Lockout/Tagout (LOTO) is consistently among OSHA's top 10 most-cited violations, reflecting widespread compliance challenges across manufacturing, maintenance, and industrial operations. OSHA estimates that failure to properly control hazardous energy accounts for nearly 10% of serious accidents in many industries, resulting in approximately 120 fatalities and 50,000 injuries per year. The 29 CFR 1910.147 standard requires not only written energy control procedures and employee training, but also periodic inspections to verify that procedures are being followed correctly. This guide covers the OSHA inspection requirements for LOTO programs, what to include in a periodic inspection, and provides a free downloadable checklist.
Free LOTO Inspection Checklist
Download our Word document checklist for conducting annual periodic inspections of your lockout/tagout energy control procedures.
Download Checklist (.docx)Why LOTO Inspections Are Required
OSHA 29 CFR 1910.147 — The Control of Hazardous Energy
This standard requires employers to establish an energy control program consisting of three elements: energy control procedures, employee training, and periodic inspections. Key inspection requirements:
- 1910.147(c)(6)(i): The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.
- 1910.147(c)(6)(i)(A): The periodic inspection shall be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected.
- 1910.147(c)(6)(i)(B): The periodic inspection shall be conducted to correct any deviations or inadequacies identified.
- 1910.147(c)(6)(i)(C): Where lockout is used, the inspector must review each authorized employee's responsibilities under the energy control procedure.
- 1910.147(c)(6)(i)(D): Where tagout is used, the inspector must review with both authorized and affected employees their responsibilities, including the limitations of tags.
Documentation Requirements — 1910.147(c)(6)(ii)
The employer must certify that periodic inspections have been performed by documenting at minimum:
- The machine or equipment on which the energy control procedure was being used
- The date of the inspection
- The employees included in the inspection
- The person performing the inspection
Periodic Inspection — Procedure Review
The periodic inspection verifies that written energy control procedures are accurate, complete, and being followed. For each procedure inspected, verify the following:
| Inspection Item | What to Verify |
|---|---|
| Procedure identification | Procedure identifies the specific machine or equipment, its location, and the types of energy (electrical, mechanical, hydraulic, pneumatic, chemical, thermal, gravitational) to be controlled. |
| Shutdown sequence | Written steps for normal shutdown of the machine or equipment are accurate and complete. Sequence matches current equipment configuration. |
| Energy isolation points | All energy-isolating devices are correctly identified (breakers, valves, disconnects). Any new energy sources added since the procedure was written are included. |
| Lockout/tagout placement | Procedure specifies where locks and/or tags are to be applied. Steps for attaching devices to each isolation point are clear and correct. |
| Stored energy dissipation | Procedure addresses all forms of stored or residual energy (capacitors, springs, elevated components, pressurized lines, hot surfaces). Methods for dissipation or restraint are specified. |
| Verification of isolation | Procedure requires verification that all energy sources have been effectively isolated. Methods specified (try start button, test with voltmeter, check pressure gauges). |
| Release from lockout | Procedure includes steps for removing locks/tags, ensuring work area is clear, notifying affected employees, and restoring equipment to service. |
| Procedure accuracy | Procedure reflects current equipment configuration. Any modifications, new energy sources, or changed isolation points since the last review are incorporated. |
Periodic Inspection — Employee Review
A critical component of the periodic inspection is verifying that employees understand their responsibilities. The inspector must observe and review with each type of employee:
| Review Item | What to Verify |
|---|---|
| Authorized employee knowledge | Authorized employees can demonstrate the correct lockout/tagout procedure for the specific machine. They understand each step and can explain why it is necessary. |
| Procedure execution observation | Inspector observes an authorized employee performing the lockout/tagout procedure on the machine or equipment. Verify each step matches the written procedure. |
| Affected employee awareness | Affected employees understand the purpose and function of the energy control procedure. They know they must not attempt to restart or re-energize equipment that is locked or tagged out. |
| Other employee awareness | Other employees in the area recognize lockout/tagout devices and understand they must not remove them or attempt to operate locked-out equipment. |
| Group lockout procedures | If group lockout is used, each authorized employee applies a personal lock. A primary authorized employee coordinates the group lockout. Communication procedures are followed. |
| Shift/personnel changes | Procedures for transferring lockout/tagout protection between shifts or between employees are understood and followed. Continuity of protection is maintained. |
Equipment and Device Inspection
While OSHA's periodic inspection focuses on procedures and employee compliance, a thorough LOTO program also includes verification of physical devices and equipment:
| Inspection Item | What to Verify |
|---|---|
| Lockout devices | Locks are durable, standardized by color/shape/size, substantial enough to prevent removal without excessive force, and labeled with the authorized employee's identity. |
| Tagout devices | Tags are durable (withstand environment for duration of use), standardized, legible, include employee identity, and include warning legend ("Do Not Start," "Do Not Operate," etc.). |
| Energy-isolating devices | All isolation devices (breakers, disconnects, valves) are operational and capable of being locked out. Lockable devices that are not locked out are identified for correction. |
| Lockout device inventory | Adequate supply of locks, tags, hasps, and other devices available. Devices are used exclusively for energy control (not used for other purposes). |
| Labeling of isolation points | Energy isolation points on equipment are clearly labeled and correspond to the written procedure. Labels are legible and not obstructed. |
Corrective Actions
Deviations Found During Inspection
- Document all deviations and inadequacies identified during the inspection
- Correct the energy control procedure immediately if it does not reflect current equipment configuration
- Provide retraining to any employee whose knowledge or execution of the procedure was deficient
- Certify that retraining has been accomplished with employee name and date
- Verify that corrective actions have been completed before the next use of the procedure
Common Deficiencies
- Procedures that do not identify all energy sources (especially stored energy)
- Missing or inadequate verification of isolation steps
- Employees skipping steps or performing steps out of sequence
- Equipment modifications not reflected in the written procedure
- Lockable energy-isolating devices that are not being locked out
- Tagout used when lockout is feasible and should be required
- Locks or tags without proper employee identification
- Missing or incomplete documentation of previous inspections
Best Practices
Program Management
Maintain a master list of all energy control procedures and track which have been inspected each year. Use a scheduling system to ensure every procedure is inspected within its annual window. Inspection software can automate scheduling, send reminders when inspections are due, and generate audit-ready documentation showing compliance across all procedures.
Training Integration
OSHA requires initial training for all authorized, affected, and other employees, plus retraining when inspections reveal deficiencies or when there are changes to equipment, procedures, or job assignments. Training management software can track who has been trained, when they were trained, and when retraining is due.
Procedure Development
Each machine-specific procedure should be developed by someone with knowledge of the machine's energy sources and isolation methods. Procedures should be reviewed and updated whenever equipment is modified, energy sources change, or a periodic inspection reveals inaccuracies. Keep procedures accessible at the point of use — either as laminated cards on the equipment or through a mobile-accessible digital system.
Download the Free Checklist
Get our LOTO inspection checklist in Word format. Customize it for your specific energy control procedures and equipment.
Download Checklist (.docx)Ecesis EHS Software
Inspections
Digital inspection forms with scheduling, mobile completion, and corrective action tracking.
Safety Inspections
Workplace safety inspections with automated scheduling and deficiency tracking.
Training
Track LOTO training, certifications, and schedule retraining when inspections identify deficiencies.
Preventive Maintenance
Coordinate maintenance activities with LOTO procedures and track equipment modifications.
Compliance Calendar
Track annual LOTO inspection deadlines, training renewals, and procedure review dates.
Task Management
Assign and track corrective actions from LOTO inspection findings to completion.
