Lockout Tagout (LOTO) Complete Guide: Steps, Procedures and OSHA Requirements

Lockout tagout - commonly abbreviated as LOTO - is a set of safety procedures designed to protect workers from the unexpected energization, startup or release of stored energy during maintenance and servicing of machinery. Every year, OSHA estimates that approximately 50,000 injuries and 120 fatalities occur due to the failure to control hazardous energy. A properly implemented LOTO program is not optional - it is a legal requirement under OSHA 1910.147 and a fundamental obligation to every worker on the floor.

This guide covers everything you need to know: the 7 LOTO procedure steps, every type of hazardous energy, the difference between affected and authorized employees, group lockout procedures, periodic inspection requirements and how to build a compliant LOTO program from the ground up.

What Is Lockout Tagout?

Lockout tagout is a safety procedure that ensures dangerous machines are properly shut off and cannot be started up again before maintenance or servicing work is completed. "Lockout" refers to physically securing an energy-isolating device in the off position using a lock. "Tagout" refers to placing a warning tag on an energy-isolating device when a lockout device cannot be applied, indicating the device cannot be operated until the tag is removed.

The goal is simple: prevent any person from accidentally or inadvertently re-energizing equipment while another worker has their hands or body in a danger zone.

OSHA 1910.147: The Control of Hazardous Energy Standard

The primary regulation governing lockout tagout in general industry is OSHA 29 CFR 1910.147 - The Control of Hazardous Energy. This standard requires employers to:

• Establish an energy control program with written procedures
• Train all affected and authorized employees
• Conduct periodic inspections of energy control procedures at least annually
• Provide adequate lockout/tagout hardware and devices
• Ensure equipment acquired after January 2, 1990 is capable of being locked out

For the construction industry, the equivalent standard is OSHA 29 CFR 1926.417. Marine terminals fall under 29 CFR 1917.157, and longshoring operations under 29 CFR 1918.88.

Non-compliance with 1910.147 is consistently one of the top 10 most cited OSHA violations each year. Penalties can reach $16,550 per serious violation and $165,514 per willful or repeat violation (2024 figures).

Types of Hazardous Energy

Understanding every form of hazardous energy is the first step to controlling it. A thorough energy control procedure must account for all energy sources present in a given piece of equipment.

Electrical Energy

The most commonly recognized form of hazardous energy. Electrical energy can cause electrocution, arc flash burns and secondary injuries from startups. Control methods include de-energizing the circuit, opening and locking disconnect switches and verifying zero voltage with a meter before work begins.

Mechanical Energy

Stored in moving parts such as flywheels, springs and rotating shafts. Even after a machine is shut off, stored mechanical energy can cause serious crushing injuries. Control methods include blocking rotating parts, releasing or restraining spring tension and using mechanical stops or pins.

Hydraulic Energy

Pressurized fluid in hydraulic systems can release with tremendous force. Lines can remain pressurized long after a pump is shut down. Control methods include closing hydraulic isolation valves, bleeding lines to relieve pressure and blocking components that could move if pressure is released.

Pneumatic Energy

Compressed air and gas systems retain stored energy in lines, cylinders and receivers. A single pressurized line can drive a cylinder with enough force to crush a hand. Control methods include isolating air supply valves and venting pneumatic lines to atmosphere before work.

Thermal Energy

Hot surfaces, steam, heated fluids and process chemicals at elevated temperatures present burn hazards. Control methods include allowing equipment to cool to a safe temperature, isolating steam supply valves and bleeding hot lines safely before opening.

Chemical Energy

Reactive chemicals, corrosives and flammable materials stored in process equipment can cause chemical burns, fires or explosions if released during servicing. Control methods include isolating and purging process lines, blanking or blinding pipes and following specific chemical handling procedures.

Gravitational Energy

Any suspended load, raised machine component or elevated part has stored gravitational potential energy. If the support fails or a cylinder bleeds down, the component drops. Control methods include blocking raised components with physical supports, using safety pins and never working under a load supported only by hydraulics.

The 7 Steps of a Lockout Tagout Procedure

OSHA 1910.147 requires a sequence of steps to safely de-energize and isolate equipment. Here are the 7 LOTO steps every authorized employee must follow:

Step 1 - Prepare for Shutdown

Before shutting down the equipment, the authorized employee must identify all energy sources and the type, magnitude and hazards associated with each. This means reviewing the machine-specific energy control procedure, gathering all required LOTO hardware (locks, tags, hasps, blocks) and notifying affected employees that a shutdown is about to occur.

Step 2 - Notify Affected Employees

All affected employees - those who operate the machine or work in the area - must be notified that the equipment will be shut down and locked out. This prevents any worker from attempting to start the machine while work is in progress.

Step 3 - Shut Down the Equipment

Use the normal stopping procedure to shut the equipment down. Follow the manufacturer recommended shutdown sequence. Do not simply cut power without following proper shutdown steps, as abrupt shutdowns can leave equipment in an unsafe state with stored energy.

Step 4 - Isolate All Energy Sources

Operate all energy-isolating devices so that each energy source is disconnected from the equipment. This may include opening electrical disconnect switches, closing hydraulic or pneumatic isolation valves and any other isolation points identified in the energy control procedure. Every single energy source must be isolated - not just the main power switch.

Step 5 - Apply Lockout or Tagout Devices

The authorized employee places their personal lock on every energy-isolating device in the off or open position. Each worker performing the task places their own lock - not just a supervisor lock. Tags are applied when lockout is not feasible, but OSHA is clear that lockout provides greater protection than tagout alone. Use lockout hasps when multiple workers need to lock the same point.

Step 6 - Release or Restrain Stored Energy

After isolating all energy sources, stored or residual energy must be released, disconnected, restrained or otherwise rendered safe. This includes bleeding hydraulic and pneumatic lines, blocking raised components, discharging capacitors, allowing heated surfaces to cool and releasing spring tension. This step is frequently overlooked and is a leading cause of LOTO-related injuries.

Step 7 - Verify Isolation (Zero Energy State)

Before beginning any work, verify that the equipment is in a zero energy state. For electrical equipment, use a properly rated voltage tester and confirm both phase-to-phase and phase-to-ground readings are zero. Attempt to operate the machine controls to confirm it will not start. For hydraulic and pneumatic systems, check pressure gauges. Only after verification is it safe to begin the maintenance or servicing task.

Restoring Equipment to Service

When work is complete, the lockout must be removed in a specific sequence to safely return equipment to service:

1. Ensure all tools, materials and non-essential items are removed from the work area
2. Ensure all employees are safely positioned and clear of the equipment
3. Notify all affected employees that lockout devices are being removed
4. Each authorized employee removes their own lock and tag - only the person who applied the lock may remove it (with limited exceptions for shift changes)
5. Restore energy-isolating devices to the energized position
6. Notify affected employees that equipment is ready to return to service

Affected vs Authorized Employees

OSHA 1910.147 draws a clear distinction between affected and authorized employees, and training requirements differ for each group.

Authorized Employees

An authorized employee is a person who locks out or tags out machines or equipment in order to perform servicing or maintenance. This includes maintenance technicians, electricians, pipefitters and any other worker who physically applies LOTO devices. Authorized employees must receive comprehensive training on:

• Recognition of applicable hazardous energy sources
• The type and magnitude of hazardous energy in the workplace
• The methods and means necessary for energy isolation and control
• Each machine-specific energy control procedure

Affected Employees

An affected employee is one whose job requires them to operate equipment being locked out, or who works in an area where LOTO is being performed. Affected employees do not apply locks - but they must be trained to:

• Understand the purpose of the energy control program
• Recognize when equipment is under lockout
• Understand that they must never attempt to restart locked-out equipment
• Know that only the authorized employee can remove their own lock

Other Employees

Any employee who works in an area where LOTO procedures are used must receive instruction about the procedure and the prohibition against attempting to restart or re-energize locked-out equipment.

Group Lockout Procedures

When servicing or maintenance is performed by a crew, team or other group, the employer must use a procedure that provides employees a level of protection equivalent to that provided by a personal lockout device.

The most common method is the use of a group lockout box or hasp:

• The primary authorized employee applies locks to all energy isolation points and places those keys into a group lockout box
• A hasp is placed on the box so that every crew member can attach their personal lock
• The box cannot be opened (and energy cannot be restored) until every crew member has removed their personal lock
• Each individual retains control of their personal safety until they themselves decide work is complete

For extended multi-shift work, a specific procedure must address the transfer of lockout protection between shifts. Outgoing workers must not remove locks until incoming workers have applied their own.

Periodic Inspection Requirements

OSHA 1910.147(c)(6) requires that each energy control procedure be inspected at least annually to ensure that the procedure is being implemented properly and that employees are familiar with their responsibilities.

The periodic inspection must be performed by an authorized employee other than the one using the procedure. It must include a review of the procedure with each authorized employee covered by that procedure and must be certified in writing, identifying:

• The machine or equipment on which the procedure was inspected
• The date of the inspection
• The employees included in the inspection
• The name of the person who performed the inspection

Annual inspections are a documentation requirement - failure to maintain inspection records is a citable violation even if the procedure itself is sound.

Machine-Specific vs Procedural LOTO

OSHA allows for two approaches to energy control procedures:

Machine-specific written procedures are required for equipment where the lockout steps are not straightforward, where multiple energy sources exist or where there is any potential for confusion. Each piece of equipment gets its own written procedure that identifies every energy source, isolation point and control method.

General procedures may be acceptable for single-energy-source equipment where the shutoff is clearly identified and there is no stored energy potential. However, OSHA compliance officers often expect machine-specific procedures, and many safety professionals recommend them for all equipment regardless.

LOTO Hardware Requirements

Lockout devices must be:

• Durable enough to withstand the environment for the duration of the task
• Standardized by color, shape or size within the facility
• Substantial enough to prevent removal without excessive force
• Uniquely keyed - each worker uses their own lock with their own key
• Identified with the authorized employee name

Tagout devices must be legible and understandable, printed to warn against hazardous conditions and constructed to withstand the environment. Tags must be attached with a self-locking, non-releasable fastener capable of withstanding at least 50 lbs of force.

Building a Compliant LOTO Program

A complete LOTO program includes five components:

1. Written energy control program - the overarching policy describing the scope, purpose and enforcement
2. Machine-specific procedures - step-by-step procedures for every piece of relevant equipment
3. Training records - documented training for every authorized and affected employee
4. Periodic inspection records - annual certification for each procedure
5. Hardware inventory - adequate locks, hasps, tags, lockout stations and blocking devices

Digital safety management platforms like Make Safety Easy (MSE) can streamline LOTO program management by digitizing procedures, scheduling and tracking annual inspections, managing training records and sending automated reminders when inspections are due.

Common LOTO Mistakes to Avoid

• Skipping residual energy release - the most dangerous oversight; always verify zero energy
• Using one lock for the whole crew - every authorized employee needs their own lock on every isolation point
• Tagout instead of lockout by default - tags alone are not locks; use lockout whenever possible
• Outdated procedures - procedures must reflect current equipment configurations; update after any modification
• Missing energy sources - secondary or backup power sources are frequently missed; audit procedures carefully
• No annual inspection records - undocumented inspections offer no compliance defense

Conclusion

A robust lockout tagout program is not merely a compliance checkbox - it is the difference between a worker going home safely and a fatality that could have been prevented. The 7 LOTO steps, when followed precisely, eliminate the primary cause of maintenance-related fatalities. Training your authorized and affected employees, maintaining machine-specific written procedures and conducting rigorous annual inspections creates a culture where hazardous energy is always respected and never assumed to be safe.

If your facility needs help building or auditing a LOTO program, Make Safety Easy offers digital tools for procedure management, inspection tracking and employee training records - all in one platform.