Key Takeaways
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Failure to follow the correct procedures for locking out or tagging out energy sources can lead to severe injuries or fatalities.
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Energy sources such as electrical, mechanical, pneumatic, hydraulic, and chemical must be effectively isolated to prevent accidental energy release.
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Proper employee training is essential to ensure that workers understand the significance of lockout/tagout procedures and are able to correctly implement them.
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Regular lockout tagout audits and inspections help reduce the likelihood of LOTO violations and keep energy control systems effective.
What Is the Lock Out Tag Out Rule?
The lock out tag out rule, established by the Occupational Safety and Health Administration (OSHA) in 29 CFR 1910.147, outlines procedures for controlling hazardous energy during equipment or machine maintenance and servicing to prevent accidental energy release. In 2023, the Control of Hazardous Energy (Lockout/Tagout) was among the most frequently cited OSHA standards, with a total of 2,554 cases.
These violations often lead to dangerous incidents involving the unexpected startup and cycling of a machine or process, energization of equipment, or the release of stored energy, resulting in serious injuries such as amputations, burns, and other physical harm.
Fortunately for employers, when you comply with the OSHA lock out tag out rules, your employees are probably safe—and if they are safe, you’re probably in compliance with the standard. Still, there are things employers miss during LOTO procedures. Take a moment to review your lockout/tagout program and make sure that you’re not making one of these common lockout/tagout compliance violations.
1. Failure to Identify and/or Lockout All Hazardous Energy Sources
This violation is part of the "Fatal Five" in LOTO safety, referring to the five most serious hazards that lead to fatal accidents or severe injuries when LOTO procedures are not properly followed. If an employer’s lockout/tagout procedures are not specific or detailed enough, the employer may be cited under one of several sections for failing to identify and neutralize all energy sources or disconnects.
For example, a poultry processing facility in Pennsylvania was cited for not fully addressing all hazardous energy sources at the facility through its lockout/tagout procedures. In reviewing the case, the administrative law judge found the meat products facility's lockout program “failed to provide enough information to permit employees to lock out the machines.” This failure led to the violation being classified as "willful," indicating that the company knew or should have known about the requirements but neglected to implement appropriate procedures.
What’s required?
“Energy sources,” according to 29 CFR 1910.147(b), include any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy.
2. Failure to Have Equipment-Specific Lockout/Tagout Procedures
This requirement, found at 29 CFR 1910.147(c)(4)(i), was the most commonly cited section of the lockout/tagout standard in 2019. Employers sometimes keep a “generic” lockout/tagout procedure on file. That’s a violation—as the poultry processing facility learned the hard way. The meat products manufacturer had four different types of machines, but only one generic lockout/tagout procedure. The Occupational Safety and Health Review Commission (OSHRC) upheld a willful citation against the facility.
What’s required?
Machines, processes, or pieces of equipment that could create a hazard during servicing or maintenance if they start up or cycle unexpectedly or release stored energy must have a specific, written lockout/tagout procedure. The procedure must address how to control each type of hazardous energy associated with the machine and enable a worker to safely lock out those power sources.
3. Failure to Follow the Sequence of Lockout/Tagout
Written procedures often fail to include one or more of the required steps, and sometimes, employers fail to ensure that workers follow these steps. For example, an automotive glass manufacturer in Ohio was cited for multiple, repeated instances of failing to require workers to follow the sequence and slapped with a proposed penalty of almost $73,000.
What’s required?
29 CFR 1910.147(d) specifies a very detailed and structured sequence to isolate energy sources. Your written lockout/tagout procedure must proceed stepwise through certain elements, including:
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Preparation for shutdown
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Specific shutdown procedures
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Application of energy-isolating devices
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Procedures for release or restraint of stored energy
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Verification of isolation
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Release from lockout or tagout
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Removal of lockout/tagout devices
Workers must follow these steps whenever performing lockout/tagout operations. If any step in the sequence is skipped or not properly executed, there is a heightened risk of exposure to energy that could result in serious injuries.
What Is the Requirement for Using a Tag by Itself on Equipment That Cannot Be Locked Out?
The requirement for using a tag by itself on equipment that cannot be locked out is outlined in the 29 CFR 1910.147(c)(2)(i). It states that “In situations where energy-isolating devices cannot be locked out, a tagout procedure may be used as an alternative.” However, the employer must demonstrate that the tag will ensure equivalent employee protection.
4. Failure to Provide Employee Protection During Group LOTO
The rules for group lockout/tagout, found in 29 CFR 1910.147(c)(4)(i), sometimes trip employers up. A fabricated steel products manufacturer in Oxford, Alabama, was cited under this provision after two employees removed a motor without following written energy control procedures. OSHA classified the violation as serious, with a proposed penalty of $9,523.
What’s required?
Even if full group lockout/tagout procedures under 29 CFR 1910.147(f)(3) aren’t triggered, employers must still protect every employee involved in servicing equipment. Under § 1910.147(c)(4)(i), this means having clear, written energy control procedures—and making sure workers follow them. When multiple employees are involved, each one must be fully protected through coordinated lockout practices.
5. Failure to Establish an Energy Control Program
This requirement, found in 29 CFR 1910.147(c)(1), was the fourth most cited section of the lockout/tagout standard in 2019. Employers may fail to create a written lockout/tagout program at all, or they may be missing specific elements of the program. Unlike other OSHA written programs, there is no requirement to review the written lockout/tagout program annually, but a periodic review of each written lockout/tagout procedure is required under 29 CFR 1910.147(c)(6)(i).
What’s required?
You need a written program that covers your energy control procedures, training, and periodic inspections.
6. Failure to Train Workers in Lockout/Tagout
Employers may fail to provide training at all, or they may provide training that is too general. A cookie dough manufacturer in Eau Claire, Wisconsin, was fined $782,526 and placed in OSHA’s Severe Violator Enforcement Program for failing to properly train authorized and affected employees in lockout/tagout. The company had been cited for similar violations in a previous OSHA inspection, but failed to implement its own safety procedures.
What’s required?
According to 29 CFR 1910.147(c)(7), employers are required to train workers in the purpose and function of the lockout/tagout program and to ensure that they have the knowledge and skills they need. Employees fall into three different categories for training:
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Authorized employees must be able to recognize the types of hazardous energy sources that exist in the workplace and know how to isolate and control them.
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Affected employees must understand lockout/tagout well enough to know not to interfere with or place themselves in danger.
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All other employees must have a basic understanding of lockout/tagout, and the importance of not attempting to restart or reenergize disabled machinery.
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7. Failure to Manage Shift Change
The rules for group lockout/tagout are a frequent pain point. Employers may fail to anticipate that a lockout/tagout operation could extend beyond a single shift. Or, workers may simply leave the equipment locked out of service at the end of a shift, creating confusion and leading to the unauthorized removal of locks or tags.
What’s required?
29 CFR 1910.147(f)(4) states that if there is a personnel change during lockout/tagout, employers must have specific procedures in place to ensure that there is an orderly transfer of locks and tags between outgoing and incoming employees.
8. Failure to Conduct Periodic Inspections
When it appealed its citation for failing to perform periodic inspections, the poultry processing facility I mentioned initially tried to argue that its written lockout/tagout program had been updated within the previous year. According to the judge, the meat products manufacturer misconstrued the standard as “requiring only a review of the written procedures.”
Meanwhile, the employer at the automotive glass manufacturing company in Ohio failed to ensure that the inspector reviewed the procedure with each authorized employee. Failure to conduct periodic inspections was the third most cited section of the lockout/tagout standard in 2019.
What’s required?
Found in 29 CFR 1910.147(c)(6), the requirement states that for each energy control procedure that is used in your workplace, you must conduct an annual inspection of the procedure while it is being performed to identify any deviations from the procedure or inadequacies in the procedure. The inspector must be an authorized employee who is not part of the lockout/tagout being performed. As part of the inspection, the inspector must review each participating employee’s responsibilities with that employee.
How Often Must an Authorized Person Inspect Each Machine's Energy Control Procedures?
According to the OSHA lockout tagout requirements, an authorized person must inspect each machine’s energy control procedures at least once per year. Regular annual inspections are essential to maintaining compliance and keeping control of hazardous energy, especially in high-risk environments.
9. Failure to Notify Other Employers
This requirement, found in 29 CFR 1910.147(f)(2), applies when multiple employers or contractors are working on the same site. Unfortunately, sometimes employers simply don’t let one another know what’s going on.
This was the case with the freight elevator products and services company, which was cited after a mechanic was injured during elevator maintenance at a department store in Brookfield, Wisconsin. The investigation revealed that the company had failed to inform Boston Store of its lockout/tagout procedures.
What’s required?
When outside employers, such as contractors, perform lockout/tagout activities at a worksite, both parties must inform each other of their respective lockout/tagout procedures.
Safety experts emphasize that all employers or contractors should be notified before the lockout/tagout procedures begin to ensure that all involved parties are aware of the specific energy sources being isolated, when the work will begin, and the safety procedures in place. Preemptive notifications allow everyone to coordinate schedules and work practices more efficiently.
10. Abusing the “Servicing and Tool Changes” Exception
Paragraph (a) of 29 CFR 1910.147 specifies when the lockout/tagout standard applies, but it includes an exception, at 1910.147(a)(2)(ii)(B), for minor tool changes and adjustments and other minor servicing activities.
Unfortunately, some employers have made the mistake of trying to use this exception for servicing and maintenance activities that are not part of normal production operations. At other times, employers and OSHA have differed over what constitutes “routine, repetitive, and integral” or what alternative measures provide “effective protection” as required by the exception.
What’s required?
The Lockout/Tagout standard applies to normal production operations if employees must bypass a guard or other safety device, or place any part of their body into a danger zone. There is an exception for minor tool changes that applies only if the activity:
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is minor;
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takes place during normal production;
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is routine, repetitive, and integral to production, and
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alternative methods (to lockout/tagout) are used to protect employees.
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Some argue that the exception can create safety discrepancies across industries, as it might be applied differently in various environments. Some industries, such as heavy manufacturing or construction, may involve more complex machinery and tasks that should not be considered "minor" despite their repetitive nature. Critics argue that the broad applicability of the exception leads to a lack of consistent safety practices.
While the Top 10 Lockout/Tagout violations highlight specific procedural breakdowns, it’s also critical to understand the severity levels OSHA assigns to violations, particularly willful violations, which carry the most serious consequences.
What Is Considered a Willful Violation Under Lockout/Tagout Standards?
A willful violation under the lockout/tagout standard occurs when an employer intentionally disregards the requirements of the standard or shows plain indifference to worker safety. It is the most serious type of OSHA violation and carries the highest penalties. Examples of willful violations in lockout/tagout:
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Knowingly skipping lockout/tagout procedures during machine servicing or maintenance, especially after previous warnings or citations.
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Continuing unsafe practices even after employee complaints or OSHA inspections have flagged LOTO deficiencies.
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Directing employees to bypass LOTO procedures to save time or maintain production rates.
As of 2024, OSHA can issue penalties of up to $161,323 per willful violation, and in extreme cases involving fatalities, criminal charges may also apply. Preventing violations—especially willful ones—starts with a clearly defined and properly executed Lockout/Tagout procedure.
What Is the Correct Procedure for Lock Out Tag Out?
The correct lockout tagout procedure involves isolating all hazardous energy sources, applying lockout devices, and verifying energy control. Following a correct procedure significantly reduces the risk of violating OSHA lock out tag out rules and ensures that all steps are consistently applied. However, employers must also maintain documentation, conduct periodic inspections, and update procedures as needed to stay fully compliant and avoid LOTO violations.
FAQs about LOTO Violations
Why is controlling hazardous energy sources important?
Controlling hazardous energy is essential to prevent the unexpected activation of machines or equipment, or energy release during maintenance, which can cause serious injuries such as amputations or electrocution. Proper energy control protects employees by keeping equipment in a safe state during servicing.
What are the potential risks of not following lockout/tagout procedures?
Failure to follow lockout/tagout procedures can lead to severe injuries, fatalities, equipment damage, and costly LOTO violations. It also exposes employers to OSHA citations and legal consequences.
What should an employer do if a lockout/tagout violation is discovered?
The employer should immediately stop all affected work, correct the issue, and review the energy control program for gaps. They must retrain involved workers and conduct a documented inspection to confirm compliance with the OSHA lockout tagout standard.
What must employers do to protect workers?
Employers must develop and enforce an energy control program, provide training, supply proper lockout devices, and conduct regular inspections. These actions are required to meet lockout tagout requirements and protect workers from hazardous energy.
Can temporary employees be subject to Lockout/Tagout requirements?
Yes, temporary employees are subject to Lockout/Tagout requirements if they are involved in servicing or maintenance activities where exposure to hazardous energy is possible. Under the OSHA lockout tagout standard, host employers are responsible for ensuring that all workers receive proper training, follow energy control procedures, and are protected during LOTO operations.