Lockout/Tagout Program | Energy Control

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OSHA Scan Editorial · AI-assisted educational guide

Based on the official sources linked below. No site-specific or independent professional review is implied. Confirm applicability and current federal or State Plan requirements with a qualified professional.

This is general educational information, not a machine-specific energy-control procedure or compliance determination. OSHA Scan is not affiliated with or endorsed by OSHA or the U.S. Department of Labor. A qualified safety professional and authorized employee familiar with the equipment should review the real procedure.

Lockout/tagout is a sequence for preventing unexpected energization, startup, or stored-energy release during servicing and maintenance. It is not simply turning off a machine. A dependable program names sources, isolation points, residual-energy controls, verification, and responsibility transfers.

1910.147 covers servicing and maintenance, including normal production when a worker bypasses a guard or enters a danger zone. It has narrow exceptions for minor servicing, certain cord-and-plug equipment, and hot taps. Another rule can control electrical work.

A photograph, scan, or completed form cannot verify zero energy. The authorized employee must perform the procedure and verify deenergization using the equipment’s controls and appropriate testing. For a real machine, involve people who understand its design and energy hazards.

Who does this apply to?

Use this program for general-industry servicing and maintenance where unexpected energization, startup, or stored energy could injure an employee.
Normal-production work can be covered when guards are bypassed or a body part enters the danger zone.
Cord-and-plug work is excluded only when unplugging controls the hazard and the plug remains under the exclusive control of the servicing employee.
Some electrical, generation, transmission, distribution, and oil-and-gas well work may fall outside 1910.147; another standard may still apply.

Implementation Steps

1. Inventory machines, tasks, and energy sources

List production, maintenance, sanitation, jam-clearing, changeover, and contractor tasks. For each machine, identify electrical, mechanical, hydraulic, pneumatic, thermal, chemical, gravity, pressure, and other sources, isolation points, stored energy, and affected employees. Begin with a field walk. Capture the equipment identifier, normal and abnormal task, source magnitude or state as understood by the authorized employee, disconnect or valve location, bleed or block point, verification point, and restart owner. Implementation questions: what source would an operator not see from the control panel, and what happens when a contractor or second shift inherits the job?

Interview operators and authorized employees about unexpected-start and residual-energy events.
Mark disconnects, valves, blocks, bleed points, and test locations.
Attach a field-checked source map and identify unresolved sources for qualified review.

2. Write and approve an equipment-specific procedure

The employer must develop, document, and use energy-control procedures unless the narrow documentation exception has all conditions. State who shuts down, isolates, locks and tags, releases energy, verifies, works, and restores service. Include group work, shifts, outside employers, and testing.

Use a procedure identifier, equipment identifier, revision date, and approver.
Use diagrams only as aids, never as proof of deenergization.

3. Shut down and isolate in the prescribed sequence

Notify affected employees, stop the machine normally, and isolate every energy source. Apply each authorized employee’s lock and tag to the energy-isolating device; push buttons, selector switches, and interlocks are not substitutes. Block, bleed, discharge, restrain, or otherwise render stored energy safe.

Check for secondary feeds, capacitors, accumulators, counterweights, heat, and pressure.
Use group lockboxes or an equivalent arrangement so each person controls protection.

4. Verify isolation before entering the danger zone

Clear people and tools, attempt a start with the normal control, and return controls to off. Test for absence of energy using an appropriate method and address induced voltage or backfeed where relevant. Verification is hands-on; a checklist or photo cannot establish zero energy now. Record the exact control attempted, test instrument or method, test location, result, residual-energy release, and person performing the verification. Illustrative scenario: a conveyor stops at its disconnect but a pneumatic accumulator still moves the actuator; the authorized employee stops and escalates, adds the missing isolation and bleed step, and updates the procedure before work resumes.

Identify who performed the test, what was tested, and what happened.
Stop and escalate if a source cannot be isolated or the result is unexpected.

5. Perform work and manage temporary energization

Keep controls in place throughout servicing and monitor work-group changes. If testing requires temporary energization, clear tools and people, remove locks and tags under the procedure, energize only as necessary, then deenergize, reapply controls, and reverify before work resumes. Decide in advance who calls the pause, who confirms the danger zone is clear, and how each person is notified before energy returns. Escalate when the scope changes, an outside employer arrives, an authorized employee leaves, an isolation device cannot accept the planned lock, or test results conflict with the procedure.

Define the test coordinator and communication signal.
Pause when scope, personnel, equipment, or energy conditions change.

6. Restore service and inspect the program

Inspect the area, account for people and tools, notify affected employees, remove each person’s lock and tag under the procedure, and restore energy in a controlled order. At least annually, inspect each procedure with an authorized employee other than the employee using it, correct deficiencies, and certify the machine, date, employees, and inspector. Completion evidence should show the restoration check, affected-employee notification, personal-lock accountability, unexpected conditions, and any revised step. Ask the inspector to observe the procedure at the machine rather than merely initialing a template; retain the signed certification and deficiency closeout.

Document unusual findings, near misses, and procedure changes.
Train authorized, affected, and nearby employees to distinct roles.

Document planning checklist

Use this planning list to organize applicable records. Suggested owners and review triggers are workflow recommendations; the linked standards determine which documents and retention periods are legally required.

Document / Record	Purpose	Owner	Review Cadence
Energy-control program	Defines procedures, training, group work, shifts, and contractors.	Maintenance or EHS manager	Review after equipment, task, staffing, incident, or rule change.
Machine-specific procedure	Names sources, isolation, stored-energy controls, verification, and restoration.	Authorized maintenance lead	Review after modification, unexpected energy, near miss, or inspection.
Annual inspection certificate	Shows machine, date, employees, inspector, and corrections.	Inspecting authorized employee	Complete at least annually and close deficiencies.
LOTO training matrix	Separates authorized, affected, and other instruction.	Training coordinator	Update on assignment, role, equipment, or knowledge change.
Group and shift handoff record	Shows personal lock control and transfer.	Maintenance supervisor	Use for every group job or shift change.

Common Pitfalls

Calling a photo verification

A picture of a lock or form cannot show the machine is deenergized now. Authorized employees must attempt startup, test appropriately, and control residual energy.

Using one generic procedure for every machine

Energy paths and isolation points differ. Generic language can omit a remote, stored, or gravity source and should not replace a machine-specific procedure.

Treating annual inspection as a safety meeting

The inspection evaluates each energy-control procedure and is performed by an authorized employee other than the one using it. It must be certified with the standard’s details.

Frequently Asked Questions

Does turning off a disconnect always satisfy LOTO?

No. The procedure must identify all energy sources, isolate them, control stored energy, and verify deenergization. A single disconnect may qualify for a narrow documentation exception only when every condition in 1910.147(c)(4)(i) is met.

Can a trainee apply a lock alone?

Follow the program’s role assignments. Authorized employees perform energy control; affected and nearby employees receive their distinct instructions. Do not assign a role solely from a job title.

What happens during a shift change?

The procedure must provide continuous protection. Use personal locks or a group arrangement, communicate status, and apply the incoming lock before removing the outgoing lock.

Are lockout and tagout interchangeable?

Lockout is the default where a device can be locked. Tagout-only requires the standard’s conditions and equivalent safety measures. Decide from the equipment and rule, not convenience.

What the AI can and can't detect

OSHA Scan reads a single photo. That makes it fast and easy for anyone on site — but it also means it has real limits. Here's an honest look at both.

What it can catch from a photo

Missing or incorrect PPE that is visible in the frame
Unprotected edges, open holes, and visible fall hazards
Housekeeping, trip, and blocked walkway or exit hazards
Visible electrical, struck-by, and equipment-guarding hazards

What a photo can't tell it

Hazards hidden from view or anything outside the photo
Exact heights, distances, weights, or measurements
Training records, procedures, or how equipment is actually used
Full legal compliance or an official OSHA pass/fail determination

OSHA Scan gives an AI-assisted preliminary review from a photo. It does not replace an on-site inspection by a qualified safety professional, and a compliance score is not an official OSHA determination.