Some industries provide lockout tagout (LOTO) training only once, typically during initial employee onboarding. However, this approach does not align with OSHA regulations and can lead to serious safety risks.
For example, the Occupational Safety and Health Administration (OSHA) cited a food manufacturing company after a temporary worker on the sanitization crew was fatally crushed by a machine’s rotating augers. The report stated, “The citations related to the fatality were issued for: lack of adequate drainage, lack of LOTO procedures, and lack of LOTO training for the sanitization crew.”
OSHA cited the company for 18 safety violations, including seven willful violations, and initially proposed fines totaling $702,300. The case was later settled for $540,000, and the company was placed in OSHA’s Severe Violator Enforcement Program.
This incident highlights the critical importance of not just implementing energy control procedures but also ensuring ongoing training and retraining for all employees, including temporary workers, involved in servicing or cleaning machinery. Retraining helps ensure continued safety, compliance, and awareness, especially in environments where a single mistake can lead to serious injury or death. So, how often is LOTO training required?
Key Takeaways
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Retraining helps prevent serious physical harm caused by the unexpected release of stored energy, and it plays a major role in maintaining compliance and reducing liability.
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There is no set annual requirement for LOTO retraining, but many employers choose to offer yearly refreshers to reinforce safety and stay proactive.
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A strong retraining program uses a mix of formats, regular assessments, practical tools, and proper documentation to keep safety efforts consistent and effective.
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Adult learning principles make retraining more effective by keeping it relevant, practical, and interactive to improve retention and engagement.
Is LOTO Retraining Required?
Yes, LOTO retraining is required for all employees under OSHA standard 29 CFR 1910.147(c)(7)(iii). This is to reestablish the LOTO proficiency of an employee, as well as to introduce new or revised energy control procedures and safe practices. Furthermore, 29 CFR 1910.147(c)(7)(iv) states that, “The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training.”
The National Fire Protection Association’s (NFPA) 70E, Article 110.2(B)(2) also supports refresher employee training at intervals not to exceed three years, whenever procedures are updated, or when an employee fails to follow hazardous energy control procedures.
So, which employees must be retrained? All authorized and affected employees should be retrained on the procedures and requirements of your lockout tagout policy as required by 29 CFR 1910.147(c)(7)(iii)(A). Retraining keeps both groups sharp. Whether someone is new to the job, returning from leave, or shifting roles, understanding the latest procedures to control hazardous energy is part of staying safe and compliant.
When Must Employers Provide Retraining for LOTO?
Employers must provide retraining when certain conditions require it. Below are the four main scenarios when additional lockout tagout training is required:
1. Change in Job Assignment
When an employee moves into a new role that involves exposure to hazardous energy sources, they must be retrained. This applies to both authorized employees who lock and tag equipment and affected employees who operate or work near it. A change in responsibilities often means a change in the types of machines or equipment, energy sources, or procedures the employee will encounter.
2. Change in Equipment or Machinery
Consequently, any change in machines or equipment will result in changed energy control procedures or job assignments, or both. Retraining bridges the gaps between the new equipment, how it will be used, and which equipment- or machine-specific LOTO procedures apply to it.
Even if two pieces of equipment are the same, including type and model number, their energy control procedures might differ from one another. For instance, Equipment #1 is connected to a power source on the same floor, while Equipment #2 is connected to another power source. In such a case, the LOTO procedures for these pieces of equipment will be different from one another.
3. Updated Energy Control Procedures
If the company updates its written energy control procedures, retraining must be provided. Employees need to know the exact steps they are expected to follow. This includes changes in the sequence of shutting down equipment, new types of lockout devices, or added instructions for verifying the isolation of stored energy (LOTOTO).
Additionally, even if employees have been performing the same LOTO procedures for a long time, they can still benefit from retraining, especially if you can introduce alternative measures to improve their efficiency.
4. Observed Deviations or Unsafe Behavior
Lockout tagout procedures are there for employee safety. So, if you observe how an authorized employee deliberately skips certain steps in the existing LOTO procedures on the machine assigned to them, that employee must be retrained. Moreover, if an employee is seen using incorrect procedures or if there’s a near miss involving lockout or tagout, retraining is required immediately. This helps correct the behavior before a serious incident happens. It also shows that the employer is actively maintaining compliance and taking safety seriously.
However, employers must also refer to state laws when it comes to LOTO retraining, especially because some states do have stricter occupational safety regulations than the federal OSHA standards. For example, California (Cal/OSHA) may require more specific documentation and could have tighter timelines or more robust retraining expectations, depending on the industry.
When Is Retraining in the Lockout/Tagout Process Not Required?
If an employee has already been trained and continues to follow the lockout/tagout process correctly, no additional training is required unless a triggering event occurs. In general, retraining is not required when:
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The employee’s job responsibilities haven’t changed.
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Machines or equipment remain the same.
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The overall energy control program and procedures have not been updated.
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No unsafe behaviors or deviations have been observed.
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There have been no incidents or near misses involving stored hazardous energy sources.
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However, a qualified person is still expected to periodically review the LOTO program and verify that employees understand their responsibilities. Just because retraining isn’t triggered doesn’t mean that LOTO training is a one-and-done event. Regular LOTO audits and observations can help identify when subtle issues are starting to develop, even if the standard retraining triggers haven’t been met yet.
Best Practices for LOTO Retraining
According to safety professionals and industry best practices, here are the key strategies to enhance the effectiveness of LOTO retraining programs:
1. Choose the Right Format: Different workplaces and roles may require different training methods. Consider:
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In-person classroom sessions for hands-on learning and Q&A
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eLearning modules for flexibility and easy tracking
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Short video tutorials for quick refreshers or toolbox talks
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Pick the format that best suits the size of your team, the complexity of your equipment, and the types of hazardous energy sources involved.
Now, if you're wondering whether OSHA allows computer-based training—they do, but only under certain conditions. Computer-based training can be part of an acceptable training program, but it must not stand alone if it does not allow for interactive engagement or hands-on components where required. OSHA emphasizes that employee training must result in understanding and retention of the material, and that often requires opportunities for questions, feedback, and demonstrations.
2. Assess Employee Understanding: Use written quizzes, verbal checks, or hands-on demonstrations to verify that authorized employees, affected employees, and other employees can explain and follow the proper steps. Apply “Adult Learning Principles” to make the training more effective. Adults learn best when training is relevant to their job, based on real-life tasks, and gives them a chance to use their experience.
3. Reinforce with Visual Tools: Supporting materials help keep procedures top of mind. Post visual reminders near machines, such as a lockout tagout poster. When employees see the same steps repeated in training and on the shop floor, they’re more likely to follow them correctly.
4. Document: Having a clear record helps with compliance and shows that you’re actively managing safety training. A retraining log also helps to plan future sessions and identify patterns. Keep a retraining log that tracks:
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Employee names and roles
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Date of retraining
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Topics covered (e.g., changes in the energy control program)
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Training format used
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Results of knowledge checks or observations
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Every workplace has its own equipment, risks, and processes, so LOTO programs should be tailored to reflect those realities. Employee training is a key part of that—to help protect workers from hazardous energy, reduce the chance of accidents, and keep your workplace in compliance with OSHA regulations.
FAQs on LOTO Retraining
Is Lockout/Tagout Training Required Annually?
No, OSHA does not specifically require annual lockout/tagout training for all employees. However, employers must provide retraining when certain conditions occur. For example, a change in job assignment, equipment, energy control procedures, or when unsafe behavior is observed. That said, many employers choose to do yearly refreshers to reinforce safe habits and reduce risk.
Does Lockout/Tagout Training Expire?
Lockout/Tagout training doesn’t have a set expiration date, but its effectiveness can decline over time. OSHA requires retraining whenever an employee’s knowledge or behavior shows that the training is no longer effective. In other words, if someone forgets the steps or a near miss occurs, retraining is no longer optional—it’s required.
How Often Should You Review Your Lockout/Tagout Procedures?
OSHA requires employers to review their energy control procedures at least once every year. This annual inspection should confirm that procedures are being followed correctly and remain effective. Any updates or changes should trigger retraining for authorized employees who are involved.
Is Digital Retraining OSHA-Compliant?
Yes, digital or computer-based retraining can be OSHA-compliant, but only if it meets certain conditions. The training must be interactive, easy to understand, and provide a way for employees to ask questions. For hands-on tasks like applying locks or isolating stored energy, OSHA requires additional in-person or practical instruction.
What Happens If LOTO Retraining Is Neglected?
Neglecting retraining puts employees at serious risk of injury or death due to hazardous energy. It also exposes the employer to OSHA citations, fines, and potential legal action. Beyond compliance, skipping retraining opportunities often leads to unsafe habits, procedural errors, and preventable accidents.