*Lockout/Tagout (LOTO) has ranked in OSHA's top five most cited standards for over a decade. In fiscal year 2025, the Control of Hazardous Energy standard (29 CFR 1910.147) generated 2,177 violations and climbed to fourth position on the annual list [1]. The year before, it accounted for 2,443 citations [2]. These are not obscure technicalities - they represent real gaps in safety programmes that leave workers exposed to hazardous energy every day. This guide breaks down the 10 specific violations that generate the most citations, with practical fixes for each.*
## 1. No Energy Control Programme
**The regulation:** 1910.147(c)(1) requires employers to establish a programme consisting of energy control procedures, employee training, and periodic inspections.
**Why companies get cited:** This is the foundational requirement. Without a documented programme, every other element of the standard is automatically out of compliance. OSHA issued 210 citations under this sub-paragraph in FY2024 alone [3]. Some employers have informal practices but nothing written down. Others have a generic policy that does not meet the standard's requirement for machine-specific procedures.
**The fix:** Develop a formal, written energy control programme that covers three pillars: documented procedures for each machine or equipment type, a training programme for all employee categories, and a schedule for periodic inspections. This is the backbone that everything else hangs from.
## 2. No Written Energy Control Procedures
**The regulation:** 1910.147(c)(4) requires documented procedures for the application of energy control, covering the specific steps for shutting down, isolating, blocking, and securing machines.
**Why companies get cited:** Many facilities rely on "tribal knowledge" - experienced technicians who know how to lock out each machine from memory but have never committed the steps to paper. This works until someone new joins the team, someone forgets a step, or an auditor asks to see the documentation.
**The fix:** Create machine-specific written procedures for every piece of equipment covered by the standard. Each procedure should identify the equipment, all energy sources, the specific isolation points, the type and location of each energy-isolating device, and the steps for verifying isolation.
## 3. Inadequate or Missing Training
**The regulation:** 1910.147(c)(7) requires training for three categories of employee: authorised employees (who perform LOTO), affected employees (who operate equipment), and other employees (who work in areas where LOTO is performed).
**Why companies get cited:** Training citations are among the most common. The failures range from having no training programme at all, to training only maintenance staff and ignoring operators, to failing to retrain when procedures change or when periodic inspections reveal knowledge gaps. OSHA requires not just that training occurs, but that it is effective - employees must demonstrably understand their responsibilities [4].
**The fix:** Implement a structured training programme that covers all three employee categories. Document every session with dates, attendees, content covered, and the trainer's name. Retrain whenever job assignments change, new equipment is introduced, or an inspection identifies a deficiency.
## 4. No Periodic Inspections
**The regulation:** 1910.147(c)(6) requires an inspection of each energy control procedure at least annually, conducted by an authorised employee who is not the one using the procedure being inspected.
**Why companies get cited:** Annual inspections are one of the most frequently neglected requirements. Some companies inspect a random sample of procedures and assume it is sufficient. Others conduct the inspection but fail to include the mandatory one-to-one review of employee responsibilities. Many simply let it slip off the calendar.
**The fix:** Schedule inspections for every energy control procedure, not just a sample. Each inspection must include a field observation of the procedure being performed and a review of responsibilities with each authorised employee. Certify every inspection with the machine, date, employees included, and inspector's name.
## 5. Failure to Apply Lockout/Tagout During Servicing
**The regulation:** 1910.147(d) covers the application of energy control during servicing and maintenance. Citations under this sub-paragraph totalled 203 in FY2024 [5].
**Why companies get cited:** Workers perform servicing activities without actually locking out the equipment. This can happen when time pressure encourages shortcuts, when the task is perceived as "minor" and therefore exempt, or when the culture tolerates working on energised equipment. The minor servicing exception in 1910.147(a)(2)(ii) is narrow and frequently misapplied - it requires the work to be routine, repetitive, integral to production, and protected by alternative measures.
**The fix:** Enforce a zero-tolerance policy for working on equipment without LOTO applied, unless the task genuinely qualifies under the minor servicing exception with documented alternative measures. Make lockout devices readily accessible so that "it takes too long to get a lock" is never a valid excuse.
## 6. Inadequate Lockout/Tagout Devices
**The regulation:** 1910.147(c)(5) requires that lockout and tagout devices be durable, standardised, substantial, and identifiable. Each device must indicate the identity of the employee who applied it.
**Why companies get cited:** Using generic padlocks without identification, reusing damaged tags, or deploying devices that are not substantial enough to prevent removal without excessive force. Another common issue is using tagout where lockout is possible - the standard requires lockout unless the energy-isolating device is not capable of being locked out.
**The fix:** Invest in standardised, purpose-built LOTO devices: individually keyed safety padlocks clearly labelled with the employee's name or ID, durable tags that withstand the environment, and the correct lockout devices for each type of energy-isolating point in your facility.
## 7. No Verification of Isolation
**The regulation:** 1910.147(d)(6) requires that after energy-isolating devices have been applied, the authorised employee must verify that isolation has been achieved by attempting to operate the equipment's normal operating controls.
**Why companies get cited:** This "try-out" step is one of the most frequently skipped in practice. Technicians apply the locks and tags, assume the equipment is de-energised, and begin work without confirming it. For equipment with stored energy (hydraulic, pneumatic, gravitational), skipping verification is particularly dangerous because residual energy can persist even after the primary source is isolated.
**The fix:** Make verification a non-negotiable step in every procedure. Train employees to attempt normal start-up after lockout, check pressure gauges for zero readings on hydraulic and pneumatic systems, and confirm that suspended loads are mechanically supported.
## 8. Group Lockout Failures
**The regulation:** 1910.147(f)(3) sets out requirements for group lockout operations, including designating a primary authorised employee with overall responsibility and ensuring each worker applies a personal lockout device.
**Why companies get cited:** Group lockout is inherently more complex than individual LOTO, and the coordination requirements are frequently mismanaged. Common failures include not designating a primary authorised employee, allowing workers to begin before all personal locks are applied, and failing to maintain the integrity of the lockout during shift changes.
**The fix:** Develop specific group lockout procedures that address the designation of the primary authorised employee, personal lock application for every worker, communication protocols, and shift-change handover processes. Use group lockout boxes to centralise control of isolation keys.
## 9. Contractor Coordination Failures
**The regulation:** 1910.147(f)(2) requires that whenever outside servicing personnel perform LOTO-covered work, the host employer and contractor must inform each other of their respective lockout/tagout procedures.
**Why companies get cited:** The two-way communication requirement is frequently overlooked. Contractors arrive on site and begin work without either party sharing their energy control procedures. Under OSHA's multi-employer citation policy, both the host and the contractor can be cited for the same violation.
**The fix:** Build LOTO procedure exchange into your contractor onboarding process. Before any contractor begins work, document the exchange of procedures, agree on who performs the primary isolation, and confirm that each contractor worker has personal lockout protection.
## 10. Failure to Remove and Re-Apply LOTO for Testing
**The regulation:** 1910.147(f)(1) addresses the temporary removal of lockout/tagout devices for testing or positioning equipment. It requires a specific sequence: clearing the machine, removing employees, removing devices, testing, then re-applying control measures before servicing resumes.
**Why companies get cited:** When equipment needs to be temporarily re-energised during a maintenance activity - for pressure testing, start-up verification, or positioning - the standard demands a strict, documented sequence. Many facilities handle this informally, with workers pulling locks to "quickly test" without following the required steps or documenting the temporary removal.
**The fix:** Develop specific procedures for temporary LOTO removal that follow the regulatory sequence exactly. Document every removal and re-application with timestamps, the reason for removal, who performed it, and confirmation that all safety steps were followed.
## The Root Cause: Paper Cannot Scale
What connects most of these violations is not a lack of intent but a lack of infrastructure. Paper-based LOTO systems make it difficult to maintain current procedures, track training comprehensively, schedule and certify inspections, coordinate group lockouts, manage contractor exchanges, and document temporary removals.
[Zentri](https://www.zentri.cc) was built to address these root causes systematically. As a purpose-built digital LOTO platform, it provides equipment-based lockout procedures with pre-defined isolation points and photo-verified steps, approval workflows for procedure sign-off, automated audit trails that satisfy OSHA's certification requirements, real-time visibility into active lockouts for supervisors and safety managers, and compliance reporting that turns inspection preparation from a week-long scramble into a button click.
Proper LOTO compliance prevents an estimated 120 fatalities and 50,000 injuries every year [6]. Every violation on this list represents a gap between what the standard requires and what a facility actually does. Closing those gaps is not just a regulatory exercise - it is the difference between a worker going home safely and one who does not.
**Ready to close the gaps in your LOTO programme?** [Book a free Zentri demo](https://www.zentri.cc/demo) to see how a digital platform eliminates the root causes of the most common LOTO violations.
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### References
1. Evotix, "A Look at OSHA's Top 10 Most Cited Violations of 2025" - [evotix.com](https://www.evotix.com/resources/blog/a-look-at-oshas-top-10-most-cited-violations-of-2025)
2. NAHB, "Top OSHA Violations of 2024 and Higher Penalties for 2025" - [nahb.org](https://www.nahb.org/blog/2025/01/osha-violations-2024)
3. Safety+Health Magazine, "OSHA's Top 10 for 2024" - [safetyandhealthmagazine.com](https://www.safetyandhealthmagazine.com/articles/26129-oshas-top-10)
4. OSHA Standard 29 CFR 1910.147(c)(7) - [osha.gov](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147)
5. Safety+Health Magazine, ibid.
6. OSHA Control of Hazardous Energy Overview - [osha.gov](https://www.osha.gov/control-hazardous-energy)
