Lockout/tagout (LOTO) is the process of isolating machines and equipment from all energy sources and applying locks and tags to prevent unexpected startup or energy release during servicing and maintenance. OSHA's Control of Hazardous Energy standard (29 CFR 1910.147) requires written LOTO procedures for virtually every workplace with powered equipment. Canadian jurisdictions enforce equivalent requirements through provincial OHS regulations and CSA Z460 (Control of Hazardous Energy). The consequences of failing to lock out are catastrophic - crushing injuries, amputations, electrocution, burns and death. This guide covers everything employers need to build, implement and maintain a compliant LOTO program.

Here is a number that should keep every maintenance manager up at night: OSHA estimates that lockout/tagout violations contribute to approximately 10% of all serious workplace injuries in general industry. Workers performing maintenance and servicing tasks on machines that unexpectedly start, release stored energy, or re-energize face some of the most gruesome hazards in any workplace. A conveyor that starts while someone is clearing a jam. A hydraulic press that cycles while a technician is adjusting the die. A capacitor bank that discharges while an electrician is working on the panel.

Every one of those scenarios is preventable with proper lockout/tagout. Every single one.

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Managing LOTO procedures across multiple machines and facilities requires rigorous documentation. Make Safety Easy's document management system keeps your machine-specific energy control procedures organized, version-controlled and accessible to every authorized worker.

What OSHA's LOTO Standard Requires

OSHA 29 CFR 1910.147 - The Control of Hazardous Energy - applies to general industry. Construction has additional lockout requirements under 29 CFR 1926 and specific standards cover electrical lockout (NFPA 70E and 29 CFR 1910.333). Here are the core employer obligations:

Canadian Requirements

Canadian provinces mirror OSHA's requirements through their OHS regulations:

Types of Hazardous Energy

Lockout/tagout isn't just about electrical energy. Workers must be protected from every energy source that could cause harm. A thorough energy control procedure identifies and addresses all of these:

Energy Type Sources Isolation Methods
Electrical Motors, circuits, transformers, capacitors, batteries Disconnect switches, circuit breakers, removal of fuses. Verify zero energy with a voltmeter.
Mechanical Flywheels, springs, gears, pulleys, gravity-fed components Blocking, bracing, pinning, releasing stored energy (springs, elevated loads)
Hydraulic Hydraulic cylinders, accumulators, pumps, lines Bleed pressure, block cylinders in position, close and lock valves
Pneumatic Air compressors, air cylinders, pressurized systems Bleed pressure, close and lock valves, disconnect air supply
Thermal Steam systems, furnaces, heated vessels, cryogenic systems Allow cooling/warming to safe temperatures, close and lock steam valves, drain lines
Chemical Process piping, reaction vessels, storage tanks Close and lock valves, blank or blind flanges, double-block-and-bleed
Gravitational Elevated components, counterweights, suspended loads Lower to stable position, block or brace, use safety pins

The most dangerous energy source is the one you don't identify. That's why machine-specific procedures are essential - generic lockout procedures miss the unique energy sources present in each piece of equipment.

The 8 Steps of Lockout/Tagout

These steps follow OSHA's recommended sequence and align with CSA Z460. Every authorized employee must know them cold.

Step 1: Preparation

Before beginning, the authorized employee must identify all energy sources associated with the machine or equipment. Review the machine-specific energy control procedure. Identify the type and magnitude of each energy source, the location of all isolation points and the method for verifying zero energy.

Step 2: Notification

Notify all affected employees - operators, other maintenance workers, supervisors - that the machine will be locked out. Tell them why, for how long (estimated), and who is performing the work. Communication prevents someone from unknowingly attempting to restart equipment.

Step 3: Normal Shutdown

Shut down the machine using its normal operating controls. Push the stop button. Turn off the switch. Follow the manufacturer's recommended shutdown sequence. Never pull a disconnect or breaker while a machine is running unless it's an emergency.

Step 4: Isolation

Isolate the machine from every energy source identified in Step 1. This means operating disconnects, closing valves, blocking mechanical motion and disconnecting any other energy feeds. The goal is complete isolation - no energy can reach the machine from any source.

Step 5: Apply Lockout/Tagout Devices

Each authorized employee working on the machine applies their own personal lock to each energy isolation device. The lock must be individually keyed - no master keys in routine use. If locks cannot physically be applied, tags are used, but OSHA requires that tags be supplemented with additional measures (such as removing a fuse or blocking a valve) because tags alone cannot prevent re-energization.

Every lock must be accompanied by a tag identifying the authorized employee, the date and the reason for lockout.

Step 6: Release Stored Energy

After isolation, stored or residual energy must be dissipated or restrained. This is the step most often missed - and it's the one that kills. Examples:

Step 7: Verification

Before beginning any servicing work, the authorized employee must verify that the machine is truly at zero energy. This is the most critical safety step in the entire process.

After verification, return all operating controls to the "off" position so the machine doesn't start when locks are removed.

Step 8: Perform the Work

Only after all previous steps are complete may the authorized employee begin servicing or maintenance work. If conditions change during the work - a new energy source is discovered, or additional workers need to be protected - stop work and repeat the procedure as needed.

Removing Lockout/Tagout Devices

Removal follows a specific sequence:

  1. Inspect the work area to ensure all tools, parts and materials are cleared and guards are reinstalled
  2. Verify that all workers are clear of the machine
  3. Notify affected employees that the lockout is being removed and the machine is about to be re-energized
  4. Each authorized employee removes only their own lock - no one else removes another person's lock
  5. Re-energize the machine following the manufacturer's startup sequence

OSHA permits removal of another employee's lock only under specific, documented circumstances - when the employee is not available (e.g., they left the facility) and only after the employer has made reasonable efforts to contact them and followed a verified procedure that ensures the employee's safety before the lock is removed.

Group Lockout/Tagout

When multiple workers service the same machine, group lockout procedures apply. The typical approach uses a lockout box or hasp system:

  1. A primary authorized employee performs the lockout procedure and places the keys to the energy isolation locks in a lockout box
  2. Each worker applies their personal lock to the lockout box
  3. No one can access the energy isolation keys until every personal lock has been removed
  4. The last lock removed is the primary authorized employee's, who then removes the isolation locks and follows re-energization procedures

This ensures that every worker is individually protected and that the machine cannot be re-energized until everyone has confirmed they are clear.

Periodic Inspections

OSHA requires that employers inspect each energy control procedure at least annually. The inspection must:

Make Safety Easy's inspection tools let you schedule annual LOTO audits, assign inspectors, document findings and track corrective actions - all digitally, with automatic reminders so inspections never slip through the cracks.

Training Requirements

OSHA defines three categories of employees who require LOTO training, each with different content requirements:

Employee Category Who Training Content
Authorized Employees who perform lockout/tagout (maintenance, servicing) Recognition of hazardous energy sources, type and magnitude of energy, methods and means for energy isolation and control, the full LOTO procedure
Affected Employees who operate machines being locked out (operators, production workers) The purpose and use of energy control procedures, the prohibition against restarting or re-energizing locked-out equipment
Other Employees who work near locked-out machines but don't operate or service them The prohibition against attempting to restart machines that are locked out or tagged out

Retraining is required when job assignments change, when the energy control procedure changes, when a new hazard is introduced, or when a periodic inspection reveals that workers are not following procedures.

Common LOTO Violations and Penalties

Lockout/tagout consistently ranks among OSHA's top 10 most-cited standards. The most frequent violations:

OSHA penalties for LOTO violations can exceed $16,000 per serious violation and $160,000 per willful or repeat violation. In Canadian jurisdictions, penalties vary but can reach into the hundreds of thousands, with the possibility of imprisonment for officers and directors under C-45 (Westray Law) where negligence contributes to a fatality.

LOTO for Specific Industries

While the core principles are universal, certain industries face unique LOTO challenges:

Building Your LOTO Program: A Checklist

Lockout/tagout is one of the most critical safety programs in any workplace. Make Safety Easy helps you manage machine-specific LOTO procedures, schedule and document annual inspections and keep training records organized and audit-ready. Book a demo to see the platform in action, or view our pricing to find the plan that fits your operation.

Learn more about how Make Safety Easy serves the LOTO in utilities industry with purpose-built safety tools.