How Often Does OSHA Require LOTO Retraining?

Under OSHA’s general industry LOTO standard, 29 CFR 1910.147, retraining is not required on a fixed annual schedule. Authorized and affected employees must be retrained when job assignments change; machines, equipment, or processes change in a way that presents a new hazard; energy control procedures change; or a periodic inspection reveals, or the employer otherwise has reason to believe, that an employee’s knowledge or use of the procedure is inadequate. Separate OSHA provisions apply outside 1910.147’s scope.

LOTO training should not be treated as a one-time event because OSHA requires retraining whenever those triggers occur.

In a 2012 enforcement case, OSHA cited Tribe Mediterranean Foods after a contract employee cleaning and sanitizing a hummus-production machine was pulled into the machine and fatally crushed between two rotating augers. OSHA found that the deceased worker and six other workers who cleaned plant machinery had not been trained on hazardous-energy control procedures.

OSHA initially cited the company for 18 alleged violations, including nine willful citations; seven of those willful citations were issued on a per-worker basis for lack of LOTO training. OSHA initially proposed $702,300 in penalties. The inspection was later resolved through a formal settlement with $540,000 in penalties, and OSHA had placed the company in its Severe Violator Enforcement Program.

This case demonstrates the consequences of failing to provide required LOTO training. It does not, by itself, demonstrate a failure to provide retraining; retraining becomes mandatory when the triggers in 29 CFR 1910.147(c)(7)(iii) occur. So, how often is LOTO training required?

Key Takeaways

• Federal OSHA does not set a universal annual schedule for LOTO retraining. Retraining is tied to specified changes or evidence that an employee’s knowledge or use of the energy control procedure is inadequate.
  

• OSHA generally requires each energy control procedure to be inspected at least annually, while retraining remains trigger-based. 
  

• A strong retraining program uses a mix of formats, regular assessments, practical tools, and proper documentation to keep safety efforts consistent and effective.

• Adult learning principles make retraining more effective by keeping it relevant, practical, and interactive to improve retention and engagement.

Is LOTO Retraining Required?

Yes. Under OSHA standard 29 CFR 1910.147(c)(7)(iii), retraining is required for authorized and affected employees when specified changes occur or when the employer has reason to believe there are deviations from, or inadequacies in, an employee’s knowledge or use of the energy control procedures. The retraining must reestablish employee proficiency and introduce new or revised control methods and procedures as necessary.

OSHA also requires the employer to certify that employee training has been completed and is being kept up to date. Under 29 CFR 1910.147(c)(7)(iv), that certification must contain each employee’s name and training dates.

NFPA 70E is a separate consensus standard for electrical safety, not the federal OSHA LOTO regulation. The current 2027 edition requires retraining for employees involved in its electrical lockout/tagout procedures when those procedures are revised, at intervals not to exceed three years, or when supervision or annual inspections indicate noncompliance. That three-year interval should not be applied as the retraining schedule for work governed by OSHA 29 CFR 1910.147.

So, which employees must be retrained? OSHA’s specific retraining provision covers authorized employees who apply lockout or tagout and affected employees who operate or work around the equipment. Other employees whose work may take them into an area where energy control procedures are used must be instructed not to restart or reenergize locked- or tagged-out equipment. The level of training should continue to match the employee’s role and exposure. The table below summarizes what each employee group must know and when OSHA’s retraining provisions apply.

LOTO training requirements by employee role.

When Must Employers Provide Retraining for LOTO?

OSHA requires retraining in four main situations: a change in job assignment; a change in machines, equipment, or processes that presents a new hazard; a change in the energy control procedures; or evidence that an employee’s knowledge or use of those procedures is inadequate.

1. Change in Job Assignment

When an authorized or affected employee’s job assignment changes, the employer must provide the retraining needed for the employee’s new responsibilities. This may involve different machines, hazardous energy sources, or energy control procedures. 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

A change in machines, equipment, or processes requires retraining when it presents a new hazard. Retraining is also required if the change results in a new or revised energy control procedure or changes the employee’s job assignment. It should cover the hazards and the machine-specific procedure the employee will encounter. 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 shutdown sequencing, lockout devices, steps for relieving, disconnecting, restraining, or otherwise rendering stored or residual energy safe, or steps for verifying that the machine or equipment is isolated and deenergized before work begins.

Even when OSHA’s retraining triggers have not occurred, an employer may still use refresher training to reinforce the procedure. That refresher should not introduce shortcuts or alternative measures simply to make servicing more efficient; any revised control method must continue to provide the protection required by the energy control program.

4. Observed Deviations or Unsafe Behavior

If an authorized or affected employee deviates from the energy control procedure, or the employer has reason to believe the employee’s knowledge or use of the procedure is inadequate, retraining is required. An incorrect procedure, skipped step, incident, or near miss can provide that reason, depending on what the review finds. The retraining should correct the identified gap and reestablish proficiency before the employee continues work covered by the procedure.

When Is Retraining in the Lockout/Tagout Process Not Required?

Federal OSHA does not require retraining on a fixed schedule when none of its retraining triggers is present. In general, additional retraining is not triggered when:

• The authorized or affected employee’s job assignment has not changed.

• No change in machines, equipment, or processes presents a new hazard.

• The energy control procedures have not changed.

• The employer has no reason to believe the employee is deviating from, or lacks adequate knowledge or use of, the procedures.

Retraining may be trigger-based, but OSHA generally requires each energy control procedure to be inspected at least annually. OSHA has stated that a procedure used less frequently than once a year needs to be inspected only when it is used. Under 29 CFR 1910.147(c)(6), the periodic inspection must be performed by an authorized employee other than the employee using the procedure being inspected. The inspection checks that the procedure and the standard’s requirements are being followed and can reveal deficiencies that require retraining. Regular LOTO audits and work observations can help identify those issues before an incident occurs.

The visual below shows how the annual inspection requirement connects to trigger-based retraining without making retraining an automatic annual requirement.

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:

1. 1. In-person classroom sessions for hands-on learning and Q&A

   2. eLearning modules for flexibility and easy tracking

   3. Short video tutorials for quick refreshers or toolbox talks

Pick the format that best suits the size of your team, the complexity of your equipment, and the types of hazardous energy sources involved.

Computer-based training can support a LOTO training program, but the format still has to provide the knowledge and skills employees need for their assigned roles. Employees should have a way to ask questions and receive answers, and authorized employees should be able to demonstrate that they can apply the machine-specific energy control procedure correctly. Online content alone is not enough if it does not prepare employees to perform their responsibilities safely.

2. Assess Employee Understanding: Use role-appropriate checks to verify understanding. For authorized employees, use hands-on demonstrations or other checks that confirm they have acquired the knowledge and skills needed to safely apply the relevant energy control procedure. For affected employees, confirm understanding of the purpose and use of the procedure. For other employees, confirm understanding of the procedure and the prohibition against restarting or reenergizing locked- or tagged-out equipment. Use practical, job-relevant examples to reinforce the training.

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: OSHA requires the employer to certify that training has been completed and is being kept up to date. At minimum, the certification must include each employee’s name and training date. A more detailed retraining log can also help manage the program and document why retraining occurred. Consider recording:

• Employee name and role

• Retraining date

• Reason for retraining

• Topics or procedures covered

• Training format used

• Results of knowledge checks or practical demonstrations

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. Federal OSHA does not require annual LOTO retraining for every employee. Retraining is required when a covered change occurs or when the employer has reason to believe an authorized or affected employee’s knowledge or use of the energy control procedure is inadequate; the separate annual requirement applies to periodic inspection of each energy control procedure.

Does Lockout/Tagout Training Expire?

Federal OSHA does not give LOTO training a fixed expiration date. Retraining becomes mandatory when one of the conditions in 29 CFR 1910.147(c)(7)(iii) occurs. This includes specified changes and situations in which the employer has reason to believe an employee’s knowledge or use of the procedure is inadequate.

How Often Should You Review Your Lockout/Tagout Procedures?

OSHA generally requires each energy control procedure to be inspected at least annually. The periodic inspection must be performed by an authorized employee other than the employee using the procedure being inspected. If the inspection reveals deviations or inadequacies in an employee’s knowledge or use of the procedure, the employer must provide retraining.

Is Digital Retraining OSHA-Compliant?

Digital retraining can be one component of a compliant training program, but OSHA has stated generally that online-only training is insufficient when it lacks timely access to a qualified trainer and necessary hands-on components. For LOTO, the employer still must ensure employees acquire the knowledge and skills required by 29 CFR 1910.147(c)(7), including the skills authorized employees need to safely perform the applicable energy control procedures.

What Happens If LOTO Retraining Is Neglected?

Failing to provide required retraining can leave employees using outdated or misunderstood energy control procedures. That gap can expose workers to unexpected energization, startup, or the release of stored energy and can result in an OSHA citation. Retraining should address the specific change, deviation, or knowledge gap that triggered it.