Top 5 LOTO violations and how to avoid them

OSHA’s lockout/tagout (LOTO) standard ranks among the agency’s most frequently cited general industry standards. It covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees.

Following are the top 5 most frequently cited violations of 1910.147 in fiscal year 2025.

#1 – Energy control procedures, 1910.147(c)(4)(i)

Employers covered by the LOTO standard must establish an energy control program tailored to the machinery and equipment in the workplace. A key component of this program is the development and use of energy control procedures. These procedures outline the specific steps employees must follow to shut down, isolate, lock or tag, and verify the isolation of energy sources before servicing or maintenance begins. Ensuring equipment isn’t energized helps prevent the unexpected startup or release of stored energy that could result in injury or death.

#2 - Periodic inspections, 1910.147(c)(6)(i)

Energy control procedures must be inspected at least annually to verify that employees are following both the procedure and the requirements of the LOTO standard. These periodic inspections must be conducted by an authorized employee who is not using the procedure being reviewed and must identify and correct any deviations or inadequacies.

Employers must certify that the inspection was completed. The certification must identify the machine or equipment on which the energy control procedure was being used, the date of the inspection, the employees involved, and the person who performed the inspection.

#3 - Energy control program, 1910.147(c)(1)

Employers must establish and maintain an energy control program that includes energy control procedures, periodic inspections, and employee training. As outlined in 1910.147(c)(7), employers must provide training to ensure employees understand the purpose and function of the energy control program and have the knowledge and skills necessary to safely apply, use, and remove energy control devices.

#4 - Procedure elements, 1910.147(d)

Energy control procedures must address specific elements and actions in the following order:

1. Preparation for shutdown,
2. Machine or equipment shutdown,
3. Lockout or tagout device application,
4. Stored energy, and
5. Verification of isolation.

#5 - Authorized employee training, 1910.147(c)(7)(i)(A)

Authorized employees must be trained in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. An authorized employee is one who locks out or tags out machines or equipment in order to perform servicing or maintenance.