Smarter HR SolutionsHouston, TX
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for employee handbooks, HR policies, HR compliance audits and OSHA written programs.
- Standards
- Pricing
- Not published
Lockout/Tagout Energy Control Program
OSHA's control of hazardous energy standard requires employers to establish an energy control program made of three parts: written energy control procedures for each machine or type of machine, employee training, and periodic inspections at least annually.
The written procedures must state the scope, purpose, authorization, rules and techniques for controlling energy, and the specific steps for shutting down, isolating, blocking and securing equipment, placing and removing locks and tags, and verifying isolation.
Lockout/tagout is consistently among OSHA's ten most cited standards, and the citations cluster on two documentary failures: no machine-specific procedure, and no record of the annual inspection.
Contractor prequalification networks grade the written program as a standalone upload, so the same document does double duty for manufacturers, contractors and facility maintenance teams.
Also called: LOTO program, Hazardous energy control program, Energy control procedures
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Who requires it, and what each one says.
| Source | Applies when | What it requires | Status |
|---|---|---|---|
| OSHA Control of hazardous energy, energy control program 29 CFR 1910.147(c)(1) | Servicing or maintenance of machines where unexpected energization could injure | An energy control program consisting of energy control procedures, employee training and periodic inspections. Legally required. | Mandatory |
| OSHA Control of hazardous energy, procedures 29 CFR 1910.147(c)(4) | Always, unless the eight-condition exception in (c)(4)(i) applies | Procedures developed, documented and used; each must state its intended use, the steps for shutdown and isolation, the steps for placing and removing lockout devices, and the requirements for testing isolation. Legally required. | Mandatory |
| OSHA Control of hazardous energy, periodic inspection 29 CFR 1910.147(c)(6) | At least annually per procedure | An authorized employee other than the one using the procedure inspects it, corrects deviations, reviews responsibilities with each authorized employee, and the employer certifies the inspection with machine, date, employees included and inspector. Legally required. | Mandatory |
| OSHA Control of hazardous energy, training and certification 29 CFR 1910.147(c)(7) | Always | Training for authorized, affected and other employees; retraining on change of assignment, machines, procedures or after a deficient inspection; certification with each employee's name and training dates. Legally required. | Mandatory |
| OSHA enforcement directive CPL 02-00-147 (February 11, 2008) | OSHA inspection | Inspectors verify the written procedures are machine-specific, that the annual inspection certification exists, and that training certifications match the authorized employee list. Examiner expectation documented in the directive. | Implied |
| ISNetworld RAVS and Avetta reviews Client-specific requirements | You bid work through a prequalification network | Upload of the written LOTO program graded against OSHA elements and client additions. Contractual. | Market |
Required sections
- Program purpose, scope and applicability, including the minor servicing and cord-and-plug exclusions (1910.147(a))
- Definitions: authorized, affected and other employees; energy source; energy isolating device
- Statement of intended use of each procedure and the rules and techniques for energy control (c)(4)(ii)(A) to (B))
- Machine-specific or group procedures: shutdown, isolation, lockout or tagout application, stored energy release, verification of isolation (d)(1) to (d)(6))
- Release from lockout: inspection, employee positioning, device removal, notification (e)
- Lockout device and tagout device specifications: durable, standardized, substantial, identifying the user (c)(5)
- Tagout limitations and the additional protection required when tagout is used alone (c)(2) to (c)(3))
- Group lockout, shift change and personnel change procedures (f)(3) to (f)(4))
- Outside contractor coordination (f)(2)
- Testing or positioning of equipment during servicing (f)(1)
- Periodic inspection process and certification content (c)(6)
- Training program by employee class, retraining triggers, training certification (c)(7)
- Procedure for removing a lockout device when the authorized employee is unavailable (e)(3), single source)
What the examiner asks for
Written planThe program document plus the library of machine-specific procedures, each dated and identified to the equipment. Safety consultants and LOTO procedure-writing services; policy tools hold versions
AttestationTraining certification listing each employee's name and training dates by class; retraining records after inspections or changes. Safety training vendors, LMS, policy tools
Operational recordsAnnual periodic inspection certifications per procedure with machine, date, employees included and inspector; deviation corrections. The employer; safety consultants who run the inspections
Technical controlsLock and tag inventory, energy isolation points labeled on equipment, group lockbox hardware. Safety equipment suppliers; LOTO software with photo procedures
Change log.
2019-05-20OSHA published a Request for Information on updating 1910.147 for control-circuit-type devices and robotics; no final rule as of last check.
2011-12-09OSHA revised the standard's minor servicing and control-circuit interpretations through directive updates; standard text substantively unchanged since 1990.
2008-02-11Compliance directive CPL 02-00-147 issued February 11, 2008, replacing STD 01-05-019 as the enforcement guidance.
1990-01-02Original standard effective (published Sept 1, 1989).
Where this document is required.
Where this document gets checked.
No one certifies a document like this on its own. It is read during the audits and inspections below, and by the agency behind each rule.
| Where it is looked at | Who looks at it |
|---|---|
| OSHA written programs | OSHA compliance safety and health officers, or State Plan inspectors (government inspection). No certification exists; voluntary recognition programs such as VPP and SHARP involve OSHA or consultation program evaluation |
Consultants.
Firms that name these standards in their own material.
Listed in random order, reshuffled each time the page loads. Firms that pay for a listing are shown at the top, labeled Sponsored.
Passio PEO and HR ConsultingEnglewood, CO, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, Harassment prevention training.
- Standards
- Pricing
- Not published
GreenLine HR Consulting LLCMeadville, PA, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, HR compliance audit.
- Standards
- Pricing
- Not published
Upstream Solutions, LLCUSA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance.
- Standards
- Pricing
- Not published
Software.
Tools that hold documents like this one and record who has read them.
Need a hand implementing it?
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From the publisher
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What people ask.
Do we need a procedure for every machine?
You need one for every machine or piece of equipment unless a group of machines shares the same energy types, isolation points and steps, in which case one procedure can cover the group if all eight conditions in the standard's note to (c)(4)(i) are met. Document why the group qualifies.
What does the annual inspection record have to contain?
The machine or equipment, the date, the employees included, and the person performing the inspection. It must be done by an authorized employee other than the one using the procedure being inspected.
Is a generic LOTO policy enough?
No. OSHA's most common LOTO citation is a program with no machine-specific procedures. The policy is the program document; the procedures are the part that gets inspected.
Does this apply to contractors on our site?
Yes. The host and the contractor must inform each other of their procedures, and your employees must understand the contractor's program where it affects them (f)(2).