Why Declining Injury Rates Are Masking a LOTO Compliance Crisis

Key Takeaways

• Non-fatal electrical injuries dropped 21% between 2019–2020 and 2021–2022, yet OSHA Lockout/Tagout (LOTO) citations increased.

• OSHA violations reveal whether safeguards are actually in place and functioning, making them a truer measure of risk.

• Fabricated metals, food processing, and plastics/rubber manufacturing account for the largest share of LOTO violations.

• True safety depends on building habits, systems, and verification practices, not celebrating injury-free streaks.

On a gray Monday in the Midwest, the safety manager at a food plant climbs a step stool and snaps a fresh plastic “3 YEARS INJURY‑FREE” tile onto the marquee by the turnstiles. Two days later, an OSHA compliance officer hands her a packet: multiple violations under 29 CFR 1910.147, the Lockout/Tagout (LOTO) standard. The proposed penalties total $45,000. On the floor, investigators have found defeated interlocks, shared padlocks, and servicing performed without verification of de-energization. No one has been hurt—yet.

So how can a facility be “injury‑free” and dangerously unsafe at the same time?

Injury Rates Down, LOTO Violations Up: The Data

At the same time, the Occupational Safety and Health Administration (OSHA) enforcement tells a different story: In FY2024, Lockout/Tagout (LOTO) was the fifth most-cited standard with about 2,655 violations, a step higher than in FY2023. In other words, inspectors are still finding serious gaps in hazardous‑energy control, just not always seeing the injuries (yet).

Now, these two trends can exist together. Injury counts are lagging indicators that move with production levels, job mix, reporting practices, and luck. Citations are closer to a leading indicator because they reveal whether safeguards are actually in place and used correctly.

"The industry’s celebration of lower injury numbers has encouraged a quiet slide away from verification and discipline. Good statistics have become a comfort blanket, and that comfort is exactly what allows high-consequence errors to take root."

When injuries go down while violations remain high, the safest conclusion is not that the danger has passed, but that the danger is being obscured. In fact, labor advocates have long flagged systemic undercounts of workplace injuries, a context that should make any safety celebration cautious.

What Inspectors Keep Seeing Behind “Injury‑Free” Signs

We combed OSHA standards, interpretations, and case studies to map the most common failure modes inspectors encounter when they walk into plants that boast spotless boards:

1. 1. Skipped Energy Verification: Employers must test and verify that energy isolation is effective before servicing resumes. Skipping the “try/test/verify” step is a recurring and dangerous shortcut.

   2. Defeated or Bypassed Interlocks: Interlocks are not a substitute for LOTO, and bypassing them is a classic precursor to serious harm. OSHA case studies repeatedly illustrate how “minor servicing” exceptions are misread or abused.

   3. Improvised or Shared Devices: Tagout where lockout is feasible, shared locks, and generic procedures not tailored to the machine all show up as top‑cited issues year after year.

Industries With the Most LOTO Citations

Recent OSHA Industry Profile data for the LOTO standard (FY2024 to date) reveal which subsectors are drawing the most citations, and they map closely to the shop‑floor realities you see every day:

These industries are dense with complex machinery, frequent changeovers, and relentless schedule pressure, which create the perfect conditions for shortcuts. Across all three sectors, OSHA frequently finds skipped verification, defeated interlocks, improvised or shared lockout devices, and incomplete procedures.

Why Good Numbers Can Hide Bad Risk

Behind the positive statistics are patterns of behavior and decision-making that point in the opposite direction. To understand why the numbers do not tell the whole story, it helps to look at three underlying drivers of complacency:

Lagging Indicators Invite False Confidence

The 21% decline in nonfatal electrical injuries between 2019 to 2020 and 2021 to 2022 looks encouraging, but it is a lagging measure. Injury counts often fall because of changes in production volume, job mix, or simple good fortune, not necessarily because safeguards are being applied correctly. When leaders point to lower rates as proof of strong control, they can overlook the daily lapses inspectors continue to find. 

Production Tempo Outcompetes Precision

In sectors like food, metals, and plastics, every minute saved on a restart is visible, while every injury avoided is invisible. Teams start favoring quick restarts, informal workarounds, and “minor servicing” habits that skip verification because those choices appear to help output. Over time, shortcuts feel normal, and workers underestimate that proper LOTO procedure is the fastest and most valued way to work.

Role Confusion and Procedural Drift

Lockout/tagout overlaps with general electrical safe work practices (29 CFR 1910.331 to 1910.335) and utility rules (29 CFR 1910.269), which often lead workers to make assumptions about what constitutes “safe enough.” Supervisors and contractors may apply exceptions too broadly or treat interlocks and e-stops as if they were isolated, which they are not. Without simple, practical procedures designed with worker input and reinforced through credible, hands-on training, employees drift toward easier habits that the declining injury numbers fail to reveal.

Human Stakes, Told Through Three Lenses

Behind the data and the citations are real people making judgment calls under pressure. Their experiences show how easy it is for routine practices, cultural signals, and training gaps to shape behavior in ways that statistics alone cannot capture.

The Machinist (Manufacturing/Machining)

• • A veteran operator is proud that his shop has gone years without a lost-time incident. Yet during equipment changeovers, he admits that workers sometimes “save a minute” by skipping the try-start. He knows one malfunction at the wrong time could undo years of spotless records.

The Engineer (Industrial/Electrical/Utilities)

• • An engineer is repeatedly asked whether an interlock and an e-stop can “count” as control methods for minor servicing. She knows the standard and recent OSHA interpretation letters are clear: these are not substitutes for full lockout procedures except in narrowly defined cases. The pressure to allow shortcuts comes from a desire to keep machines running, not from a misunderstanding of the rules.

The Safety Manager & Insurer (Workplace Health/Insurance)

• • A manager takes pride in low incident rates, but the company’s insurer has started asking for periodic inspection records and training logs instead of injury metrics alone. The insurer’s message is clear: risk is measured by the strength of procedures, not the absence of reported harm. That shift forces the manager to rethink what true proof of safety looks like.

What Our Analysis Shows

The celebrated 21% decline in non‑fatal electrical injuries is real, but it coexists with persistent and rising LOTO enforcement. If injury-free streaks truly reflected strong energy-control programs, inspectors would not continue to find widespread failures in basic steps like verification and isolation. The disconnect is especially clear in high-pressure sectors such as fabricated metals, food processing, and plastics, where violations are concentrated.

"What this means for industry leaders is simple: the absence of injuries does not prove the presence of safety. It proves only that luck has held so far."

And luck is not a strategy. To break this cycle, companies must shift focus from celebrating lagging indicators to building the habits, systems, and verification practices that make real safety visible every day.

The Fix: Move from “Injury‑Free” to “Verification‑First”

Redefine Success Metrics

Shift the scoreboard. Stop celebrating “days without injury.” Replace the lobby plaque with a dashboard of leading indicators:

• • % of machine‑specific LOTO procedures validated this month

  • % of jobs with documented try/test/verify

  • % of authorized employees observed performing full LOTO correctly

  • # of near misses captured + corrective actions closed

When proof of control becomes the scorecard, the right behaviors follow.

Make Procedures Practical

Generic one-page lockout procedures do not work for complex systems. Every machine needs its own step-by-step LOTO instructions, written with input from the people who actually use them. Worker involvement not only ensures accuracy but also creates ownership and accountability. At the same time, train supervisors on when 29 CFR 1910.331 to .335 and 29 CFR 1910.269 duties apply, and when “minor servicing” exceptions do not.

Engineer Out the Temptation

The easiest way to prevent unsafe shortcuts is to make the safe way the simplest way. Too often, workers are faced with isolation points that are hidden, poorly labeled, or impossible to lock without improvised tools. Engineering controls can eliminate that friction.

• • Add energy‑isolation hardware that’s easy to lock (lockable disconnects, lockable valves).

  • Use device‑level indicators to support (not replace) lockout tagout devices. For example, permanently installed voltage indicators to inform verification steps.

  • Simplify group LOTO for multi‑craft work to prevent shared locks and control confusion.

Strengthen Oversight and Observation

If you’re in fabricated metals, food processing, or plastics/rubber, benchmark your program against recent OSHA industry‑profile data. Assign qualified observers who can watch the process in real time, identify gaps, and trigger retraining where needed. Supervisors must also listen carefully to their own language, replacing subtle production pressure with clear reinforcement of why every step matters.

A New Scoreboard for Safety

A month after the citations, that Midwest plant’s lobby looks different. The old board is gone. In its place:

“LOTO VERIFIED THIS WEEK: 47 JOBS — 47 VERIFIED”
“MACHINE‑SPECIFIC PROCEDURES REVALIDATED THIS MONTH: 93%”

Output hasn’t slowed, but shortcuts have. Supervisors sign off on verification steps; technicians know audits are routine, not punitive. The manager still counts days, but now she’s counting proof of control, not the absence of luck.

Every company faces the same choice: keep relying on injury statistics as a comfort blanket, or build systems that make proof of control the daily measure of safety. The path forward is not complicated, but it does require commitment. By shifting culture in this way, leaders can protect their people, strengthen compliance, and ensure that when the next inspection or near miss arrives, their safety record reflects more than just luck—it reflects resilience.

FAQs on Rising LOTO Citations

How can a facility be “injury-free” while still being cited for serious LOTO violations?

Because injury counts are lagging indicators, a facility may appear safe simply due to luck or underreporting. OSHA citations expose gaps in hazardous-energy control that have not yet resulted in harm but still pose a serious risk.

Are lower injury rates a true reflection of safer workplaces?

Not always. Declining numbers can reflect changes in production levels, reporting practices, or chance rather than stronger safeguards. True safety is better measured through compliance audits, verification practices, and near-miss data.

What are the requirements for lockout tagout compliance?

OSHA’s 29 CFR 1910.147 requires employers to establish machine-specific procedures, train authorized employees, and verify de-energization before servicing. Compliance also demands periodic inspections and the use of proper lockout devices rather than improvised methods.

What are some of the barriers to performing a LOTO?

Workers often face production pressure, poorly designed or hidden isolation points, and confusing procedures. These barriers make shortcuts seem faster, even though they increase the risk of serious injury.

What cultural changes are needed in management and supervision to reduce the gap between reported safety records and actual risk?

Leaders must shift focus from celebrating “injury-free” streaks to tracking proof of control, such as verified lockouts. Supervisors should reinforce LOTO as the valued way to work, replacing subtle production pressure with visible support for safety discipline.