Your Guide to OSHA Lockout/Tagout Rules: Preventing Deadly Accidents

The consequences of violating the government’s lockout/tagout rules for manufacturers and machine shops can be harsh: fines, lost productivity and costly health insurance claims.

For workers, the situation is even more dire: Exposure to uncontrolled energy that lockout/tagout policies are meant to prevent is often debilitating and even deadly.

Despite the grim repercussions, the number of citations for violating the rules in U.S. Occupational Safety and Health Administration Standard 1910.147 climbed again during the 2024 fiscal year, which runs from Oct. 1 through Sept. 30, reaching at least 2,676.

That marks a 5 percent increase from the previous year, underscoring the importance of constant vigilance. The system requires “action by people to be effective,” an article in the American Society of Safety Professionals monthly journal, Professional Safety, explains.

“For that reason, lockout is subject to human error,” the article says. “Consider, for example, a machine that requires seven points of lockout. Despite proper training and the use of machine-specific procedures, the fact remains that a person may inadvertently fail to lock out one of the points, thus presenting a risk of injury.”

High-Tech LOTO

That’s a factor OSHA considered when it began gathering information five years ago about whether its lockout/tagout policy should be updated to include control-circuit devices and robotics, though the agency has yet to issue a draft regulation, a key step in the federal rulemaking process.

While lockout and tagout sound virtually interchangeable, there’s a significant difference between the two, according to Safety Culture, a technology firm that helps businesses improve operational safety. A lockout device stops operation of a piece of equipment, while a tagout device informs workers that it shouldn’t be used.

Employers’ Lockout/Tagout Responsibilities

Among the most important components of OSHA’s lockout/tagout rule, the agency says, are requirements to:

• Establish and enforce an energy-control program and procedures.
• Use lockout devices for equipment that can be locked out. Tagout devices may be used instead only if they provide protection equivalent to a lockout.
• Make sure new or overhauled equipment can be locked out.
• Use only lockout/tagout devices authorized for particular pieces of equipment or machinery and ensure they’re durable, standardized and substantial.
• Set a policy that permits only the worker who applied a lockout/tagout device to remove it.
• Inspect energy control procedures at least once a year.
• Provide effective training for all workers covered by the OSHA standard.
• Comply with OSHA’s additional energy-control requirements for situations when machines must be tested or repositioned, outside contractors work at a site, group lockouts are required and shift and personnel changes occur.

Overall, OSHA’s lockout/tagout rule ranked fifth among the standards for which the agency issued the most citations in the year ending in September 2024. According to an analysis by the National Safety Council, individual requirements violated most often were:

• Developing, documenting and enforcing energy control procedures: 738 violations.
• Communicating LOTO procedures to workers and training them in compliance: 477 violations.
• Periodic inspection to correct any deviations: 377 violations.

Overall, OSHA charged $21.6 million in penalties for violating the lockout/tagout rule, with 83 percent imposed on manufacturing companies.

For businesses trying to improve lockout/tagout systems, Master Lock has identified five areas to consider:

• Lockout policy: It’s the all-important starting point that puts in place essential elements of your program and is required by OSHA. Policies should include identification of hazardous energy types in a workplace, who is responsible for using lockout/tagout devices to isolate the energy, who’s responsible for training and who will write specific procedures.
• Lockout procedures: These are specific steps that an authorized person can follow to correctly shut down a piece of equipment so that it can be safely repaired or maintained. Procedures should include scopes and purposes and should address issues such as potential for residual energy and how to verify that energy has been cut off.
• Lockout training: Communication of company procedures and expectations should be thorough and consistent. Training should target: authorized employees (who perform lockouts); affected employees (who work in lockout areas but aren’t involved with locking out machinery or maintaining it); contractors and other employees.
• Auditing and review: At least once a year, energy control procedures should be examined and each employee’s responsibilities under those procedures reviewed.
• Equipment strategy: Companies should make sure that proper locks and lockout devices are available and authorized employees have what they need to succeed. There’s no one-size-fits-all strategy; it will vary depending on the function and size of operations.

What parts of your lockout/tagout system need improvement? Tell us in the comments below.