13 Steps to LOTO Compliance

Date First Published on SafetySmart Compliance: September 10th, 2012
Topics: Lockout Tagout |

Worker working on locked out machinery

On April 4, 1991, GM millwright Daniel Smith was killed when the conveyor he was repairing unexpectedly started up.  Sadly, many workers continue to lose lives and limbs in machine accidents like this. That’s why the OSHA Lockout/Tagout (LOTO) standard (Sec. 1910.147) requires employers to ensure machinery and equipment is shut down and doesn’t energize, or start up, during servicing, repair or maintenance operations. But while they serve an important purpose, the OSHA rules are technical and hard to apply to practical operations. So it’s not surprising that LOTO remains a leading source of OSHA citations.

The key to avoiding Daniel Smith-type injuries—and OSHA LOTO citations—is to implement an Energy Control Plan (ECP, which we’ll refer to by its common name “LOTO program”) for safe repair and maintenance of machinery and equipment that’s subject to unexpected energization. Here are the 13 things you have to do to comply with LOTO program requirements.

The first thing you need to do is figure out which, if any, of your operations require a LOTO program. Rule of thumb: LOTO requirements apply to any operations for controlling energy during the servicing or maintenance of machines and equipment where unexpected energization, start up or release of stored energy could harm workers. But there are some key exceptions:



Non-repetitive or routine maintenance or servicingOperations that involve removal of guards or disabling of safety devicesOperations in which workers must place body parts into danger zonesClearing a jammed or block machineRebuilding equipmentEquipment set up  Minor, repetitive or routine tool changesMinor, repetitive or routine adjustmentsMinor, repetitive or routine servicing integral to normal production activity and for which safeguards are in placeWork on unplugged electrical equipment or machines where the worker performing service or maintenance has exclusive control over plugHot tap operations on transmission and distribution systems for gas, steam, water or petroleum products where employer can show:

  • Continuity of service is essential;
  • System shutdown is impractical; and
  • Effective protective measures are in place.

For More Help Figuring Which Operations Are Subject to LOTO Rules

Your LOTO program must indicate the method you use to control the release of hazardous energy. The options:

  • Lockout, i.e., applying a locking device to the equipment’s energy isolating device—the preferred method to use because it imposes a physical barrier to prevent start-up of the equipment;
  •  Tagout, i.e., notifying people in the area that the machine/equipment is being serviced so they don’t start it up—a riskier method that you’re allowed to use only when:
  •  The machine/equipment being serviced isn’t capable of being locked out;  and
  • You can demonstrate that tagout provides a level of safety “equivalent to that under a lockout program”
  • Combination of both methods.

For More Help Selecting Lockout or Tagout

The LOTO standard says you must set out a “clear and specific” lockout (or tagout) procedure for controlling hazardous energy. The words “clear and specific” aren’t window dressing. Many an employer has been cited because it procedure wasn’t clear and specific enough. To avoid citations, the procedure must list—at a minimum:

  • The name of the company;
  • A description of the equipment/machine the procedure covers;
  • A specific statement of the procedure’s “intended use” or purpose it serves;
  • The specific steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;
  • The specific steps for the placement, removal and transfer of lockout or tagout devices and who’s responsible for performing them;
  • The specific steps for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices and other energy control measures.
  • A statement requiring workers to comply with the procedure; a detailed description of the lockout sequence—or tagout sequence (see Step 5 below); and
  • A detailed description of how the equipment/machine is returned to service.

For More Help Ensuring Your Lockout/Tagout Procedure Is Clear & Specific

The individual who performs the actual energy control procedure must be what’s called an “authorized employee,” i.e., a person who locks out or tags out machines or equipment to perform servicing or maintenance on that machine or equipment, as opposed to what’s called an “affected employee,” i.e., one whose job requires him to operate or use the machinery or equipment being serviced or maintained or whose job requires him to work in the area where the servicing or maintenance is performed.

For More Help Complying With “Authorized”& “Affected Employee” Requirements

Your energy control procedure must provide that service/maintenance on machinery/equipment can begin only after all of the following steps are taken in this ordere:

  • Step 1: Preparation for Shutdown, i.e., the  authorized employee has knowledge of the type and magnitude of the energy, the hazards it poses and the methods used to control them;
  •  Step 2: Shutdown, i.e., the machine/equipment is turned off or shut down using the appropriate shutdown method in the energy control procedure in an orderly way that doesn’t create additional hazards;
  •  Step 3: Isolation, i.e., all energy isolation devices are physically located and operated so as to isolate the machine/equipment from the energy source;
  •  Step 4: Application of Lockout or Tagout Device(s), i.e., the authorized employee affixes each of the energy isolating devices and:
  • Lockout devices are fixed so as to hold the energy isolating device(s) in a “safe” or “off” position;
  • Tagout devices are fixed so as to clearly indicate that operation or movement of energy isolating device(s) from the “safe” or “off” position is prohibited;
  • If tagout devices are used with energy isolating devices capable of being locked, the tag is fastened at the same point where the lock would have been attached; and
  • If a tag can’t be affixed directly to the energy isolating device, the tag is as close as safely possible” to the device, in a position that’s immediately obvious to anyone trying to operate the device.
  • Step 5: Restraint of Stored Energy, i.e., once the lockout or tagout device(s) is in place, all potentially hazardous stored or residual energy is relieved, disconnected, restrained and otherwise made safe;
  • Step 6: Verification of Isolation, i.e., before service or maintenance can begin on the machine/equipment locked or tagged out, the authorized employee verifies that isolation and deenergization of the machine/equipment has been accomplished

For More Help Complying With Energy Control Procedure Sequence Rules

There also needs to be a procedure to ensure that the lockout/tagout device isnt removed and power to the machine/equipment isn’t restored, unless and until the authorized employee checks the work area to verify that nonessential items have been removed,

machine or equipment components are operationally intact and all employees have been safely positioned or removed.

The energy isolating device(s) must be removed by the authorized employee who attached it. Exception: If the authorized employee isn’t available, it may be removed by somebody else, as long as the Energy Control Procedure includes specific steps and training requirements for removal by another person and the alternative removal procedure is just as safe as removal by the authorized employee and steps are taken to verify that the authorized person isn’t at the facility, reasonable efforts and were taken to find to let him know the device has been removed before he resumes work at the facility.

The authorized employee must ensure that all affected employees are notified after the lockout or tagout device(s) has been removed. The machine/equipment can’t be restored to service until after all affected employees receive notification.

For More Help Complying With Lockout/Tagout Removal & Power Restoration Rules

The energy control procedure should provide that if the lockout/tagout device is temporarily removed from the energy isolating device so the machine/equipment can be tested or positioned, the following steps must be taken in this order:

  • Clearing of machine or equipment of tools and materials;
  • Removal of all employees from the machine or equipment area;
  • Authorized employee who attached it removes lockout or tagout device or alternative removal procedure is followed if authorized employee isn’t at the facility;
  • Energization of machine/equipment and proceeding with testing or positioning;
  • Deenergization of all systems and refollowing the energy control procedure;
  • Servicing or maintenance of machine/equipment; and
  • Execution of the removal procedures referred once servicing or maintenance ends.

There must also be specific procedures to ensure the continuity of lockout or tagout protection through changes in shifts or personnel, including procedures for the orderly transfer of lockout or tagout device protection between the off-going and oncoming employees.

For More Help on Temporary Lockout/Tagout Removal



Like some employers, you might rely on an outside contractor or subcontractor to carry out your energy control procedure. In this case, make sure you and the contractor notify each other of your respective lockout/tagout procedures and decide which procedures to use. If you use your own procedure, make sure the contractor’s employee’s understand and comply with it; if you use the contractors procedure, make sure your own employees understand and comply with it.

For More Help with Contractors & LOTO

You must provide locks, chains, wedges, key blocks, adapter pins, self-locking fasteners or other hardware for isolating, securing or blocking machines or equipment from energy sources. The actual lockout devices and tags you use must also meet specific OSHA requirements.

For More Help with Lockout/Tagout Device & Equipment Rules

You must inspect your energy control procedure at least once a year to verify that the procedure and LOTO requirements are being followed. Inspection must be carried out  by an authorized employee who is not utilizing the energy control procedure being inspected and include reviews with authorized employees who are using it (and affected employees affected by it). Make sure you document each inspection by creating a written certification that lists the:

  • Identity of the machine/equipment on which the energy control procedure is being used;
  • Date of the inspection;
  • Employees included in the inspection; and
  • Person who performed the inspection.

For More Help with Energy Control Inspections

You must train and instruct your workers about the purpose of your energy control program and ensure they have the necessary knowledge and skills to play their role under it. The substance and objectives of training vary depending on who’s being trained:

  • Authorized employees must be trained to recognize hazardous energy sources, the type and magnitude of energy available in the workplace and the necessary methods of energy isolation and control;
  • Affected employees must be instructed in the purpose and use of the energy control procedure; and
  • All other employees whose work operations are or may be in an area where energy control procedures may be used must be instructed about the procedure and that restarting or reenergizing locked out or tagged out machines or equipment is prohibited.

For More Help with LOTO Safety Training

You must ensure authorized and affected employees receive retraining whenever:

  • Their job assignments change;
  • There are changes in machines, equipment or processes that pose a new hazard;
  • The energy control procedure changes; and/or
  • You have reason to believe that there are deviations from or inadequacies in the employee’s knowledge or use of the energy control procedures.

For More Help with LOTO Retraining

Finally, you must document that LOTO training has been accomplished and is kept up to date by creating a written certification that lists each trainee’s name and the date(s) training was provided.

For More Help with LOTO Training Certification

[  ] Retraining reestablishes the employee’s proficiency in and, if necessary, introduces him/her to any new or revised energy control methods and procedures.

For More Help with Energy Control Inspections