Why Safety Investments Aren’t Stopping LOTO Violations

This is what happens when compliance metrics replace control of hazardous energy as the benchmark for safety.

A maintenance technician crouched beside a hydraulic dock plate in June 2023 at an Omaha-area beef processing plant. When he reached to help guide a pallet, the dock plate unexpectedly energized, crushing his fingertip and ultimately requiring a surgical amputation three weeks later.

Investigators found no lockout/tagout procedures for the hydraulic dock plates and enclosures, despite recent investments in upgraded guards and retraining. OSHA’s follow-up inspection uncovered two willful and 11 serious violations resulting in a $274,569 penalty and showed how “safety on paper” can’t prevent real harm without enforced LOTO protocols.

This incident echoed a troubling trend I’ve observed sweeping American workplaces: lockout/tagout violations surged 29% from 2022 to 2023, despite 68% of manufacturers reporting implementation of "extensive" corporate-wide sustainability strategies. The disconnect between soaring safety investments and persistent violations reveals a deeper crisis in workplace safety culture.

Key Takeaways

• Despite a 68% rise in corporate safety investments and near-universal digital transformation, LOTO violations increased 29% from 2022 to 2023, revealing that technology alone can’t replace worker trust or procedural rigor.
• The most cited LOTO violations (energy control procedures, inadequate training, poor inspections, and inadequate energy control programs) highlight persistent culture gaps that digital tools fail to address.
• Psychological safety is a hidden hazard: workers fear speaking up, leading to underreported near-misses and uncorrected risks, which the ASSP calls “the new slippery floor” of disengagement.
• Companies like MGE and dss+ have reduced LOTO violations by focusing on trust-building, worker feedback, and leadership accountability, proving that cultural transformation drives lasting safety outcomes.

The Paradox: Investments Up, Violations Up

Control of hazardous energy (lockout/tagout) ranked #3 among OSHA's most frequently cited standards in fiscal year 2024, maintaining its position as one of the most persistent safety failures across industries. This comes despite unprecedented investment in safety technology and training programs.

Consider the scale of this paradox:

• OSHA charged businesses $132.3 million for violations of its 10 most cited regulations in 2023, a 30% increase from the year before.
• 98% of surveyed manufacturers have started their digital transformation journey, compared to 78% in 2019.
• Safety spending has increased dramatically, with 68% of executives implementing extensive strategies compared to just 39% in 2019.

Yet OSHA recorded 2,532 LOTO citations from October 2022 to September 2023, resulting in $20,728,257 in penalties across 1,368 inspections. The manufacturing sector bore the brunt of this enforcement wave, with food manufacturing facing 384 violations and $7,495,528 in penalties, followed by fabricated metal products with 377 citations and $1,380,262 in penalties.

"Paper doesn't save people, people save people." — Dan Peterson, Safety Expert

This fundamental truth, articulated by one of the industry's most respected voices, cuts to the heart of the matter. Companies are investing millions in digital dashboards, AI-powered monitoring systems, and predictive analytics platforms. But these technological solutions are failing to address the human element of safety.

The Invisible Barrier: Safety Culture Gaps

When OSHA investigators examine LOTO violations, they consistently uncover patterns that technology alone cannot fix. The data reveals systemic failures in how companies approach safety culture:

The most common violations tell a fundamental disconnect between what companies think they're achieving and what's actually happening on factory floors.

The energy sector faces particular challenges. Despite operating in high-risk environments with potentially catastrophic failure scenarios, academic research shows energy companies remain underrepresented in safety culture studies. A 2024 bibliometric analysis of 7,058 safety culture papers revealed significant geographical and industry gaps, with limited focus on utilities.

ASSP findings call disengagement "the new slippery floor,” a hazard that can't be fixed with better equipment or stricter rules. When workers disengage from safety protocols, they become less likely to report hazards, conduct thorough inspections, or offer improvement suggestions.

Humanizing the Crisis with Workers on the Frontline

The machinery hums to life without warning. A maintenance worker's scream cuts through the factory noise. Another preventable tragedy unfolds, one that will never make headlines but will haunt coworkers for years.

These moments happen in split seconds but stem from months or years of eroded trust, ignored warnings, and normalized deviance. Workers know which machines have quirky safety switches. They know which supervisors prioritize speed over protocols. They know when management's safety speeches ring hollow because production deadlines haven't budged.

The gap between corporate safety initiatives and shop floor reality can be measured in more than violation counts. It's counted in missing fingers, shattered families, and workers who wake up in cold sweats remembering the day everything went wrong. While executives debate return on investment for their latest safety technology, workers face immediate, visceral consequences of systemic failures.

The data below captures this harsh reality, showing not just the rising violation rates that make headlines, but the human toll that rarely gets quantified in corporate presentations:

The Pattern of Preventable Tragedies

While digging through OSHA enforcement records, I came across cases that revealed a pattern. A worker at a manufacturing plant in Ohio lost part of their hand when a power press cycled during maintenance. According to OSHA’s findings, the machine lacked proper safeguarding, and lockout/tagout procedures weren’t enforced. It was a textbook example of a system that existed on paper but failed in practice.

In another case I read, a 27-year-old maintenance employee at a food processing facility was cleaning a rotating roller on a bacon transfer conveyor when his fingertip was caught between the moving roller and a metal bar, resulting in an amputation. The incident occurred because lockout/tagout procedures were not performed during the cleaning process.

These incidents share common threads:

• Workers performing routine maintenance tasks
• Equipment that should have been de-energized
• Safety procedures that existed but weren't followed
• Management awareness of hazards without action

The Psychological Toll

According to Deloitte's research, only 50% of workers report their team leaders create the psychological safety necessary for them to speak up about concerns. This lack of psychological safety creates a vicious cycle:

1. Workers observe safety violations but fear retaliation for reporting.
2. Near-misses go undocumented and unaddressed.
3. Preventable incidents occur, reinforcing workers' belief that management doesn't care.
4. Trust erodes further, making future safety initiatives even less effective.

The manufacturing sector exemplifies this crisis. Despite 92% of surveyed companies believing smart manufacturing will be the main driver for competitiveness over the next three years, human factors remain neglected. While 48% of manufacturers report having smart manufacturing training standards in place, human capital remains at the lowest maturity level of all categories surveyed.

The Executive Disconnect: Digital Doesn't Mean Done

Companies showcase impressive safety investments while missing fundamental human factors. The rush to digitize has created a dangerous illusion of progress. Yet the disconnect persists. While 89% of executives say their organization is advancing human sustainability, only 41% of workers say the same.

This gap between leadership perception and worker reality underlies many safety failures. Companies invest heavily in:

• AI-powered monitoring systems for real-time hazard detection
• IoT sensors tracking equipment status and worker movements
• Digital dashboards displaying safety metrics
• Predictive analytics identifying potential risks

But research reveals critical gaps:

• Just 30% of workers at organizations with human-centered commitments feel "completely" empowered to help achieve safety goals.
• Manufacturing received 1,896 LOTO citations in 2023, a 19% jump from the previous year, despite widespread technology adoption.
• Companies like Pan-O-Gold Baking showed DART rates 160% higher than industry averages despite safety investments.

The irony is undeniable: companies are innovating around the problem rather than addressing its human core.

Resolution: Building Trust Before Tech

Transformation remains possible, but it requires a fundamental shift in approach. Successful companies are discovering that trust, not technology, forms the foundation of effective safety culture.

MGE Energy's Evolution

In 2014, MGE launched a companywide safety initiative establishing a Safety Steering Team made up evenly of exempt and non-exempt employees who meet bimonthly to examine safety topics. Their approach focuses on employee-led initiatives rather than top-down mandates.

dss+ Consulting's Approach

Working with a leading integrated energy company, dss+ identified 10 focus areas to accelerate Process Safety Transformation, engaging working groups from corporate and Operating Companies. Their methodology emphasizes:

• Management of Change reviews for organizational readiness
• Development of "best-in-class Process Safety capability programs"
• Integration across all levels from Executive Leadership to Operators

In their work with Suncor Energy, dss+ helped reduce recordable injuries significantly through their "Journey to Zero" program, which focused on changing culture alongside implementing management systems.

The 3-Part Framework for Real Change

1. Re-engage Workers Through Face-to-Face Feedback

The foundation of safety transformation begins with genuine dialogue. Weekly safety conversations should replace one-way presentations where managers talk and workers pretend to listen. These conversations work best when supervisors ask open-ended questions: "What made your job harder this week?" or "Which procedures don't match how the work actually gets done?"

Anonymous reporting channels need teeth. A guaranteed 48-hour response time creates accountability. Workers quickly learn whether their concerns disappear into a void or spark action.

Recognition systems must shift focus from celebrating accident-free days to rewarding hazard identification. When workers see colleagues recognized for spotting problems rather than hiding them, the culture shifts from covering up near-misses to preventing them. Daily pre-shift huddles that begin with "What could go wrong today?" normalize safety as an operational reality, not a compliance burden.

2. Align Digital Tools with Frontline Reality

Technology succeeds when workers want to use it, not when they're forced to. The selection process should begin with shadowing workers through their actual tasks, understanding where current procedures create friction. Digital solutions must reduce steps, not add them.

Consider lockout procedures: if the digital system requires more time than the paper version, adoption will fail. Successful implementations often start with pilot programs where volunteer teams test systems and provide direct feedback.

Success metrics should focus on voluntary usage patterns. Track how often workers access safety resources without prompting, how many contribute suggestions through digital platforms, and whether near-miss reporting increases. Installation completion rates mean nothing if the system sits unused.

3. Audit Leadership Behavior, Not Just Worker Compliance

Traditional audits count violations. Transformative audits examine leadership actions. How often do executives walk the floor without an entourage? When workers report concerns, how long before they see action? These behavioral metrics predict safety outcomes better than compliance percentages.

Response time to concerns should be tracked like production metrics. A dashboard showing average days to address reported hazards, broken down by department, creates peer pressure among managers.

Culture indicators require careful measurement. Anonymous pulse surveys asking "Would you report a safety concern to your supervisor?" or "Do you believe management values safety over production?" provide leading indicators. When these scores improve, incident rates typically follow. Including these metrics in executive compensation, not just lagging indicators like injury rates, aligns incentives with behaviors that prevent incidents rather than just documenting them.

The Path Forward

The surge in LOTO violations despite massive safety investments exposes an uncomfortable truth: companies cannot purchase their way to safety. The solution doesn't require more dashboards, AI systems, or digital transformations. It requires rebuilding the fundamental trust between workers who face daily hazards and managers who set priorities.

For Safety Professionals

Stop treating workers as the weak link in your safety system. They're your most valuable asset for identifying and preventing hazards. Listen to their concerns, act on their suggestions, and involve them in solution design.

For Engineers

Design systems that enhance human capabilities rather than attempting to eliminate human involvement. The goal is augmentation, not automation. Your technical solutions must work for the people using them, not despite them.

For Executives

Your next safety investment should prioritize building relationships over buying software. Walk the floor. Listen to concerns. Act on feedback. The majority of respondents—86% of workers, 94% of managers, and 95% of the C-Suite—say they could use help to advance human sustainability.

The stakes couldn't be higher. LOTO compliance prevents thousands of fatalities and injuries annually. Each violation represents a potential tragedy, a family shattered, a community mourning a preventable loss.

Until workers believe their safety matters more than production metrics, violations will continue rising regardless of investment levels. For the energy sector, where a single LOTO failure can trigger catastrophic consequences, closing this trust gap isn't simply good business but a moral imperative.

Lives depend on getting this right. The time for action is now.

FAQs

Is lockout/tagout a federal law?

Lockout/tagout (LOTO) is required by OSHA under 29 CFR 1910.147. Although it’s a regulation rather than a statute, it was issued under the Occupational Safety and Health Act and therefore has the force of federal law.

Under what circumstances is LOTO not required?

LOTO isn’t needed if no employee can be exposed to hazardous energy during servicing. It also doesn’t apply to minor tool changes or adjustments that are routine, repetitive, and integral to production when “alternative effective protection” (like a guard) is used. Likewise, unplugged cord-and-plug equipment is exempt if the worker has exclusive control of the plug, and hot-tap operations on pressurized pipelines are allowed when shutdown is impractical and approved procedures and protective equipment are in place.

How are LOTO procedures different for electrical vs. mechanical systems?

For electrical systems, LOTO typically means locking out or tagging the circuit breaker or disconnect, verifying zero voltage, and sometimes applying grounds. For mechanical systems, it means releasing or blocking stored energy, such as bleeding off hydraulic or pneumatic pressure, discharging springs, or inserting blocks to prevent motion. Both require step-by-step energy control procedures, but the methods of isolation depend on the energy source.

Can whistleblower protections improve LOTO safety outcomes?

Yes. OSHA’s Section 11(c) prohibits retaliation against employees who report unsafe conditions, including LOTO violations. Knowing they’re protected, workers are more likely to report problems early, helping prevent uncontrolled-energy incidents.

What are the consequences of violating lockout/tagout procedures?

OSHA can issue a serious or other-than-serious citation with fines up to $16,550 per violation, or up to $165,514 per violation for willful or repeated offenses (effective last January 15, 2025). Beyond fines, violations can cause severe injuries or fatalities, lead to workers’ compensation claims and civil lawsuits, and—in rare, egregious cases—trigger criminal charges if a worker dies. There’s also reputational harm and potential follow-up inspections requiring corrective actions.