10 Common OSHA Lockout Tagout Violations and Compliance Solutions

Key Takeaways

• Failure to follow the correct procedures for locking out or tagging out energy sources can lead to severe injuries or fatalities.

• Energy sources such as electrical, mechanical, pneumatic, hydraulic, and chemical must be effectively isolated to prevent accidental energy release.

• Proper employee training is essential to ensure that workers understand the significance of lockout/tagout procedures and are able to correctly implement them.

• 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 lockout/tagout rule in 29 CFR 1910.147 sets minimum requirements for controlling hazardous energy during covered machine or equipment servicing and maintenance in general industry. Section 1910.147 expressly excludes certain work, including construction, agriculture, specified maritime employment, certain electric-utility and electrical hazards, and oil and gas well drilling and servicing. A LOTO violation occurs when an employer’s energy control program, procedures, training, inspections, or work practices do not meet an applicable requirement of the standard.

In OSHA’s fiscal year 2025 Top 10 list, the Control of Hazardous Energy standard ranked fourth among the agency’s most frequently cited standards.

Failures to control hazardous energy can expose employees to unexpected startup or energization and the release of stored energy, which can cause serious injury or death, including electrocution, burns, crushing injuries, and amputations. Compliance with OSHA’s lockout/tagout requirements reduces the risk of unexpected startup or hazardous energy release during servicing. Still, there are details employers miss during LOTO procedures.

The table below connects each common LOTO violation with its principal OSHA provision and the first compliance issue to address. 

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.” The violation was classified as willful. In OSHA enforcement, a willful violation involves intentional disregard of, or plain indifference to, legal requirements.

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?

Energy-control procedures must be specific enough to address the hazardous energy and isolation steps for the machine or equipment being serviced. OSHA permits one procedure to cover similar machines or equipment if it adequately addresses the unexpected-energization hazards for each. A narrow exception from documenting a procedure applies only when all eight conditions in 1910.147(c)(4)(i) are met.

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?

For the application of energy control under 29 CFR 1910.147(d), the sequence includes:

1. Preparing for shutdown

2. Shutting down the machine or equipment

3. Operating the energy-isolating devices

4. Applying locks or tags to the energy-isolating devices

5. Relieving, disconnecting, restraining, or otherwise rendering safe stored or residual energy

6. Verifying that isolation and deenergization have been accomplished

Before the equipment is returned to service under 29 CFR 1910.147(e), the authorized employee must inspect the work area, make sure employees are safely positioned or removed, remove the lockout or tagout devices under the applicable removal rules, and notify affected employees after the devices are removed and before the machine is started. 

What Is the Requirement for Using a Tag by Itself on Equipment That Cannot Be Locked Out?

If an energy-isolating device is not capable of being locked out, the employer’s energy control program must use a tagout system. If the device can be locked out but the employer chooses tagout instead, the employer must demonstrate that the tagout program provides full employee protection equivalent to lockout and use additional safety measures as needed.

4. Failure to Provide Employee Protection During Group LOTO

The group lockout/tagout requirements are found in 29 CFR 1910.147(f)(3). When servicing or maintenance is performed by a crew, craft, department, or other group, the procedure must provide employees protection equivalent to that provided by a personal lockout or tagout device.

What’s required?

Group lockout/tagout must provide each authorized employee with protection equivalent to personal lockout or tagout. A primary authorized employee coordinates the group operation and must be able to determine the exposure status of individual group members. Each authorized employee must apply a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when beginning work and remove it when stopping work.

5. Failure to Establish an Energy Control Program

Employers may fail to establish an energy control program at all, or they may be missing required procedures, training, or periodic inspections. 29 CFR 1910.147(c)(6)(i) requires a periodic inspection of each energy control procedure at least annually to ensure that the procedure and the standard’s requirements are being followed; a document-only review is not sufficient. 

What’s required?

You need an energy control program consisting of energy control procedures, employee training, and periodic inspections. The procedures must be documented unless the narrow exception in 1910.147(c)(4)(i) applies.

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:

• • 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.

  • Affected employees must understand lockout/tagout well enough to know not to interfere with or place themselves in danger.

  • Other employees whose work operations are or may be in an area where energy control procedures may be used must be instructed about the procedure and the prohibition against restarting or reenergizing locked- or tagged-out machines or equipment.
    

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) requires specific procedures during shift or personnel changes to maintain continuous lockout or tagout protection, including an orderly transfer of protection 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?

Under 29 CFR 1910.147(c)(6), the employer must inspect each energy control procedure at least annually to identify and correct deviations or inadequacies. The inspection must be performed by an authorized employee other than the employee or employees using the procedure being inspected, and the employer must certify that the inspection was completed. For lockout procedures, the inspector reviews each authorized employee’s responsibilities with that employee; for tagout procedures, the review includes authorized and affected employees.

How Often Must an Authorized Person Inspect Each Machine's Energy Control Procedures?

Each energy control procedure must be inspected at least annually. OSHA requires the inspection to be performed by an authorized employee other than the employee or employees using the procedure being inspected.

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.

Beyond exchanging procedures, the on-site employer must ensure that its employees understand and comply with the restrictions and prohibitions of the outside employer’s energy-control program.

10. Abusing the “Servicing and Tool Changes” Exception

Paragraph (a) of 29 CFR 1910.147 explains when the lockout/tagout standard applies. It includes a narrow exception for minor tool changes, adjustments, and other minor servicing activities performed during normal production operations. Employers can misuse this exception by applying it to work that does not meet every condition.

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. The exception applies only when the activity:

• is minor;

• takes place during normal production;

• is routine, repetitive, and integral to production; and

• uses alternative measures that provide effective employee protection.

While these common 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 occurs when an employer intentionally disregards an OSHA requirement or acts with plain indifference to employee safety. It carries a substantially higher maximum penalty than a serious violation. Examples of willful violations in lockout/tagout:

1. Knowingly skipping lockout/tagout procedures during machine servicing or maintenance, especially after previous warnings or citations.

2. Continuing unsafe practices even after employee complaints or OSHA inspections have flagged LOTO deficiencies.

3. Directing employees to bypass LOTO procedures to save time or maintain production rates.

For 2026, federal OSHA’s maximum penalty is $16,550 per serious or other-than-serious violation and $165,514 per willful or repeated violation. Failure to correct a cited condition by the abatement date can carry a penalty of up to $16,550 per day beyond the abatement date, generally limited to 30 days. Actual penalties depend on the violation classification and applicable adjustments. 

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

What counts as a lockout/tagout violation?

A lockout/tagout violation occurs when an employer’s energy control program, procedures, training, inspections, devices, or work practices do not meet an applicable requirement of 29 CFR 1910.147. OSHA citations identify the specific provision and condition that failed to comply.

What are the potential risks of not following lockout/tagout procedures?

Improper lockout/tagout can expose employees to unexpected startup, energization, or stored-energy release, resulting in amputations, electrocution, burns, crushing injuries, or fatalities. Employers may also face OSHA citations, current penalties, required abatement, and operational disruption.

Can a supervisor remove another employee’s lock?

A lockout or tagout device generally must be removed by the employee who applied it. Another person may remove it only under the employer’s specific procedure after the employer verifies that the employee is not at the facility, makes all reasonable efforts to contact the employee, and makes sure the employee knows the device was removed before resuming work. A supervisor cannot bypass those safeguards simply because production needs to restart.

What should an employer do if a lockout/tagout violation is discovered?

Stop the affected work if employees may be exposed, correct the immediate hazardous-energy-control failure, and determine why the procedure or work practice broke down. Retraining is required when job assignments, equipment, processes, or procedures change, or when an inspection or other evidence shows that an employee’s knowledge or use of the procedure is inadequate. Document the corrective action and update the procedure or program when the review identifies a gap.

Can temporary employees be subject to Lockout/Tagout requirements?

Yes. Temporary employees must receive the same LOTO protection as permanent employees when their work makes them authorized or affected employees under the standard. The host employer and staffing agency are generally joint employers with shared responsibilities, although the host is usually best positioned to provide site-specific procedures and training.