Summary of the 1910.147 Standard: The Control of Hazardous Energy

Key Takeaways

• The OSHA lockout tagout standard, or control of hazardous energy, applies to any industry where servicing and maintenance expose workers to hazardous energy sources.

• There are some states that enforce their own lockout tagout rules, which may be stricter than federal OSHA standards.

• OSHA requires that lockout and tagout devices be identifiable, durable, standardized, substantial, and utilized exclusively for controlling energy.

• There are certain industries that follow specialized LOTO rules based on unique energy hazards and operational risks.

What is the OSHA 1910 Regulation?

The OSHA 1910 Regulation is a massive section of federal regulations established by the Occupational Safety and Health Administration (OSHA) for employee protection from hazards and applies to General Industry. Before OSHA, no federal laws required employers to provide safe working conditions. With over 14,000 workplace fatalities and nearly 2.5 million disabling injuries occurring annually, Congress passed the Occupational Safety and Health Act (OSH Act) in 1970.

The 1910 OSHA regulations became the foundation of general industry safety standards, covering a wide range of safety topics, including machine guarding, hazardous materials, fall protection, and, of course, the Control of Hazardous Energy (Lockout/Tagout) under 1910.147.

What Is the Scope of 29 CFR 1910.147?

The 29 CFR 1910.147 Standard applies to workplaces where employees service or maintain machines that could unexpectedly start up or release stored energy. It is designed to prevent injuries caused by hazardous energy sources such as electricity, mechanical parts, hydraulic systems, pneumatic energy, thermal energy, pressurized systems, and other stores or residual energy. 

This regulation is mandatory for employers in the General Industry and covers any machine, equipment, or system that requires energy isolation during maintenance or repair work. The standard does not apply to construction, agriculture, or maritime industries, but those sectors have their own lockout/tagout regulations.

Where Does This OSHA Lockout/Tagout Standard Apply?

The OSHA LOTO standard is enforced in General Industry workplaces where machinery or equipment has the potential to cause injury if it unexpectedly starts up. At its core, the General Industry regulations cover a broad range of industries in the US, and US Territories but do not cover federal employee workplaces (For further information regarding applicability, visit osha.com). Some of the most common industries where the LOTO standard include:

• • Manufacturing: Assembly lines, processing plants, and industrial machinery that require strict lockout tagout requirements to protect employees during maintenance activities.

  • Warehousing and Logistics: Conveyor systems, automated sorting machines, and loading equipment may retain stored energy even when powered off.

  • Utilities and Energy Production: Power plants, substations, and water treatment facilities use high-voltage systems and pressurized equipment that require energy control programs.

  • Hydrocarbons, Chemical, and Oil Refining: Reactors, compressors, boilers, turbines, columns, and piping systems must implement LOTO standards. 

  • Healthcare: Medical device servicing, hospital equipment maintenance, and sterilization systems fall under LOTO requirements.

  • Food Processing: High-speed packaging, slicing, and refrigeration systems often require controlled energy isolation.

While OSHA sets the baseline, some states run their own occupational safety lockout programs (like Cal/OSHA in California), which may have stricter LOTO requirements. 

There are also instances where OSHA does not require full lockout/tagout procedures. For example, cord-and-plug equipment can be exempt if an employee unplugs the equipment and maintains exclusive control of the plug. Hot tap operations and work on a pipeline, steam, or gas system where LOTO is impractical and would create additional hazards are also exempt, provided specific conditions are met and risk assessments demonstrate other safe work practices are acceptable. 

Lockout Tagout Definition

Simply put, lockout/tagout is a safety procedure designed to control hazardous energy during servicing and maintenance of machines or equipment. Lockout devices, such as breaker locks, valve locks, locking hasps, or flange locks are physical locks that prevent machinery from being re-energized or opened to cause energy to be released. Meanwhile, tagout devices are warning labels attached to energy sources that indicate the machine is being serviced and should not be powered on.

Before we explore the 1910.147 standard further, let's define some other key terms:

Which Government Entity Establishes the Requirements for Lockout/Tagout?

The Occupational Safety and Health Administration (OSHA) sets the lockout tagout requirements under the Department of Labor. Specifically, 29 CFR 1910.147 details how employers must protect workers. If a company ignores it, they risk serious OSHA fines, or worse, accidents, disabling injuries, and fatalities. 

What Is an Energy Control Program?

An Energy Control Program (ECP) is a mandatory safety program under OSHA 1910.147 standard. It defines the processes, procedures, and responsibilities for controlling hazardous energy during machine servicing and maintenance. Failure to have an ECP in place may result in OSHA citations, fines, and potential liability if an accident occurs due to hazardous energy exposure.

Common Lockout Tagout Violations

Companies often receive OSHA citations for failing to follow lockout tagout requirements under their Energy Control Program. Common violations include:

1. Lack of written energy control procedures

2. Failure to train employees on proper LOTO procedures

3. Not performing annual inspections of lockout/tagout procedures

4. Using incorrect or missing lockout/tagout devices

5. Failing to verify zero energy state before servicing

OSHA penalties for LOTO violations can be severe, with fines exceeding $15,000 per violation (and much higher for repeat offenses).

What Are the Key Elements of an Energy Control Procedure?

The lockout tagout standard requires employers to develop machine-specific energy control procedures for the effective control of hazardous energy. A proper energy control procedure must include the following key elements:

• • Statement of intended use of the procedure

  • Specific procedural steps for shutting down, isolating, blocking, and securing equipment

  • Specific procedural steps for the placement, removal, and transfer of lockout/tagout devices and assigned responsibilities

  • Specific requirements for testing the equipment to verify the effectiveness of energy control measures

In my experience, I can say that the most effective strategy to improve an energy control program is a continuous improvement approach, combining clear procedures, frequent audits, and technology integration. Engaging workers in safety enhancements and making procedures practical and accessible will significantly reduce inefficiencies while ensuring compliance. In addition, effective training is crucial to any LOTO program. Typically, training conducted in person by senior employees that have experience using the LOTO procedures are the best instructors for effective training results.

Who Should Be Involved in the Lockout/Tagout Process?

The lockout/tagout process involves three groups of employees: authorized employees, affected employees, and other employees. The authorized employee is the person who is specifically trained and designated to perform the maintenance or repair work on the locked-out equipment. As you can see in the image, they are the only ones with the authority to remove the lock and tag and give the all-clear signal. They are truly “authorized” through training and competency by the employer. 

The affected employee would be the machine operator or anyone else whose job requires them to work with, around, or on the equipment. Once the lockout tagout procedure is in place, the operator's control over the equipment is temporarily suspended, and they must defer to the authority of the authorized employee until the work is completed and the machine is declared safe to operate again. Meanwhile, the other employees are workers who may work in the same area as locked-out equipment but are not directly involved in operating or servicing it.

Who Performs the Required Periodic Inspection of Energy Control Procedures?

A trained authorized employee who is NOT the one performing the lockout must inspect procedures. This employee must have knowledge of the energy control program and be capable of identifying deficiencies or non-compliance. The purpose of the inspection is to ensure that LOTO procedures are being followed correctly, that employees understand their roles, and that any necessary updates or corrections are made to improve safety and compliance.

What Are the Requirements for Lockout/Tagout Devices?

To properly isolate energy sources, the standard outlines five key characteristics that LOTO devices, like padlocks, tags, and hasps must have:

1. Durable: Must withstand workplace conditions without becoming damaged or ineffective.

2. Standardized: Must have a consistent color, shape, or size across the workplace so that they are easily recognizable as lockout tagout devices.

3. Substantial: Must be strong enough to prevent removal without special tools or excessive force.

4. Identifiable: Must clearly communicate that the equipment is locked out and should not be operated.

5. Exclusive for Lockout Tagout Use: Must be used only for energy control purposes and not for any other reason (such as locking toolboxes or securing doors). 

One of the biggest mistakes I’ve seen in the companies I’ve worked for is management choosing cheap plastic padlocks that can be snapped off by hand or thin zip ties for tagout devices that workers could remove and reattach without anyone noticing. These decisions were always made to save money, but they put workers at serious risk.

Therefore, it is important to select lockout tagout devices that meet the OSHA requirements, especially when it comes to durability, keeping in mind the lock material of construction for certain industries where environmental conditions may be harsh. 

What Are the Training and Communication Requirements?

OSHA 1910.147 requires a robust training and communication program for lockout tagout. All three employee groups must know their part: authorized employees need in-depth knowledge to perform lockouts safely​, affected and other employees need awareness to stay safe and not interfere​. 

Additionally, employers must communicate procedures clearly through written plans, tags or signs, and notifications, and reinforce that communication with effective training. The standard also requires lockout tagout retraining for all authorized and affected employees whenever conditions change or if understanding falls short​. 

Control of Hazardous Energy in Different Industries

Certain industries may have unique energy sources or hazards that are not fully addressed by the overarching regulation. To ensure worker safety in these specific sectors, OSHA developed additional, industry-specific requirements. These requirements aim to supplement the general rule by providing targeted guidance and procedures for controlling hazardous energy sources:

Pulp & Paper Mills (1910.261)

• • Requires padlocks or equivalent devices to lock out main power disconnect switches and valves before maintenance or servicing.

  • All energy sources (electrical, mechanical, hydraulic, material flow) must be isolated and locked or blocked (e.g., using padlocks or blank flanges) before employees enter or work near equipment.

Electric Power Generation/Transmission (1910.269)

• • Employers must establish a hazardous energy control program for power generation equipment and distribution lines.

  • Clearance procedures must be followed when de-energizing and tagging out transmission lines, with a designated employee overseeing the process.

Marine Terminals & Longshoring (1917.48 & 1918.64)

• • Requires energy isolation for conveyors at docks, terminals, and ships.

  • Disconnect switches must be locked in the OFF position and tagged to prevent unintentional restart.

  • Unlike other industries, a full written program may not be required, but employers must enforce lockout/tagout procedures, including padlocks and “Do Not Start” tags.

Process Safety Management of Highly Hazardous Chemicals (1926.64)

• • Energy control is integrated into mechanical integrity, operating procedures, energy isolation, and emergency planning.

  • Covers chemical reactions, pressure systems, and emergency shutdowns, not just electrical or mechanical lockout.

Electrical Circuit Lockout/Tagout (1926.417)

• • All deenergized circuits and equipment must be rendered inoperative, with tags attached at potential energy sources.

  • Though padlocks are not explicitly required, the standard implies using physical disconnection or locks to prevent reactivation.

  • Requires “Do Not Energize” tags on circuit breakers and switches, aligning with NFPA 70E electrical safety practices.

Concrete & Masonry Equipment (1926.702)

• • Workers cannot perform maintenance or repairs unless all hazardous energy sources are locked out and tagged.

  • Prohibits entry into bulk material storage units (silos/bins) unless ejection systems are fully shut down, locked out, and tagged to prevent material flow.

Food Manufacturing Industry

The control of hazardous energy in the food manufacturing industry adheres to the general industry lockout tagout rule. However, due to the diverse and complex equipment used in food processing, standard LOTO protocols may need to be tailored to address specific energy control challenges. For example, the packaging machines in a food processing plant ran at high speeds and had complex control systems. To keep maintenance and servicing safe, we customized the LOTO procedure with specific shutdown steps that isolated both mechanical and control system energy sources, making sure all moving parts were fully secured.

FAQs on 29 CFR 1910.147

When was OSHA Standard 29 CFR 1910 created?

OSHA established 29 CFR 1910 in 1971 as part of the Occupational Safety and Health Act of 1970, with various subparts added and updated over time. The Lockout/Tagout standard (1910.147) was specifically issued in 1989.

What is the formal name for OSHA’s lockout/tagout standard?

The formal name is "The Control of Hazardous Energy (Lockout/Tagout)" under 29 CFR 1910.147.

What does OSHA standard 1910.147 regulate?

It regulates the control of hazardous energy during the servicing and maintenance of machines and equipment to prevent unexpected startup or release of stored energy.

What is the difference between lockout and tagout?

Lockout involves placing a physical lock on an energy-isolating device to prevent operation, while Tagout uses warning tags to indicate that the equipment should not be operated, but it does not provide a physical barrier.

Does OSHA 1910.147 apply to construction?

No, OSHA 1910.147 applies to general industry, while lockout/tagout requirements for construction are covered under 29 CFR 1926.417 under Subpart K Electrical.