Introduction
Lockout/Tagout (LOTO) is a critical safety protocol designed to prevent accidental machine energization during servicing and maintenance, this LOTO Compliance Checklist outlines 10 OSHA requirements a company should review. According to OSHA, proper LOTO practices save hundreds of lives and thousands of injuries annually. Yet, it remains one of the most cited violations and for fiscal year 2025 LOTO is ranked 4th overall.
1. Written Energy Control Program
Your path to LOTO compliance starts with a documented energy control program. A solid compliant energy control program should consist of 5 components. The components consist of LOTO procedures, Periodic Inspection for employees and procedures, LOTO Devices, LOTO Trainings and Policy. Review and update these key components in your program annually to maintain compliance. Refer to OSHA 29 CFR 1910.147(c)(2) standard for guidance.
2. Machine-Specific Lockout/Tagout Procedures
Generic instructions won’t cut it. Each machine needs its own lockout/tagout procedure, detailing shutdown steps, isolation points, and required devices along with step-by-step instructions for isolating electrical, hydraulic, pneumatic, and other hazardous energy sources. Make these procedures easily accessible to authorized employees and be sure to review the OSHA 29 CFR 1910.147(c)(4) standard for guidance.
3. Proper Lockout Devices and Padlocks
Invest in durable, substantial and standardized lockout devices and padlocks that allow your authorized employees to achieve a compliant lockout while maintaining exclusive control when performing servicing and maintenance. LOTO devices and locks must only be used specifically for locking out equipment. Remember that it is the facilities responsibility to provide these devices to their employees and to ensure that these devices are identifiable with information pertaining to who is using them. Please reference OSHA 29 CFR 1910.147(c)(5) standard for guidance.
4. Lockout vs. Tagout Requirements
Identification tags that are typically used with locks for energy isolation under “lockout” are not considered as “tagout”. If you are choosing to utilize “tagout” instead of “lockout” you must have specific types of tags and have additional information explaining why “lockout” is not used and if the tags will provide a level of protection while maintaining exclusive control. In short, always use “lockout” when possible. Please reference OSHA 29 CFR 1910.147(c)(3) standard for guidance.
5. Employee Training and Retraining
Training is non-negotiable. Both “authorized”, “affected” and “other” employees must understand energy hazards, lockout/tagout steps, and tag limitations. Retrain whenever equipment or procedures change. There are responsibilities not just with your employees but with temporary workers and contractors to ensure that they are trained. Please reference OSHA 29 CFR 1910.147(c)(7) standard for guidance.
6. Isolation and Verification of Hazardous Energy
Verification should be your last step when locking out the equipment before maintenance or servicing begins. Verifying your lockout by confirming that all energy sources are fully isolated and the machine is in a zero-energy state to prevent unexpected startup or stored energy release. Follow your normal start up procedure for the specific equipment at hand to help with this verification process. Please reference OSHA 29 CFR 1910.147(c)(4)(ii)(C) standard for guidance.
7. Annual Periodic Inspections
OSHA requires an annual periodic inspection must be performed for all your existing LOTO procedures and authorized employees. The annual inspection is crucial in maintaining your energy control program by revealing results of employee comprehension with utilizing the LOTO procedure correctly when performing a” lockout” on the employee inspection side and identifying any procedural changes with your existing procedures on the procedural audit side. These results could trigger retraining and give you a good gauge of the facility’s safety wellness. Please reference OSHA 29 CFR 1910.147(c)(6) standard for guidance.
8. Group Lockout Procedures
When multiple employees work on the same equipment, implement a group lockout system. Assign a primary authorized employee and ensure each worker verifies isolation individually to achieve exclusive control. When it comes to performing group lockouts your authorized employees should always defer to a “Trust but Verify” mentality. Utilizing hasps or lock boxes are the most common methods for this process. Please reference OSHA 29 CFR 1910.147(f)(3) standard for guidance.
9. Control of All Hazardous Energy Sources
Don’t overlook “non-lockable” energy sources (i.e. thermal, capacitance, gravity, kinetic) when creating your LOTO procedures. The “non–lockable” energy sources are just as important as “lockable” energy sources and are vital to having compliant LOTO procedures. Neutralizing these energy sources are essential for achieving a zero-energy state when performing “lockout”. In short you need to account for non-lockable energy sources in your procedures. Please reference OSHA 29 CFR 1910.147(b)(energy source) & 1910.147 App A standard for guidance.
10. Shift Changes and Contractor Coordination
Having a process in place for shift change and contractors performing work at your facility is key. This is important because miscommunication or gaps in protection during personnel changes or contractor work can lead to unexpected energization, which can lead to serious injuries or fatalities. Regularly reviewing your protocols and trainings for these situations will help maintain compliance and ensure personnel safety. Please reference OSHA 29 CFR 1910.147(f)(2) & 1910.147(f)(4) standard for guidance.
Why LOTO Compliance Matters
A strong LOTO program protects lives, reduces downtime, and avoids costly OSHA penalties. Compliance isn’t just about regulations—it’s about creating a culture of safety and ensuring your employees go home safe.
About the Author
Paul Heffernan is an executive operations and supply-chain leader with more than 25 years of experience improving safety, efficiency, and operational performance across global manufacturing and industrial environments. He has led large-scale transformation programs, built high-reliability safety systems, and partnered closely with frontline teams to create cultures where people feel protected and empowered.