Why Lockout Tagout Rules Still Fail and What Could Fix Them

Key Takeaways

• Despite decades of regulation, lockout/tagout (LOTO) failures continue to cause severe injuries and fatalities, showing the gap between written rules and real-world practice.

• The Control of Hazardous Energy (29 CFR 1910.147) ranked fifth among OSHA’s most cited standards in FY 2024, with 2,655 violations.

• Production pressure, lean staffing, and incentive systems that reward speed over safety often push workers to bypass lockout procedures.

• Many workers lack hands-on LOTO training, and some view certain tasks (like clearing jams) as “too minor” to require lockout, normalizing unsafe shortcuts.

• OSHA estimates proper LOTO could prevent 120 deaths and 50,000 injuries annually. Financially, each serious injury costs about $43,000 and each fatality averages $1.46 million.

On a maintenance shift, a worker slips past the guard to clear a jam. A coworker resets the machine, unaware that anyone is inside. The startup is over in an instant, but the consequences last a lifetime. Case files from the Occupational Safety and Health Administration (OSHA) are full of versions of this story. They even have a term for this: “unexpected startup.” The very scenario that lockout tagout (LOTO) rules were written to eliminate.

But, if the fix is straightforward: de-energize, lock, tag, verify zero energy, why are we still here?

Lockout Tagout in Numbers

A decade after LOTO became shorthand for basic industrial safety, the injuries it is designed to prevent persist. In OSHA’s latest data on the Most Frequently Cited Standards, the Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) ranked fifth among all citations, with 2,655 violations in FY 2024, a higher spot than the year before. That rise underscores how often employers are still failing to meet even the minimum requirements of LOTO.

The citation record aligns with a troubling reality in national safety data. In 2023, the Bureau of Labor Statistics (BLS) recorded 226 deaths in the category “struck, caught, or compressed by running powered equipment.” Within that, 48 deaths occurred during maintenance, cleaning, or testing, which are the precise windows when machines should have been de-energized and verified safe.

Fatalities are the tip of the iceberg. OSHA’s Severe Injury Reports (SIR), which capture inpatient hospitalizations and amputations reported to federal OSHA, show 19,690 severe cases from 2022 to 2023 alone. The leading event type? “Caught in or compressed” injuries, with more than 4,100 incidents. The leading source? Machinery, responsible for more than 4,500 cases.

While no federal system tags these incidents directly as “LOTO failures,” these numbers are evidence that the hazards lockout tagout is designed to control, remain stubborn and deadly.

Why LOTO Failures Continue

LOTO failures persist for reasons that go beyond the limits of the available data. Despite decades of regulation, many workplaces still struggle to align safety procedures with the daily realities of production. The following reasons create an environment where shortcuts often seem more practical than compliance:

Production Pressure

Tight production schedules make downtime costly. Supervisors and workers feel pressure to get machines back online quickly, sometimes at the expense of following lockout steps. In many plants, faster turnaround still earns more praise than careful compliance.

Lean Staffing

With fewer people on the floor, employees are often asked to do more with less. In these conditions, the perceived burden of LOTO, including finding locks, applying tags, and testing for zero energy, feels too slow. Staffing shortages can also mean that trained personnel are not always available to enforce or guide the process.

Incentives for Speed And Output

Many organizations directly or indirectly reward throughput, not procedure. Workers who “get the job done” are celebrated, while those who take extra time for LOTO may be seen as slowing production. The absence of recognition for safe behavior reinforces shortcuts.

Training Gaps and Complexity

Some employees never receive adequate, hands-on LOTO training. Others only receive generic annual refreshers that do not reflect the real equipment in their workplace. Complex procedures or unclear written policies discourage proper compliance.

Perceived Low Risk

Workers may view certain tasks, like clearing jams or quick adjustments, as “too minor” to require a full lockout. When shortcuts save time and go unchallenged, they quickly become normalized as the “real” way things get done. In this environment, employees rationalize bypassing LOTO because the inconvenience feels greater than the perceived risk.

Who’s Getting Hurt—and When?

The maintenance window is a recurring weak point. As mentioned earlier, data revealed there were 48 deaths in 2023 during maintenance, cleaning, or testing on running equipment—moments when control of hazardous energy should be airtight.

That aligns with what safety teams observe: maintenance technicians, machine operators, and electricians interact with energy sources most frequently, and face the greatest harm when lockout steps are skipped, rushed, or missequenced. OSHA’s own materials emphasize that about 3 million workers routinely service equipment and face elevated risk if LOTO isn’t implemented.

Notable case studies:

• • At a sawmill in the southern U.S., repeated neglect of LOTO protocols resulted in multiple fatalities and dozens of serious injuries. In one incident, a night-shift maintenance worker entered a silo to clear a jam without securing the equipment and was fatally struck by moving parts. Despite years of citations for inadequate training and enforcement, the same hazards continue to claim lives.

  • In another case at a large furniture manufacturer in the Midwest, a worker nearing retirement was killed while entering a laminating conveyor that had not been fully locked out. Instead of performing a full lockout, employees had been following a shortcut “alternative” that left some components energized. The practice was known but not consistently enforced. Only after the fatality did the facility update hardware and procedures.

OSHA estimates that proper LOTO prevents approximately 120 fatalities and 50,000 injuries every year. For those injured, the average cost is 24 lost workdays, nearly a month of wages, and recovery. For employers, the numbers scale even higher. The National Safety Council (NSC) calculates U.S. workplace injuries at $176.5 billion in 2023, with each serious case costing around $43,000 and each fatality averaging $1.46 million. For a mid-sized manufacturer, a single severe LOTO-type incident can erase an entire year’s profit margin.

Why the Rules Still Fail in Practice

Even when companies have lockout tagout policies on paper, the reality on the shop floor often looks very different. Workers may rely on shortcuts, skip the critical “try-start” step, or assume someone else has isolated the energy. 

Production pressure makes this worse. No one may explicitly tell employees to skip steps, but when phrases like “let’s get this done” or “we don’t have much time” come from supervisors or coworkers, they can be heard as a green light to rush. When someone is familiar and comfortable with a system, they might think they can “get away” with skipping a step or two. That’s dangerous.

Steven Stogner, a Certified Safety Professional with experience serving various industries, emphasizes to crews during training: 

“Missing a lockout tagout tryout (LOTOTO) step is never worth it because the consequences can be life-altering or fatal.”

For Stogner, the deeper issue is cultural. Too often, we don’t spend enough time explaining the why behind our procedures. If workers don’t understand why the program is written the way it is, they’re more likely to see it as a burden. He argues that involving employees in designing and updating programs changes that dynamic—when they help shape the process, they own it.

Training gaps, he adds, compound the problem. Overly complex checklists or procedures written in isolation make compliance harder than it should be. Stogner highlights the “try” step as one of the most frequently overlooked safeguards. Workers might think isolating a light switch is enough when changing a fixture, but a faulty switch can still leak current. 

“I always remind people: as little as .1 to .2 amps can interfere with the heart’s rhythm. At lower voltages, the body’s natural reaction is to grab onto the source—meaning a small oversight can be fatal.”

According to Stogner, the solution isn’t more paperwork. Effective training must be hands-on, designed for the audience, and led by someone with credibility. Ideally, a peer or seasoned expert who has been in the field, not just a safety officer. Until we address the cultural signals, redesign training, and involve the workforce in building solutions, the rules will keep failing in practice.

What Would Actually Move the Numbers

Reducing LOTO failures requires more than restating rules. It means targeting the weak points where cultural pressure and procedural gaps translate into injuries. Five changes, if widely adopted, would make the greatest difference:

1. 1. Zero-Energy Verification By Design: Designing equipment and procedures so verification is automatic, or at least unavoidable, would cut the temptation to bypass LOTO. Examples include built-in test circuits, interlocks that require a restart attempt before servicing, or sensors that confirm all energy has been discharged. 

   2. Strengthening Oversight and Accountability: Supervisors and contractors must be held to the same standards as production employees. Contractor coordination, in particular, is a weak link; clear responsibility must be assigned so “I thought they locked it out” is not possible.

   3. Job-Built Procedures: Generic lockout steps don’t work in complex plants where each machine has unique hazards. Asset-specific steps, photos of isolation points, and a digital checklist with try-start verification make compliance the path of least resistance.

   4. Maintenance Staffing: This ensures that trained personnel are available to perform lockouts correctly, and that production crews are not forced into tasks they are neither trained nor authorized to do.

   5. Shifting Incentives Toward Safe Performance: Production bonuses and praise often reward speed, not procedure. Recognizing and rewarding teams that follow LOTO, even when it slows output, would begin to counterbalance that bias.

Moving the numbers will take aligning design, enforcement, and incentives so that the safest step is also the fastest and most recognized step.

FAQs on Lockout Tagout Failures

How accurate is the available data on LOTO failures, given under-reporting and gaps in OSHA’s coverage?

Directionally useful, but incomplete. OSHA’s severe injury reports cover only half of the U.S. workforce under federal jurisdiction. State-plan cases are largely absent, and under-reporting is well-documented. Therefore, treat official figures as a floor.

Which industries and sectors show the highest rates of LOTO-related injuries and fatalities?

Heavy, fast-moving, and energy-dense operations dominate. This includes manufacturing & fabrication; energy & utilities; waste, recycling, and materials handling; construction and mining; and agriculture and forestry. Tasks like jam clearing, changeovers, die swaps, and cleaning after short stops drive a disproportionate share of events.

What are some of the common reasons lockout tagout goes wrong?

LOTO failures usually come down to either missed hazards or skipped steps. The biggest trouble spots are hidden energy sources, no “try-start” test, outdated or generic instructions, poor hardware practices, time pressure, and multiple crews at once.

In what ways do incentive systems reward speed over compliance?

Many workplaces unintentionally put a higher price on speed than on safety. Examples:

• • Output-Only Goals: Bonuses tied to uptime or production volumes, with no counterweight for safe practices.

  • Repair Time Targets: Mechanics are praised for fast restarts, not for verified safe restarts.

  • Piece-Rate or Contract Pay: When pay depends on how much gets done, LOTO can feel like “lost time.”

  • Cultural Signals: Supervisors cheer a quick fix, but stay silent when someone takes the full time to lock out properly.

  • Zero-Incident Bonuses: These can backfire by discouraging reporting of near-misses or small mistakes.

The result? Workers get the message that cutting corners is “efficient,” even if it puts them at risk.

How can accountability be strengthened, both for individual workers and for supervisors/contractors?

Accountability can be strengthened in two main ways. First, make roles and verification visible: clearly assign who locks, who verifies, and always require a documented try-start test so that isolation is confirmed, not just assumed. Second, apply consistent standards for everyone: each person uses their own lock and key, and the same rules apply equally to workers, supervisors, and contractors, with fair consequences if anyone bypasses the process. This way, accountability shifts from being about punishment after the fact to building confidence that every lockout really holds.

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