What Are the LOTO Tag Requirements and Limitations?

Clear communication is essential to keeping workers informed about potential electrical hazards, especially during maintenance or repair tasks. LOTO tags, or lockout tagout tags, are a key part of this, providing clear warnings and information during hazardous energy control procedures. Typically made of durable, industrial-grade plastic, LOTO tags are attached to energy-isolating devices to indicate that machinery is secured in a safe or OFF position. These tags help communicate who applied the lockout, when, and why.

In one OSHA-reported incident, a 38-year-old worker at a forklift parts manufacturer in Cullman, Alabama, died after being caught in a molding machine. The investigation found that the company failed to follow required safety protocols, including proper machine guarding and lockout tagout procedures. This case highlights the serious consequences of overlooking even one step in the process and the importance of using both lockout and tagout devices during service work operations.

In the next section, we’ll break down the specific requirements for LOTO tags, including what they must contain, when they can be used, and what their limitations are under OSHA and ANSI standards.

Key Takeaways

• Lockout tagout tags must be used along with energy-isolating devices unless locking is not feasible and equivalent protection is proven.

• OSHA outlines the requirements for tagout devices in terms of durability, legibility, and attachment. 

• Incomplete or mislabeled LOTO tags can lead to serious incidents due to misunderstandings about equipment status.

• Each tag must list the authorized employee’s name, department, date, time, and reason for the lockout to ensure clear communication.

OSHA Requirements for Tagout Devices

The Occupational Safety and Health Administration (OSHA) defines the minimum performance requirements in its standard 29 CFR 1910.147, titled The Control of Hazardous Energy. Within this regulation, section 29 CFR 1910.147(c)(5) specifically addresses what are the requirements for tagout devices used during servicing and maintenance operations:

Durable

Tagout devices must be built and printed in such a way that exposure to weather or damp environments does not cause the lockout tag to deteriorate or the message on the lockout tag to become unreadable. When utilized in corrosive conditions, such as locations where acid and alkali chemicals are handled and stored, tags must not also deteriorate.

Substantial

Tagout devices, including their attachment methods, must be sturdy enough to prevent removal through excessive force. Tagout device attachment methods must be non-reusable and attachable by hand. It should also be non-releasable with a minimum unlocking strength of 50 pounds and be designed in a way that is comparable to a durable nylon cable tie that can be used in all types of environments.

Identifiable

Lockout/tagout tags must have the identity of the employee who applied them, and tagout devices must also provide warnings of hazardous conditions and include a clear legend to prevent machines or equipment from starting or operating. This includes legends such as “Do Not Start,” “Do Not Open,” “Do Not Close,” “Do Not Energize,” and “Do Not Operate.” Tags must also be securely attached to the hazard, as close as possible, using attachment means at least equivalent in strength and durability to a one-piece, all-environment-tolerant nylon cable tie.

Failure to follow lockout tagout regulations can result in serious consequences, including OSHA citations. As of 2025, fines for serious violations can exceed $16,000 per violation, with significantly higher penalties for willful or repeated offenses. One of the most common reasons companies are cited is the use of improper, makeshift, or incorrect lockout or tagout devices.

Are LOTO Tags Required in Lockout/Tagout Procedures?

Yes, LOTO tags are required in lockout/tagout procedures as per OSHA. 1910.147(d)(4)(iii) specifies that tags must be used as an integral part of the energy control program to indicate that the equipment is being serviced or maintained and should not be turned on until the maintenance or servicing is complete. Proper compliance with the Lockout/Tagout standard, including the use of required tagout devices, is estimated to prevent approximately 120 fatalities and 50,000 injuries each year.

ANSI Requirements for Tagout Devices

While OSHA sets the legal minimum standards for lockout tagout, the American National Standards Institute (ANSI) provides additional guidelines focused on the design, format, and content of tagout devices. Specifically, the ANSI Z535.5-2011 guidelines recommend that safety tags:

• • Use a standardized header and signal word panel to convey the severity of the hazard and the urgency of the message.

  • Use standardized colors, with red indicating immediate danger, orange indicating a warning, and yellow indicating caution.

  • Use standardized text to clearly and concisely communicate the specific hazard and the action required to avoid it.

  • Use standardized symbols and pictograms to convey information, especially when language barriers or low literacy levels may be a concern.

Should LOTO Tags Have a Specific Color?

Yes, LOTO tags should have a specific color to help ensure that they are easily identifiable as part of a lockout/tagout program. There is no OSHA-mandated color for LOTO tags, but using a consistent, attention-grabbing color is strongly recommended for lockout tagout programs. Most workplaces follow ANSI Z535.1 Standard for Safety Colors, which recommends using red or red-and-white tags to signal danger and indicate that stored energy sources are under control for maintenance or servicing.

As shown above, red is used to signal immediate hazards that could result in serious injury or death. This color-coding system is critical in energy control procedures where workers are exposed to potentially lethal energy sources.

What Should Be Written on a LOTO Tag?

Lockout tags must specify the service or maintenance work being done in addition to the general message warning employees not to remove the tag or restore power to a particular machine. The authorized employee who attaches their own tag and lock to the system must include their name, department, and date of tagout device attachment.

This information helps prevent accidental restarts, especially during shift changes or multi-person maintenance tasks. A few years ago, a colleague told me about an incident involving a maintenance technician working on a conveyor system during a routine shutdown. He was hospitalized after another employee restarted the conveyor that had been tagged but was not labeled properly. OSHA’s investigation concluded that the lack of required information directly contributed to the miscommunication and failure of the lockout tagout process.

This case underscores the importance of clearly written, fully completed LOTO tags—not just tags placed “for appearance.” It also raises a question: how can we reduce the chances of human error even further?

To help answer that, some organizations are starting to explore smart lockout tagout systems, including digital tagging, QR codes, and even augmented reality (AR) overlays. These tools allow workers to view lockout information through a mobile device or headset, and can link to digital permits, schematics, and live maintenance logs.

💡 Expert Insights

 

 

“As someone who's been in safety for years, I see this (technology in LOTO) as an opportunity, not a burden. We're not just updating a standard; we're re-imagining how technology and human safety can coexist more intelligently. The future of workplace safety isn't about rigid rules. It's about smart, flexible systems that protect people while enabling technological progress.” – Randal Hines, Senior Consultant

Limitations of Tagout Devices

According to 29 CFR 1910.147(c)(7)(ii), there are specific limitations of tagout devices that employees must be trained to understand:

• • Tagout devices do not provide the same level of protection as lockout (energy-isolating) devices. Tags are essentially warning labels, not physical restraints.

  • Tags are essentially warning devices affixed to energy-isolating devices. They do not prevent the operation of equipment or the release of potentially hazardous stored energy.

  • Tags must not be removed without proper authorization, and they should never be ignored, bypassed, or defeated.

  • Tags must be legible and understandable by all authorized and affected employees.

  • Tags and their attachment means must be securely attached and able to withstand environmental conditions and physical forces (though not necessarily providing full restraint like a lock).

  • Tags evoke a false sense of security if not used with proper procedures and employee awareness.

Unlike physical LOTO locks, tagout devices don’t offer any mechanical restraint. They rely entirely on workers noticing and respecting the tag, which introduces risk. A tag can be ignored, overlooked, or even removed by mistake. A lock, on the other hand, physically prevents operation.

Can Tagout Devices Be Used in Place of Lockout Devices?

According to OSHA 29 CFR 1910.147(c)(2)(i), tagout devices can be used in place of lockout devices when there is no way to lock out a device, and the employer can demonstrate that tags will ensure full employee protection. This could include removing control fuses, applying additional warning signs, or using control circuit-type devices. In a proper lockout tagout setup, the lockout tag is attached directly to the energy isolating device—typically alongside a padlock or other lockout device. 

Can Lockout Tags Be Reused?

No, lockout tags cannot be reused. OSHA 29 CFR 1910.147(c)(5)(ii)(C)(2) states that "Tagout devices, including their means of attachment, shall be substantial enough to prevent inadvertent or accidental removal. Tagout device attachment means shall be of a non-reusable type, attachable by hand, self-locking, and non-releasable..." Rightly so, because reusing a tag can cause confusion and compromise worker safety, who rely on these safety tags to keep themselves safe from dangerous energy sources.

Other Types of Safety Tags

Keeping your workplace safe starts with understanding the importance of safety tags, and not just lockout tagout tags. Listed below are five different types of safety tags, along with a guide on when to use them and why they're essential.

Is Lockout Safer Than Tagout?

Essentially, lockout is safer than tagout. Lockout provides a physical barrier to prevent accidental re-energization, which helps ensure that the equipment remains off until work is complete. Meanwhile, tagout is a procedure typically done in conjunction with lockout to provide additional information about the status of equipment being serviced or maintained.

While the above statements are true, it is imperative to note that lockout and tagout procedures must always be performed together to control hazardous energy sources, thereby minimizing the potential for unintended startup or residual energy release during maintenance or repair operations.

FAQs on LOTO Tags

What color are LOTO tags?

Red is the most common color for loto tags, signaling immediate danger. While OSHA doesn’t require a specific color, ANSI recommends red or red-and-white for high-risk energy control points.

Can I print my own LOTO tags?

Yes, you can print your own tags as long as they meet OSHA’s durability, legibility, and strength requirements. They must be securely attached and standardized across the facility.

Who can remove tagout devices?

Only the authorized employee who applied the tag is allowed to remove it. If unavailable, a formal removal process must be followed per OSHA rules.

Are tags safer than locks?

No, locks are always safer than tags because they physically prevent equipment from being energized. Tags only serve as visual warnings.

Can digital lockout systems replace tags?

No, digital systems can support LOTO procedures but cannot replace physical tags under OSHA standards. Tags are still required at the point of energy isolation.