OSHA's Control of Hazardous Energy standard (29 CFR 1910.147) requires employers to establish an energy control program that includes energy control procedures, employee training, and periodic inspections. While equipment-level LOTO inspections verify that specific lockout/tagout procedures are being followed correctly, a program audit evaluates the entire energy control program including written procedures for all applicable equipment, the periodic inspection process, training program adequacy, and overall program management. OSHA specifically requires annual periodic inspections of each energy control procedure, making program-level audits essential.
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Download Checklist (.docx)Regulatory Requirements
OSHA 29 CFR 1910.147 — Control of Hazardous Energy
The standard requires an energy control program consisting of energy control procedures, an employee training program, and periodic inspections. Employers must develop, document, and utilize procedures for the control of potentially hazardous energy. The standard applies to the servicing and maintenance of machines and equipment where unexpected energization or startup could cause injury.
Annual Periodic Inspection Requirement
OSHA requires periodic inspections of each energy control procedure at least annually per 1910.147(c)(6). The inspection must be performed by an authorized employee other than the one using the procedure being inspected. The inspection must include a review between the inspector and each authorized employee to verify understanding. The employer must certify the inspection was performed.
OSHA Enforcement and Citations
Lockout/tagout consistently ranks among OSHA's most frequently cited standards. Common citations include failure to develop machine-specific procedures, failure to conduct annual periodic inspections, inadequate training, and failure to follow established procedures. Serious violations can result in penalties up to $16,131 per violation; willful violations up to $161,323.
Written Program and Procedures
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Energy control program | A written energy control program exists that addresses the three core components: energy control procedures, employee training, and periodic inspections. The program is documented, available to employees, and current. |
| Machine-specific procedures | Written energy control procedures exist for each machine or piece of equipment requiring lockout/tagout. Each procedure identifies the specific types and magnitudes of energy, the location of isolating devices, and the sequential steps for shutdown, isolation, lockout, and restoration. |
| Procedure completeness | Each procedure includes: specific statement of intended use, procedural steps for shutting down and isolating the machine, steps for applying lockout/tagout devices, steps for verifying isolation (try/test), steps for releasing stored/residual energy, and the sequence for restoring the machine to service. |
| Group lockout procedures | Procedures exist for group lockout/tagout situations where multiple employees service the same equipment. Procedures designate primary authorized employee responsibility, ensure continuity of protection during shift changes, and account for all energy-isolating devices. |
| Procedure exceptions | If the employer uses the exception for machines with no stored or residual energy (1910.147(c)(4)(i)), documentation justifies the exception for each applicable machine. The eight criteria for the exception are verified and documented. |
Annual Periodic Inspections
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Inspection completion | Each energy control procedure has been inspected within the last 12 months. Inspections are conducted by an authorized employee other than the one(s) utilizing the procedure being inspected. All applicable procedures are covered. |
| Inspection process | Each inspection includes a review between the inspector and each authorized employee of their responsibilities under the energy control procedure. For lockout procedures, this includes direct observation. For tagout-only procedures, this includes employee consultation on limitations. |
| Certification records | Employer has certified that periodic inspections have been performed. Certification records identify the machine/equipment, the date of inspection, the employees included in the inspection, and the person performing the inspection. |
| Deficiency correction | Deficiencies identified during periodic inspections are documented and corrected. Procedures are updated as needed. Retraining is provided when inspections reveal knowledge gaps. |
Training Program
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Authorized employee training | All authorized employees have received training in the recognition of applicable hazardous energy sources, the type and magnitude of energy in the workplace, and the methods and means for energy isolation and control. |
| Affected employee training | All affected employees have been instructed in the purpose and use of the energy control procedure. Affected employees understand they must not attempt to restart or re-energize equipment that is locked or tagged out. |
| Other employee training | All other employees whose work may be in an area where energy control procedures may be utilized have been instructed about the procedure and the prohibition against removing lockout/tagout devices or attempting to re-energize equipment. |
| Retraining | Retraining is provided when there is a change in job assignments, a change in machines or equipment, a change in energy control procedures, or when a periodic inspection reveals inadequacies. Retraining is also provided when new hazards are introduced. |
| Training documentation | Training records document each employee's name, training dates, and the content of training. Records demonstrate that all three employee categories (authorized, affected, other) have received appropriate training. |
Equipment and Devices
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Lockout devices | Lockout devices are durable, standardized (color, shape, or size), substantial enough to prevent removal without excessive force, and identify the employee who applied them. Each authorized employee has an individually keyed lock. |
| Tagout devices | Tagout devices (if used) are standardized, durable (weather-resistant), substantial (non-reusable, attachable by hand, self-locking, non-releasable with minimum 50 pounds pull strength), and identify the employee who applied them. Warning language is legible and standardized. |
| Energy-isolating devices | All energy-isolating devices on covered equipment are identified. Devices are capable of being locked out (or tagged out with additional measures). Push buttons, selector switches, and similar control circuit devices are NOT used as energy-isolating devices. |
| Device inventory | Adequate supply of lockout/tagout devices is maintained. Devices are available when needed. Replacement process ensures continuous availability. Devices are inspected periodically for condition. |
Corrective Actions
Common Issues and Responses
- Missing machine-specific procedures: Conduct an inventory of all equipment requiring LOTO. Develop written procedures for each machine/equipment with input from authorized employees. Include all energy types and isolation points.
- Overdue periodic inspections: Schedule and conduct inspections immediately. Ensure inspectors are authorized employees not involved in the procedures being inspected. Complete certifications for each inspection.
- Training gaps: Identify all employees requiring training by category (authorized, affected, other). Schedule and conduct appropriate training. Document training with employee names, dates, and content.
- Inadequate lockout devices: Assess current device inventory against authorized employee count and equipment requirements. Purchase standardized, individually keyed devices. Distribute and assign to authorized employees.
- Procedure inaccuracies: Walk down each procedure against actual equipment configuration. Update procedures to reflect current energy sources, isolation points, and equipment modifications. Retrain affected authorized employees on updated procedures.
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Inspections
Digital periodic inspection forms with certification tracking and deficiency management.
Document Management
Centralized storage for machine-specific procedures, inspection certifications, and program documents.
Training
Track LOTO training by employee category with automatic refresher reminders.
Compliance Calendar
Annual periodic inspection schedules and training deadline tracking.
Task Management
Track corrective actions from periodic inspections and program audits.
Safety Inspections
Workplace safety inspections with LOTO compliance verification checklists.
