Lockout/Tagout (LOTO) Compliance Guide

The Control of Hazardous Energy standard — universally called Lockout/Tagout or LOTO — exists to prevent one specific scenario: a worker servicing or maintaining equipment gets caught, crushed, or electrocuted because the machine unexpectedly energized while they were working on it. OSHA estimates LOTO compliance prevents roughly 120 fatalities and 50,000 injuries every year. When the program breaks down, people die.

What Equipment Requires LOTO?

The LOTO standard applies to the servicing and maintenance of machines and equipment in which the unexpected energization, startup, or release of stored energy could harm employees. This includes any machine or equipment that:

• Could start up or energize unexpectedly during servicing
• Contains stored energy that could be released during servicing (springs, pressure, gravity, capacitors)
• Requires employees to place any part of their body into a hazard zone

Routine production operations using normal production controls are not covered if the equipment is properly guarded. LOTO applies when guards are removed, when employees must bypass normal safety controls, or when employees must place any part of their body into a point of operation or associated danger zone.

Energy Types Covered

LOTO covers all forms of hazardous energy, not just electrical:

• Electrical — the most common; includes all voltages
• Hydraulic — pressurized fluid systems, cylinders, accumulators
• Pneumatic — compressed air systems
• Mechanical — springs, gravity (suspended parts), flywheels
• Thermal — steam, hot fluids, heated surfaces
• Chemical — hazardous materials under pressure in process piping
• Radiation — nuclear, laser, RF energy sources

Each energy type requires a specific isolation and verification method. Turning off a machine at its control switch does not de-energize a hydraulic accumulator or discharge a capacitor.

Required Written Energy Control Program

Every employer whose workers service or maintain covered equipment must have a written Energy Control Program. The program must include:

• A scope statement covering all equipment subject to the program
• Rules and techniques for controlling hazardous energy
• Means to enforce compliance
• Procedures for affixing and removing lockout/tagout devices
• Employee training requirements
• Annual inspection procedures

A generic written program downloaded from the internet is not sufficient by itself. The program must reflect your specific workplace, equipment, and procedures.

Equipment-Specific Energy Control Procedures

In addition to the general written program, OSHA requires a documented energy control procedure for each piece of covered equipment — unless the employer can demonstrate that all of the following apply:

• The machine has no potential for stored or residual energy after shutdown
• There is a single energy source that can be readily identified and isolated
• Isolation and locking of the energy source completely de-energizes the equipment
• The equipment is isolated from the energy source and locked out during servicing
• A single lockout device will achieve a locked-out condition
• The lockout device is under the exclusive control of the authorized employee
• Servicing does not create hazards for other employees
• There have been no accidents involving the unexpected activation of this equipment

For most industrial equipment, machine-specific written procedures are required. Each procedure must identify the equipment, the authorized employees, the steps to shut down and isolate energy, the type and magnitude of energy, and the method to verify de-energization.

The 8-Step LOTO Procedure

Every lockout must follow this sequence:

Step 1: Prepare for shutdown

Identify all energy sources for the equipment. Review the machine-specific energy control procedure. Notify affected employees that a lockout is being performed.

Step 2: Notify affected employees

Let everyone who operates or works in the area of the equipment know that it will be shut down and locked out, and why.

Step 3: Shut down the equipment

Use the normal stopping procedure — push the stop button, close the valve, throw the switch — to bring the equipment to a complete stop.

Step 4: Isolate all energy sources

Operate the energy isolating device — open the disconnect switch, close the valve, block the stored energy — so the machine is physically isolated from its energy supply. This is not the same as turning it off at the control panel.

Step 5: Apply lockout/tagout devices

The authorized employee applies their personal lock to each energy isolating device. Each worker must apply their own lock. Multiple workers on the same machine means multiple locks — one per person.

Step 6: Release or restrain stored energy

Bleed hydraulic or pneumatic lines, discharge capacitors, release spring tension, block suspended parts against gravity, allow thermal energy to dissipate. Stored energy that isn't addressed at this step will release when the machine is opened.

Step 7: Verify de-energization

Test the equipment to confirm it is truly de-energized before beginning work. Try the normal operating controls. Use a voltmeter to verify electrical isolation. This step is not optional — it is what separates a real lockout from a paper lockout.

Step 8: Perform servicing or maintenance

Work can now begin. The authorized employee's personal lock remains on the energy isolating device for the entire duration of the work.

Restoring Equipment to Service

When work is complete, restore energy in the reverse sequence:

• Ensure all tools and non-essential items are removed from the work area
• Ensure all guards and safety devices are reinstalled
• Ensure all employees are safely positioned away from the machine
• Notify affected employees that lockout devices are being removed
• Remove each authorized employee's personal lock from the isolating devices
• Restore energy to the machine

Authorized vs. Affected Employees

OSHA distinguishes between two categories of employees under the LOTO standard:

Authorized employees are those who perform the servicing or maintenance work and apply the lockout/tagout devices. They must receive full training on the LOTO standard, the energy control program, and the machine-specific procedures for equipment they service.

Affected employees are those who operate the equipment being serviced, or who work in an area where lockout/tagout is being performed. They must be trained to recognize when and why equipment is locked out, and they must never attempt to restart locked-out equipment or remove locks that are not their own.

Lockout vs. Tagout: When Is Tagout Acceptable?

Lockout — physically locking an energy isolating device in the safe position — is the preferred method and must be used whenever the energy isolating device can be locked. Tagout — applying a warning tag without a physical lock — is only permitted when the energy isolating device cannot accept a lock.

When tagout is used instead of lockout, additional protective measures must be implemented to provide a level of protection equivalent to lockout. This may include removing a valve handle, removing a fuse, or blocking a control. A tag alone, without additional measures, provides minimal protection.

Group Lockout Procedures

When multiple employees are working on the same piece of equipment, group lockout procedures must ensure each worker's personal protection. Common approaches include:

• Each worker applies their own personal lock directly to each energy isolating device (requires multi-lock hasp)
• A primary authorized employee applies the group lockout lock, then each worker applies their personal lock to a group lockout box containing the group lock key

Under no circumstances should one worker's protection depend on another worker's lock.

Annual Program Inspection

OSHA requires a periodic inspection of the energy control program at least annually. The inspection must be performed by an authorized employee other than the one using the procedure being inspected. The purpose is to verify the procedure is being followed correctly and that employees understand their responsibilities.

The annual inspection must be certified in writing, including the date, the equipment inspected, the names of employees involved, and the inspector's name. This documentation is one of the first things an OSHA inspector will request.

Common LOTO Violations