Lockout/Tagout Program: What OSHA Actually Requires
A lockout/tagout program (OSHA calls it an energy control program) is required under 29 CFR 1910.147 whenever employees service or maintain machines or equipment that could injure them by starting unexpectedly or releasing stored energy. The program has three required parts: written energy control procedures for each machine, training for authorized and affected employees, and periodic inspections of the procedures at least annually.
The three parts OSHA requires
- ✓ Written energy control procedures: step-by-step instructions for shutting down, isolating, and locking out each machine or type of equipment
- ✓ Training: authorized employees who apply locks, affected employees who work around the equipment, and other employees who need awareness
- ✓ Periodic inspections: an authorized employee reviews each procedure at least annually, watching it performed, and the inspection is certified in writing
What a machine-specific procedure looks like
The most cited gap in LOTO programs is a generic procedure that never names the equipment. A usable procedure covers one machine, or one group of machines with identical energy sources, and walks through the actual steps.
- ✓ The machine and its energy sources: electrical, hydraulic, pneumatic, gravity, stored energy in springs or capacitors
- ✓ Shutdown steps in order, including notifying affected employees
- ✓ Every energy isolating device and where it is: disconnects, valves, blocks
- ✓ Lock and tag placement, one lock per authorized employee
- ✓ How stored or residual energy is relieved, blocked, or bled down
- ✓ Verification: trying the start button before work begins
What about construction sites?
On construction work, 29 CFR 1926.417 requires that circuits be deenergized and tagged before employees work on them. Contractors who service their own equipment (compressors, pumps, conveyors, batch plants) are still expected to follow energy control procedures, and GCs and prequal reviewers routinely ask trade contractors for a written LOTO program regardless of which part applies.
Why downloaded templates get returned
A blank template gives you the headings, not the procedures. Reviewers look for equipment names, energy sources, and steps that match your actual work. A program that says "insert machine here" reads as unfinished, because it is.
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Common questions
▸Do small contractors need a lockout/tagout program?
There is no small-employer exemption in 1910.147. If your employees service or maintain equipment where unexpected startup or stored energy could injure them, you need the program regardless of company size.
▸What is the difference between lockout and tagout?
A lock physically holds the energy isolating device in the safe position. A tag only warns people not to operate it. Tagout alone is allowed only when a device cannot be locked out, and it requires additional protective measures.
▸How often does the program need to be reviewed?
Each energy control procedure must be inspected at least annually by an authorized employee other than the one using the procedure, and the inspection must be certified in writing.
Official sources
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