Is Your LOTO Procedure OSHA-Compliant?
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- Issue Time
- Sep 27,2025
Summary
Your LOTO procedure is OSHA-compliant if it is a specific, written, energy control procedure that your authorized employees are trained to follow for every piece of equipment covered by the standard.
Your LOTO procedure is OSHA-compliant if it is a specific, written, energy control procedure that your authorized employees are trained to follow for every piece of equipment covered by the standard.
The 8 Key Elements of an OSHA-Compliant LOTO Program
1. Written Energy Control Procedure
This is the cornerstone of compliance. You must have a specific, written procedure for each machine or piece of equipment.
✅ Requirement: The procedure must outline the scope, purpose, authorization, rules, and techniques for controlling hazardous energy.
❌ Common Pitfall: Using a generic, one-size-fits-all procedure for all machines.
2. Employee Training and Retraining
OSHA mandates three distinct types of training, and you must keep records of it.
✅ Authorized Employees: Those who perform the LOTO procedure. They must be trained on the specific procedures for the equipment they work on.
✅ Affected Employees: Those who operate the equipment but do not perform LOTO. They must be trained on the purpose and use of the LOTO procedure.
✅ Other Employees: Those who work in the area where LOTO is used. They must be instructed on the prohibitions of attempting to restart or energize locked-out equipment.
❌ Common Pitfall: Providing initial training but no retraining. Retraining is required when:
There is a change in job assignments.
There is a change in machines, equipment, or processes that presents a new hazard.
There is a change in the energy control procedures.
Periodic inspections reveal inadequacies in an employee's knowledge.
3. Periodic Inspections
This is one of the most frequently cited areas for violations. You must conduct an annual audit of each energy control procedure.
✅ Requirement: An authorized employee (other than the one(s) using the procedure) must perform a periodic inspection of each procedure. This inspection must:
Observe an authorized employee performing the procedure.
Review the responsibilities of all involved employees (authorized and affected).
❌ Common Pitfall: Failing to conduct the annual inspection or failing to document it properly. The certification of the inspection must include the machine/equipment, the date, the employees included, and the person performing the inspection.
4. Proper Lockout/Tagout Devices
The physical hardware must be durable, standardized, and substantial.
✅ Requirement: Locks, tags, chains, wedges, etc., must be:
Durable: Withstand the environment (e.g., weather, chemicals).
Standardized: Consistent in color, shape, or size. Red is common for locks. Tags must be legible and warn against hazardous operations.
Substantial: Locks must be strong enough to prevent removal without excessive force or bolt cutters.
Identifiable: Each lock must have the name of the employee who applied it.
❌ Common Pitfall: Using a generic tag without a lock, or using flimsy locks that can be easily broken.
5. Machine-Specific Energy Control
The procedure must correctly identify and isolate all sources of hazardous energy.
✅ Requirement: The procedure must include steps for:
Preparation for Shutdown: Notifying affected employees.
Equipment Shutdown: Turning off the machine using normal controls.
Equipment Isolation: Physically disconnecting all energy sources (e.g., opening circuit breakers, closing valves, blocking moving parts).
Application of LOTO Devices: Placing locks and tags on every energy isolation point.
Release of Stored Energy: Bleeding air from lines, blocking gravity-driven parts, etc.
Verification of Isolation: Attempting to start the equipment from the normal operating controls to ensure it's de-energized, then returning controls to the "off" position.
6. Group LOTO / Complex Procedures
If more than one person is working on the equipment, you need a specific plan.
✅ Requirement: A group LOTO procedure must be used. This typically involves a group lockbox. The primary authorized employee locks out all energy sources and places the keys in a lockbox. Each individual worker then places their personal lock on the lockbox.
❌ Common Pitfall: Multiple employees using a single lock with multiple keys or simply signing a group tag. This is not compliant.
7. Shift or Personnel Changes
The procedure must ensure continuity of protection during shift changes.
✅ Requirement: The procedure must outline a safe transfer of LOTO responsibility. Typically, the outgoing employee removes their lock, and the incoming employee applies their own lock before the equipment is re-energized.
❌ Common Pitfall: An incoming employee simply "taking over" the previous employee's lock.
8. Release from LOTO
The process for returning equipment to service must be safe and orderly.
✅ Requirement: The procedure must include steps for:
Inspecting the equipment to ensure it is intact and non-essential items are removed.
Ensuring all employees are clear of the danger zones.
Notifying affected employees that the lock is being removed.
Removing LOTO devices by the authorized employee who applied them.
Lita Lock, a China based manufacturer, since 2017, active in manufacturing safety padlocks, electrical lockout, valve lockout, lockout station, tags and other lockout & tagout for global partners.
To help customers compliance with OSHA Standard 29 CFR 1910.147, Lita Lock does not only offer design, production and final assembly, but also a complete lockout & tagout solution for various industries.
Lita Lock pursues the competitiveness on creative, quality control, technology and sustainable development. As the founder of Lita Lock, Iris Chen says: “Many things have changed, but one thing that has not—our original intention to start businesses: keeping workers safe.” Together, we make work environments safer.
Sales Manager: Iris Chen
Email: iris@litalock.com
Whatsapp: +86 19519767209
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