Lockout/tagout requirements
Published 2026-09-04 · 10 min read · sources checked 2026-09-04
Control of hazardous energy was the third most frequently cited federal OSHA standard in fiscal year 2024. Not because contractors do not own locks — because the standard asks for three things and most programmes have one.
What a program has to contain
1910.147(c)(1), quoted: the employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs servicing or maintenance where the unexpected energising, start up or release of stored energy could occur and cause injury, the machine is isolated from the energy source and rendered inoperative.
Three legs. The locks are equipment, not one of them. A programme with procedures and training but no periodic inspection fails the sentence as written.
Notice
Authorised, affected, other
| Class | Who they are | What they are trained in |
|---|---|---|
| Authorised | Locks out the machine to service it | Recognition of hazardous energy sources, types and magnitudes, and the methods of isolation and control |
| Affected | Operates the machine, or works in the area | The purpose and use of the procedure |
| Other | Works anywhere lockout may be used | The prohibition on restarting or re-energising a locked-out machine |
Read from 29 CFR 1910.147(c)(7) on 2026-09-04.
The standard adds a line worth quoting: an affected employee becomes an authorised employee when that employee’s duties include performing servicing or maintenance covered under this section. The class travels with the task, not the job title.
Track which of your crew holds which class on the safety training matrix.
Why tagout is the harder option
A tag is a warning device; it does not physically prevent energisation. So where an energy-isolating device is capable of being locked out, the employer’s programme has to use lockout unless it can demonstrate that a tagout system will provide full employee protection.
And where tagout is used, the periodic inspection has to go further: the review is held between the inspector and each authorised and affected employee, and it must cover the additional tagout elements of (c)(7)(ii) — not just the authorised employees, as with lockout.
The written procedure need not be documented only when all eight conditions of the exception hold at once — no stored or residual energy, a single readily identified and isolated source, complete deenergisation on isolation and lockout, isolation during the work, a single lockout device, exclusive control by the authorised employee, no hazard to other employees, and no accident history of unexpected activation on that machine.
The annual periodic inspection
This is the leg most programmes are missing. 1910.147(c)(6): a periodic inspection of the energy control procedure, at least annually, performed by an authorised employee other than the one utilising the procedure being inspected, conducted to correct any deviations or inadequacies identified.
Two design consequences follow. You need at least two authorised employees per procedure, or the inspection cannot be performed as written. And the inspection is per procedure, not per plant — thirty machine-specific procedures means thirty reviews on a schedule.
Write the procedures on the lockout/tagout procedure template and put the inspection dates on the matrix beside the training. What a citation costs is in OSHA penalties and citations.
