Lockout/Tagout Reference: 29 CFR 1910.147 and Its Most-Cited Provisions

What 1910.147 covers, and what it does not

The standard applies to general industry servicing and maintenance where the unexpected energization, startup, or release of stored energy could injure an employee. It establishes minimum performance requirements, meaning it sets the outcome (hazardous energy controlled) and gives employers flexibility in how they build a program to get there.

Several categories fall outside it, and knowing the boundaries is part of using the reference correctly. The standard does not cover construction or agriculture; maritime employment (covered by parts 1915, 1917, and 1918); oil and gas well drilling and servicing; or installations under the exclusive control of electric utilities for power generation, transmission, and distribution. It does not cover exposure to electrical hazards from work on or near energized parts, which is addressed by Subpart S (1910.331 through 1910.335). It also carves out minor servicing during normal production operations when that work is routine, repetitive, and integral to production, provided effective alternative protection is used. Cord-and-plug connected equipment is excluded only when the plug is unplugged and under the exclusive control of the person doing the work. Certain hot-tap operations on pressurized systems have a conditional exemption when specific criteria are met (documented in paragraph (a)).

The structure of the standard

The regulation is organized into lettered paragraphs. For a reference, the useful map is this: the requirements employers get cited on live primarily in paragraph (c).

Table 1: Top-level structure of 29 CFR 1910.147. Paragraph (c) contains the program requirements that generate the large majority of citations. Refer to the eCFR for the authoritative subsection text.

Paragraph (c) is where the program is defined, and it breaks down into the pieces that matter most for compliance: (c)(1) the requirement to have an energy control program at all; (c)(2) and (c)(3) the rules governing when lockout versus tagout is used; (c)(4) documented energy control procedures; (c)(5) the lockout and tagout devices themselves; (c)(6) periodic inspection; and (c)(7) training and communication.

The most-cited provisions

This is the part that distinguishes a reference from a generic overview. The pattern is stable: violations concentrate in the program provisions of paragraph (c), and one provision leads consistently. Recent preliminary subsection breakdowns presented by OSHA and reported by Safety+Health show the same top-five order in FY2023 through FY2025.

Table 2: The five most-cited provisions of 1910.147, in the order the subsection data has ranked them across recent fiscal years. The top three, (c)(4), (c)(7), and (c)(6), account for a clear majority of all LOTO citations. Note that OSHA’s finalized Top 10 page publishes the overall standard ranking, not the detailed subsection table; the subsection order here comes from preliminary breakdowns presented by OSHA and reported by Safety+Health. For current figures, consult those annual releases.

The takeaway a safety manager can act on: the top cited provisions map to the legs of the program (procedures, training, inspection) plus the application sequence, and (c)(4) leads consistently. A program audit that verifies documented energy control procedures exist, that training is role-differentiated and documented, that annual inspections are performed and certified, and that the application sequence is followed addresses the large majority of citation exposure.

For where LOTO sits among all OSHA standards by total citation count and rank, see our OSHA most-cited maintenance violations guide, which covers the full Top 10 and where LOTO places on it.

A note on “documented procedures” and the (c)(4)(i) exception

Two precise points here, because this is the most-cited provision.

First, the procedures must clearly and specifically address the equipment and the hazards involved, but they do not have to be one-per-machine. Genuinely similar equipment may be grouped under a single procedure when it is sufficiently detailed and the common procedure identifies the equipment it covers, at least by type and location. Grouping is defensible only where the equipment is truly alike in the factors that matter: energy type and magnitude, the controls involved, the shutdown steps, device handling, and verification. A generic procedure alone is not acceptable for equipment with different hazards.

Second, there is a limited documentation exception. Under the Note to 1910.147(c)(4)(i), an employer need not document the energy control procedure for a particular machine only when all eight of these conditions exist:

1. The machine or equipment has no potential for stored or residual energy, or for reaccumulation of stored energy after shutdown, that could endanger employees.
2. The machine or equipment has a single energy source that can be readily identified and isolated.
3. Isolating and locking out that energy source will completely deenergize and deactivate the machine or equipment.
4. The machine or equipment is isolated from that energy source and locked out during servicing or maintenance.
5. A single lockout device will achieve the locked-out condition.
6. The lockout device is under the exclusive control of the authorized employee performing the work.
7. The servicing or maintenance does not create hazards for other employees.
8. The employer, in using this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.

If any one condition is not met, the procedure must be documented. Equipment with multiple energy sources or hazardous stored or reaccumulating energy does not qualify for the exception.

The lockout/tagout application sequence

Paragraph (d) governs how control is actually applied, in a required sequence commonly taught as six steps.

1. Prepare for shutdown. The authorized employee identifies the energy sources and the appropriate controls before anything is touched.
2. Shut down the machine using its normal stopping procedure.
3. Isolate the machine from every energy source by operating the energy-isolating devices.
4. Apply lockout or tagout devices to each isolating device, applied only by the authorized employee performing the work.
5. Release or restrain stored energy (electrical, hydraulic, pneumatic, mechanical, thermal, chemical). Blocked, capacitive, or spring-loaded energy has to be relieved or safely blocked. Where reaccumulation of stored energy to a hazardous level is possible, verification of isolation must continue until the work is finished or the possibility of reaccumulation no longer exists.
6. Verify isolation before work begins. Verification uses the method appropriate to the energy involved: a deliberate attempt to start the machine, test instruments, or a combination, to confirm the machine is deenergized and will not operate.

Restoring equipment to service, governed by paragraph (e), requires inspecting the work area, confirming employees are safely positioned or clear, removing the devices, notifying affected employees that the devices have been removed, and then reenergizing the equipment.

Device removal is normally done only by the authorized employee who applied the device. The standard provides a specific exception: when that employee is unavailable, the employer may remove the device under a documented procedure that provides equivalent safety, which must include verifying the employee is not at the facility, making all reasonable efforts to contact the employee, and ensuring the employee knows the device was removed before resuming work.

Training requirements in plain language

Training under (c)(7) is a leading cited area, and the citations concentrate where employees are treated the same regardless of role. The standard defines three roles with different training needs:

Authorized employees (those who apply lockout/tagout and perform the servicing) need the most: recognition of hazardous energy sources, the type and magnitude of energy present, and the methods to isolate and control it.

Affected employees (those who operate the machine or work in the area) need to understand the purpose and use of the procedures, and that they must never attempt to restart equipment under lockout.

Other employees who may be in the area need to be instructed about the procedures and the prohibition on tampering with locked-out equipment.

Retraining is required when job assignments change, when machines or processes change, when procedures are updated, or when an inspection reveals a knowledge gap. OSHA does not mandate retraining on a fixed annual schedule; it is triggered by change or deficiency. Employers must certify training with each employee’s name and the dates.

Periodic inspection in plain language

Under (c)(6), each energy control procedure must be inspected at least annually. The inspection has to be performed by an authorized employee who is not using the procedure being inspected, and it must verify that employees know and follow the procedure. OSHA’s enforcement directive (CPL 02-00-147) and LOTO eTool describe a representative-sampling approach: the inspector observes a representative sample of authorized employees actually performing the servicing or maintenance under the procedure, rather than observing every authorized employee individually, and where an employer has genuinely similar procedures, inspection can be organized around that similarity rather than duplicated one-by-one for identical setups. The review of employee responsibilities may be conducted in a group meeting rather than one-on-one, though the procedure itself must still be observed in practice. Where tagout is used, the review extends to affected employees as well. This is a leading cited area, and the citations concentrate in two failures: the inspection is skipped, or it happens but is never certified. Failure to certify the inspection can itself violate 1910.147(c)(6)(ii).

Frequently Asked Questions

What is the most-cited provision of 1910.147?

29 CFR 1910.147(c)(4), the requirement for documented energy control procedures, is the most-cited provision, consistently ranking first among LOTO subsections. The common failures are relying on a single generic policy and lacking documented procedures that address the specific equipment and hazards.

What are the three core components of a LOTO program?

Under 1910.147(c)(1), an energy control program consists of three parts: documented energy control procedures, employee training, and periodic inspections performed at least annually. These three areas account for the clear majority of LOTO citations.

How often does OSHA require LOTO periodic inspections?

At least annually. Under 1910.147(c)(6), each energy control procedure must be inspected at least once a year by an authorized employee who is not using the procedure being inspected. OSHA’s guidance allows the inspector to observe a representative sample of authorized employees performing the procedure, rather than every one, but the responsibility review still covers all authorized employees expected to use the procedure; where tagout is used, that review also extends to affected employees. The inspection must be certified, and failure to certify can itself be a violation under (c)(6)(ii).

Does 1910.147 require machine-specific written procedures for every machine?

Not necessarily. Procedures must clearly address the equipment and hazards involved, but genuinely similar equipment can be grouped under one sufficiently detailed procedure that identifies the equipment it covers. There is also a limited documentation exception under the Note to (c)(4)(i): when all eight listed conditions are met, including that the machine has no stored, residual, or reaccumulating energy that could endanger employees and has a single readily isolated energy source, the procedure for that machine need not be documented. If any condition is not met, it must be.

Does 1910.147 require annual retraining?

No. Retraining under 1910.147(c)(7) is triggered by change or deficiency, not by a fixed annual schedule. It is required when job assignments change, when machines or processes change, when procedures are revised, or when a periodic inspection reveals gaps in an employee’s knowledge or practice.

What is the difference between lockout and tagout?

Lockout physically prevents a machine from being energized, using a lock on the energy-isolating device. Tagout uses a warning tag instead, which does not physically restrain the device. The standard treats lockout as the preferred method: where an energy-isolating device can be locked out, the program must use lockout unless the employer can demonstrate that a tagout system provides full equivalent protection.

Sources and References

• 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout), U.S. Occupational Safety and Health Administration. Authoritative current text at the eCFR (ecfr.gov) and osha.gov. All regulatory requirements here are paraphrased; consult the eCFR for the controlling language.
• OSHA Directive CPL 02-00-147 (effective February 11, 2008), The Control of Hazardous Energy, Enforcement Policy and Inspection Procedures, osha.gov. The current LOTO enforcement directive; it cancels and replaces the earlier STD 01-05-019. Covers the (c)(4)(i) documentation exception, periodic inspection, and representative-sampling procedures.
• OSHA LOTO Safety and Health Topics page and Lockout/Tagout eTool, osha.gov, for scope, definitions, program guidance, and periodic-inspection representative sampling.
• NIOSH, Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tagout) Program, Publication No. 2022-106 (2021), cdc.gov.
• OSHA annual Top 10 Most Frequently Cited Standards (finalized ranking) and preliminary subsection breakdowns as presented by OSHA and reported by Safety+Health, for the most-cited subsection order (c)(4), (c)(7), (c)(6), (c)(1), (d). LOTO’s overall rank and total appear in our OSHA most-cited maintenance violations guide.
• OSHA’s longstanding estimate that full compliance with the standard prevents approximately 120 fatalities and 50,000 injuries annually, osha.gov.