lockout tagout affected employees are those whose jobs require them to operate or use equipment being serviced under LOTO, or to work in the area where that servicing takes place. Although affected employees are not authorized to apply or remove lockout tagout devices, their actions can directly impact safety if they’re unaware or uninformed. These employees must be trained to:

• • Understand the purpose and use of the energy control procedure
    

  • Understand why equipment must not be restarted or bypassed

  • Follow instructions from authorized personnel during servicing activities

For example, a machine operator may see a red tag and think the equipment is “just down for cleaning.” Without training, they might try to restart it, putting a coworker in danger. Affected employee training focuses on awareness and response, not technical isolation steps.

Other Employee

Other employees are workers whose work activities may take them into an area where energy control procedures are used, but who do not perform the servicing or have the operating or servicing-area duties described above. Like affected employees, other employees cannot apply or remove lockout tagout devices. 

There isn’t a set distance that determines the category. Look at the employee’s assigned duties and where those duties may take them.

With that said, other employees must be informed about:

• • The energy control procedure used in the area
    

  • The prohibition against restarting or reenergizing locked-out or tagged-out equipment
    

  • The need to leave locks and tags undisturbed
    

Group Lockout/Tagout Procedures

During group lockout or tagout, each authorized employee attaches their personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism before beginning servicing or maintenance. Each employee removes their personal device when they stop working on the machine or equipment. The equipment must remain protected against unexpected energization while employees are working under the group procedure. If work extends across shifts or personnel changes, specific transfer procedures must maintain continuity of protection.

An authorized employee must have primary responsibility for the defined group. When more than one crew, craft, or department is involved, an authorized employee must coordinate the workforces and continuity of protection. The designated lead’s responsibilities include:

• • Coordinate and implement the LOTO of hazardous energy sources and the particular machine to be serviced

  • Coordinate with the machine operators pre- and post-servicing on tasks that require group LOTO

  • Lead a group of servicing or maintenance employees

  • Maintain accountability of each authorized employee under their group

 

Working With Outside Personnel

According to the standard 29 CFR 1910.147(f)(2), “Whenever outside servicing personnel are to be engaged in activities covered by the scope and application of this standard, the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures… The on-site employer shall ensure that his/her employees understand and comply with the restrictions and prohibitions of the outside employer's energy control program.”

This mutual understanding helps in preventing accidents, ensuring that all personnel are aware of the energy control measures in place. Outside personnel are also required to receive LOTO training, and their employer (the contractor company) is responsible for providing that training.

 

When Is Retraining Required?

OSHA requires retraining for LOTO for authorized and affected employees when assignments or procedures change, new hazards are introduced, or there is evidence that employees need further instruction. Retraining is required when:

A change in an authorized or affected employee’s job assignment

A change in processes, machines, or equipment that presents new hazards

A change in the procedures for energy control

Any reason to believe that an employee needs more knowledge of the energy control procedures

An employee deviating from the established procedures

Use this checklist to identify employee training gaps and energy control program issues. Questions 8–12 assess authorized-employee tasks and should not be used to evaluate affected or other employees against responsibilities outside their roles. Questions about device suitability and procedure documentation are program compliance checks, not direct measures of employee knowledge. This checklist does not replace OSHA’s required periodic inspection of energy control procedures at least annually. OSHA does not require blanket annual LOTO retraining; retraining is triggered by the conditions specified in §1910.147(c)(7)(iii).

Lockout Tagout (LOTO) Training Assessment Checklist

FAQs on LOTO Training

What is the OSHA standard for lockout tagout training?

The training requirements are outlined in 29 CFR 1910.147(c)(7). This section of the standard states that authorized employees, affected employees, and other employees must receive training tailored to their roles and exposure to hazardous energy. The goal is to ensure they understand the purpose and function of the energy control procedures, as well as the scope of their responsibilities.

Which employees receive LOTO training without performing lockout?

Affected and other employees receive LOTO instruction without being authorized to isolate equipment. Affected employees learn the purpose and use of the energy control procedure. Other employees learn about the procedure and the prohibition against restarting or reenergizing locked-out or tagged-out equipment. If an affected employee’s duties change to include servicing covered by the standard, they must receive authorized-employee training before performing that work.

Do office or administrative employees need LOTO training?

Office employees do not need LOTO training solely because they work for the company. If their work activities may take them into an area where energy control procedures are used, they need instruction appropriate to their duties. Someone passing through may be an “other employee,” while someone whose job requires work in the servicing area is an affected employee.

Do temporary or seasonal workers require LOTO training?

Yes. OSHA does not exempt temporary, part-time, or seasonal workers from safety training requirements. Temporary workers need the same role-appropriate lock out tag out training as permanent staff, including instruction for other employees when their work may take them into LOTO areas. The host employer and staffing agency share responsibility for worker safety and must coordinate training. The host generally provides instruction specific to its equipment and hazards, while the staffing agency must check that the necessary training is provided.

Can one person be both an authorized and affected employee?

Yes, absolutely. Many workers shift roles throughout the day. For example, a technician might normally operate a machine (making them an affected employee) but also perform maintenance when needed (making them an authorized employee). In such cases, they must receive training that covers both sets of responsibilities.