Lockout/Tagout (LOTO)

Who must follow LOTO procedures?

Per 29 CFR 1910.147(a)(1), the standard covers servicing and maintenance of machines and equipment in which the unexpected energization or startup, or release of stored energy, could cause injury. 'Authorized employees' (those who lock out and perform service) and 'affected employees' (those who operate or work near the machine) have different training requirements. Construction-side LOTO is covered by 29 CFR 1926 Subpart V for power generation and Subpart K for electrical work.

What must an energy control procedure include?

Per 29 CFR 1910.147(c)(4), each procedure must specifically describe: scope, purpose, authorization, rules, and techniques to be used; the steps for shutting down, isolating, blocking, and securing machines; the steps for placement, removal, and transfer of lockout/tagout devices; and requirements for testing the machine to verify de-energization. A separate procedure is required for each machine unless certain similarity conditions are met.

How often must LOTO procedures be inspected?

Per 29 CFR 1910.147(c)(6), the employer must conduct a periodic inspection of energy control procedures at least annually. The inspection must be performed by an authorized employee other than the one using the procedure. Findings and corrective actions must be documented in writing — this is a frequently-missed recordkeeping element during OSHA inspections.

What is the difference between lockout and tagout?

Lockout uses a physical device (lock) to hold an energy-isolating device in a safe position, preventing energization. Tagout uses a written warning tag instead of a lock. Per 29 CFR 1910.147(c)(2), lockout is preferred — tagout is permitted only when the energy-isolating device cannot accept a lock, or when the employer demonstrates equivalent protection through additional means.