Which Employees Must Receive Lockout Tagout Training?

Employees involved in machinery maintenance or servicing must receive lockout tagout training to protect against unexpected startup or the release of stored energy. According to Grace Technologies' 2024 State of Electrical Safety Report, many electrical accidents still stem from contact with energized parts—often due to missing energy control procedures, poor supervision, and lack of lockout tagout (LOTO) training. The report's analysis of more than 300 event records revealed a 29% rise in LOTO violations from the previous year, particularly in manufacturing settings.

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.”

However, many companies still treat lockout tagout as something only mechanics or electricians need. Since their jobs obviously involve exposure to hazardous energy, it’s easy to assume they’re the only ones who require training. But this assumption overlooks a bunch of scenarios where other employees also face risks or could accidentally interfere with a lockout tagout process.

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 provide retraining when job duties change, new equipment is introduced, or when inspections show employees are not following procedures correctly.

• Outside servicing personnel and the on-site employer should discuss their LOTO procedures before starting work to identify and address any discrepancies or conflicts.

Who Needs LOTO Training?

According to the Occupational Safety and Health Administration (OSHA), all employees who may be exposed to hazardous energy, directly or indirectly, must receive training that matches their role. The standard 29 CFR 1910.147(c)(7) breaks this down into three groups:

Authorized Employee

A lockout tagout authorized employee has been given the responsibility, training, and authority to implement lockout tagout procedures on particular equipment. They must be certified by their supervisor on each piece of equipment to demonstrate a thorough understanding of the lockout tagout safety procedures. 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

  • Working only under his or her own lock and tag

  • Maintaining lockout tagout devices in good and working condition

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

When it comes to LOTO, the supervisors of the authorized employees must ensure that the employees are certified and that training has taken place. A supervisor’s responsibilities include:

• • Creating equipment-specific LOTO procedures

  • Maintaining a list of authorized workers

  • Providing lockout tagout safety guidelines if requested

They must also provide the equipment that the authorized employees need for the equipment-specific LOTO training. The authorized employee will be presented with equipment-specific procedures to verify their understanding of the procedure so that they can perform it accordingly.

Affected Employee

Lockout tagout affected employees are those who operate or use equipment being serviced, or work in the area where LOTO procedures are being applied. 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:

• • Recognize when lockout/tagout is in progress

  • 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

This group includes anyone who may pass through or work near an area where lockout/tagout procedures are active, even if they don’t operate or service equipment themselves. Like affected employees, other employees cannot apply or remove lockout tagout devices. Now, there isn’t a set distance or exact “proximity” that determines if someone falls into this category. It’s about whether the employee could:

• • Enter or be present in an area where a machine or equipment is undergoing LOTO.

  • Come close enough to see, interact with, or be impacted by the work or the locked-out equipment.

  • Accidentally interfere with the LOTO process, even unintentionally.

With that said, other employees must be informed about:

• • The meaning of energy isolating devices and warning signs

  • The importance of not disturbing locks, tags, or authorized workers

  • General awareness of hazardous energy in their environment

Group Lockout/Tagout Procedures

If a group of employees is tasked to repair a machine, each employee will attach their personal padlock to the group lockout device (lockout hasp or group lockbox) as soon as they begin to work. They will only remove these padlocks once the work on the machine has been completed. If there is more than one authorized employee required to lock or tag out a machine, there should be a primary authorized employee to:

• • 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 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?

Now, even the best employee training isn’t permanent if it's not reinforced. That’s why OSHA includes clear guidance on when employers must provide retraining for LOTO. Retraining is required when:

A job assignment change involving the use of different LOTO procedures

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

So, if you want to know your employees' knowledge of your facility's existing LOTO procedures in your workplace, you can use the following checklist for your reference:

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 type of employee doesn't participate in lockout procedures or work?

That would be an affected employee. While they don’t install locks or physically isolate energy sources, they work on or near equipment that is being serviced or maintained. They must be trained to recognize LOTO devices and understand why equipment must not be restarted during servicing.

Do office or administrative employees need LOTO training?

In most cases, no—unless they work in or frequently pass through areas where lockout/tagout procedures are active. If an office employee’s duties never bring them near machines being serviced, they don’t require LOTO training. However, if they’re exposed to those areas—even occasionally—they fall under the category of “other employees” and must receive general awareness training.

Do temporary or seasonal workers require LOTO training?

Yes. OSHA does not exempt temporary, part-time, or seasonal workers from safety training requirements. If a temp worker is assigned tasks that make them an authorized or affected employee, they must receive the same lock out tag out training as permanent staff. The responsibility falls on the host employer, even if the worker is placed through a staffing agency.

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.