Lockout/tagout is a perennial on OSHA's most-cited list, and the reason is rarely the padlock. It's the paperwork around the padlock: the missing machine-specific procedure, the periodic inspection that never happened, the "affected" employee who was never trained. Here's what the standard asks for and where programs come apart.
What the standard covers
The Control of Hazardous Energy standard, 29 CFR 1910.147, applies to the servicing and maintenance of machines and equipment where the unexpected startup, energization, or release of stored energy could injure someone. "Energy" is broader than electrical — it includes hydraulic, pneumatic, mechanical, thermal, chemical, and gravitational energy.
The written program has three parts
- Energy-control program — your overall written policy for how hazardous energy is controlled.
- Energy-control procedures — the machine-specific steps. This is the part inspectors ask for by name: a documented procedure for each machine (or a group of similar machines) covering how to shut it down, isolate it, lock it, and verify. A generic one-page policy is not a substitute for machine-specific procedures.
- Training and periodic inspection — proof that people know the procedures and that the procedures are actually being followed.
The six steps of a lockout
Every compliant lockout follows the same sequence:
- Prepare — identify the energy sources and the magnitude of the hazard.
- Shut down the machine using its normal stopping procedure.
- Isolate each energy source (open the disconnect, close the valve).
- Apply lockout devices — each authorized employee applies their own lock.
- Release stored energy — bleed pressure, discharge capacitors, block suspended parts, let it cool.
- Verify isolation — try to start the machine (then return controls to off), and test with instruments where needed. This "try" step is the one most often skipped.
Who's who
- Authorized employees perform the lockout and the servicing. They get the most training.
- Affected employees operate the machine being serviced. They need to recognize when lockout is in effect and know not to restart.
- Other employees work in the area. They need awareness training.
Getting these categories right matters because training obligations differ by role — and citations often turn on an "affected" operator who was never told what a lock on the disconnect means.
The periodic inspection people forget
At least annually, an authorized employee who isn't using the procedure being inspected must review each energy-control procedure with the employees who use it, and certify that the review happened — who, what procedure, the date, and the employees involved. Miss this and you have a paperwork gap that's easy for an inspector to find and hard to backfill.
Two exceptions that get misread
- Minor servicing during normal operations (routine, repetitive, integral to production) can be exempt if it's covered by an alternative measure that provides effective protection. This is narrow — don't stretch it to cover real maintenance.
- Cord-and-plug equipment can be exempt when unplugging fully controls the energy and the plug stays under the exclusive control of the person servicing it.
Where it becomes a records problem
Padlocks are cheap; the discipline around them is the hard part — a current procedure for every machine, role-correct training records, and an annual inspection that actually gets certified. That's records and follow-through, which is where software helps.
SE Worldwide manages lockout as a permit-to-work with machine-specific procedures attached, tracks who's authorized on what, and schedules the annual periodic inspection so it doesn't lapse — with a signed, tamper-evident record of each review. See permits and control-of-work for how it fits the wider program.
This article is general information about health, safety, and environmental regulations, not legal or compliance advice. Rules change and apply differently by site — verify against the current regulation and your own obligations. See our Terms of Use.