Lockout/tagout is not a minor paperwork topic. It remains one of OSHA's most frequently cited standards. In OSHA's FY2025 Top 10 most frequently cited standards, **Control of Hazardous Energy / Lockout-Tagout, 29 CFR 1910.147**, ranked fourth across federal OSHA inspections.[^osha-top-10]
The pattern is usually not that a company has never heard of LOTO. The failure is more often somewhere in the workflow: the procedure is missing, the procedure is too generic, workers are not trained for the actual equipment, stored energy is not controlled, isolation is not verified, group LOTO is poorly coordinated, or the site cannot show reliable evidence after the work is complete.
This article breaks down common OSHA 1910.147 violation patterns, using public OSHA standards, guidance and enforcement examples. The point is not to scare safety teams. The point is to show where LOTO programs actually fail in practice and what controls should be in place to reduce those failure points.
> **Note on OSHA examples:** The enforcement examples below are based on OSHA public inspection records and news releases. Citation status, penalties and classifications can change through contest, settlement, amendment or final order. For that reason, this article uses wording such as "OSHA cited," "OSHA inspection records state" and "OSHA said." This article is general information, not legal advice.
## What OSHA 1910.147 expects
OSHA 1910.147 covers servicing and maintenance of machines and equipment where unexpected energization, startup or release of stored energy could injure employees. The standard establishes minimum performance requirements for controlling hazardous energy.[^osha-standard]
OSHA describes the energy control program as having three core components: **energy control procedures, employee training and periodic inspections**.[^osha-ecp] In the actual standard, those requirements expand into a practical workflow:
- Create and use energy control procedures.
- Train authorized, affected and other employees.
- Inspect procedures at least annually.
- Prepare for shutdown.
- Shut down the machine or equipment.
- Locate and operate each required energy-isolating device.
- Apply lockout or tagout devices.
- Relieve, disconnect, restrain or otherwise make stored energy safe.
- Verify isolation and de-energization before work starts.
- Control release from lockout/tagout before restoring energy.
- Coordinate outside personnel and contractors.
- Control group LOTO and shift or personnel changes.
For a broader explanation of the workflow, see our guide to [how digital lockout/tagout works in practice](/resources/blog/what-is-digital-loto-how-digital-lockouttagout-works-in-practice).
## The most common LOTO violation pattern
Safety+Health's FY2025 OSHA Top 10 analysis reported **2,562 total Lockout/Tagout violations** under 1910.147. The five most cited LOTO sections in that analysis were energy control procedures, training and communication, periodic inspection, the overall energy control program and application of control.[^safety-health-top10]
That ranking is useful because it mirrors what many sites experience in the field. LOTO failures are rarely one isolated mistake. They usually involve a chain of weak controls.
| Common failure | OSHA area | Practical control |
|---|---|---|
| No effective energy control program | 1910.147(c)(1) | Maintain procedures, training and periodic inspection discipline |
| Missing or generic procedures | 1910.147(c)(4) | Create equipment-specific procedures with clear isolation and verification steps |
| Cleaning, setup or adjustment without LOTO | 1910.147 scope/application | Define which non-production tasks require LOTO |
| Energy-isolating devices not controlled | 1910.147(d)(3)-(d)(4) | Map and control every required isolation point |
| Stored or residual energy not controlled | 1910.147(d)(5) | Include pressure, motion, gravity, heat, springs, capacitors and residual energy steps |
| Isolation not verified | 1910.147(d)(6) | Require documented verification before work begins |
| Training gaps | 1910.147(c)(7) | Train by role and by actual equipment risk |
| Annual periodic inspection missed | 1910.147(c)(6) | Schedule and certify annual procedure inspections |
| Group LOTO poorly controlled | 1910.147(f)(3) | Assign responsibility, require personal devices and retain sign-on/sign-off evidence |
| Contractor coordination gaps | 1910.147(f)(2) | Exchange LOTO procedures and clarify restrictions before work starts |
| Release poorly controlled | 1910.147(e) | Use post-execution checks before energy is restored |
## Violation 1: No effective energy control program
OSHA 1910.147(c)(1) requires an energy control program consisting of energy control procedures, employee training and periodic inspections. If that foundation is weak, the rest of the system is usually weak too.
A common failure is treating LOTO as a set of disconnected documents: a procedure in one folder, a training record somewhere else, a paper sign-on sheet near the job, and a review spreadsheet maintained separately. That may look like a program on paper, but it becomes difficult to control once workers are setting up, cleaning, adjusting, clearing jams or maintaining real equipment.
**Real OSHA example:** OSHA cited Family Fresh Pack in 2025 under 1910.147(c)(1). OSHA's public inspection record states that the employer failed to establish an energy control lockout/tagout program for production equipment before assigning personnel to setup, adjustment, teardown, cleaning and sanitation tasks. The citation text describes operators working on energized packaging and cup-sealing equipment, with exposure to caught-in, pinch point and struck-by hazards, and references recordable injuries after unexpected startup because lockout was not performed.[^family-fresh]
How to reduce this failure:
- Maintain a written energy control program that connects procedures, training and periodic inspections.
- Define who is authorized to perform LOTO.
- Make clear which servicing, cleaning, setup, jam-clearing and adjustment tasks require lockout/tagout.
- Keep machine-specific procedures current.
- Retain evidence that procedures were used, reviewed and corrected when deficiencies were found.
Evidence you would want to retain: the energy control program, machine-specific procedures, authorized employee training records, periodic inspection records, completed LOTO execution records and corrective actions.
## Violation 2: Missing or generic machine-specific procedures
OSHA requires procedures to be developed, documented and used for controlling hazardous energy when employees perform covered servicing or maintenance. The procedure must clearly and specifically outline the scope, purpose, authorization, rules and techniques for energy control. It must include specific shutdown, isolation, blocking, securing, placement/removal/transfer and verification requirements.[^osha-standard]
Generic instructions such as "turn off machine and lock out" are usually not enough for equipment with multiple energy sources, stored energy, sequence-specific shutdown steps or confusing isolation points.
**Real OSHA example:** OSHA cited Ascend Elements in 2025 under 1910.147(c)(4)(i). OSHA inspection records state that procedures were not developed, documented and implemented during servicing and maintenance of equipment including dryers, a regenerative thermal oxidizer and shredder machines, exposing employees to amputation, chemical and electrical shock hazards.[^ascend]
**Another example:** OSHA cited Huestis Machine Corporation in 2024 for not having machine-specific lockout/tagout procedures in a production area.[^huestis]
How to reduce this failure:
- Create asset-specific procedures where required.
- Identify all energy sources, not just the obvious electrical disconnect.
- Include equipment-specific shutdown, isolation, lock/tag application, stored energy, verification and restart/release steps.
- Add photos or diagrams where isolation points are hard to identify.
- Control procedure versions so workers know which procedure is current.
Evidence you would want to retain: approved procedure, procedure version, isolation point list, reviewer/approver, last review date, and the completed execution record showing which version was used.
## Violation 3: Cleaning, setup, adjustment or jam-clearing performed without LOTO
One dangerous misconception is that LOTO only applies to major maintenance. OSHA's definition of servicing and maintenance includes activities such as setting up, adjusting, inspecting, modifying, cleaning, unjamming, lubricating and tool changes where employees may be exposed to unexpected energization, startup or release of hazardous energy.[^osha-standard]
This matters because many serious LOTO failures happen during "quick" tasks: cleaning under a conveyor, reaching into a machine to clear a jam, changing a blade, setting up a line or adjusting equipment while production pressure is high.
**Real OSHA example:** OSHA's June 2023 news release on Miracapo Pizza Company said a 29-year-old temporary sanitation worker was fatally injured while using compressed air to clean a moving spiral conveyor. OSHA said temporary workers had not been trained or given authority to stop equipment from moving before cleaning. OSHA also said inspectors identified deficient lockout/tagout procedures, failure to provide locks and failure to train employees in a language they understood on how to lock out equipment such as dough mixers, ovens, sauce depositors, toppings equipment and crust spiral devices.[^miracapo-release]
How to reduce this failure:
- Review sanitation, cleaning, setup, adjustment, jam-clearing and tool-change tasks specifically.
- Decide which tasks require full LOTO and which, if any, qualify for a minor-servicing exception with effective alternative protection.
- Train workers that "quick task" does not mean "no hazardous energy control."
- Give workers authority to stop equipment before cleaning or servicing where LOTO is required.
- Use [LOTO execution checklists](/resources/blog/loto-execution-checklist-pre-execution-and-post-execution-checks) to make critical pre-work checks explicit.
Evidence you would want to retain: task classification, procedure used, authorized employee identity, pre-execution checklist, lock/tag application evidence, verification record and closeout record.
## Violation 4: Not isolating and locking each required energy-isolating device
OSHA's application-of-control sequence requires all energy-isolating devices needed to control the energy to the machine or equipment to be physically located and operated. Lockout or tagout devices must then be affixed to each energy-isolating device by authorized employees.[^osha-standard]
The failure here is often practical. The main electrical disconnect is locked out, but another energy source remains active. A pneumatic valve is missed. A line valve is not controlled. Gravity, pressure or thermal energy is overlooked. Or the team relies on a push button, selector switch or control-circuit device, even though OSHA states that control-circuit type devices are not energy-isolating devices.[^osha-circuit]
**Real OSHA example:** OSHA cited TMS International in 2025 under 1910.147(d)(4)(i). OSHA inspection records state that during multiple tool, blade, belt and wheel changes, the employer did not ensure all energy-isolating devices were physically operated to isolate power to machinery including a Bridgeport Mill, bandsaw, polisher, peeler, saw and grinder.[^tms]
How to reduce this failure:
- Map every required isolation point before the procedure is approved.
- Include electrical, pneumatic, hydraulic, mechanical, chemical, thermal and gravity energy where relevant.
- Make the procedure clear enough for a worker to find the correct device in the field.
- Do not rely on stop buttons, control switches or interlocks as substitutes for energy isolation.
- Use labels, photos or diagrams where similar devices are close together.
Evidence you would want to retain: isolation-point map, procedure step completion, worker identity, timestamp, and any field evidence showing the correct device was controlled.
## Violation 5: Stored or residual energy not controlled
LOTO does not end when the disconnect is off. OSHA requires potentially hazardous stored or residual energy to be relieved, disconnected, restrained or otherwise rendered safe after lockout/tagout devices are applied. If stored energy can reaccumulate, verification must continue until servicing or maintenance is complete, or until reaccumulation is no longer possible.[^osha-standard]
Stored energy can include coasting blades, pressure in lines, hydraulic accumulators, gravity loads, thermal energy, capacitors, springs, trapped product, magnetic energy and residual mechanical motion.
**Real OSHA example:** OSHA cited Graham Packaging PET Technologies in 2025 under 1910.147(d)(5)(i). OSHA inspection records state that an employee conducted maintenance on an offline grinder without ensuring the grinder blades had come to a complete stop after applying a lockout device to the electrical disconnect.[^graham]
**Another example:** OSHA cited Skids, Crates, & Pallets in 2025 after an employee suffered a severe hand injury when residual energy from rotating arbors and saw blades had not been completely dissipated and rendered safe.[^skids]
How to reduce this failure:
- Identify stored and residual energy during procedure development.
- Include steps to bleed pressure, block gravity loads, restrain moving parts, discharge capacitors, release spring tension and wait for rotating components to stop.
- Define how workers confirm the stored energy is safe.
- Include reaccumulation checks where pressure or energy can build back up.
Evidence you would want to retain: stored-energy steps, required wait times or measurements, verification method, worker confirmation and any comments or photos if the condition is unusual.
## Violation 6: Isolation not verified before work starts
OSHA requires the authorized employee to verify that isolation and de-energization have been accomplished before work begins on machines or equipment that have been locked out or tagged out.[^osha-standard]
This is one of the most important LOTO controls. A lock on the wrong device, an incomplete isolation step or uncontrolled stored energy may not be obvious until someone tries to work on the machine.
**Real OSHA example:** OSHA cited Domtar Paper Company in 2025 under 1910.147(d)(6). OSHA inspection records state that a paper machine winder slitter was not properly shut down and locked out before employees performed servicing and maintenance, including clearing jams.[^domtar]
**Contractor example:** OSHA cited Repcon in 2025 under 1910.147(d)(6). The OSHA record states that the contractor did not verify isolation and de-energization of a 12-inch line/flange before starting work at a refinery.[^repcon]
How to reduce this failure:
- Make verification a required step in the procedure.
- Specify the verification method, not just "verify."
- Require confirmation before work starts.
- Record who verified, when and how.
- Be especially careful when contractors or host operations teams are involved, because one party may assume the other has already verified isolation.
Evidence you would want to retain: verification step, method, authorized employee identity, timestamp, result and any comments or supporting field evidence.
## Violation 7: Weak or missing LOTO training
OSHA requires training so employees understand the purpose and function of the energy control program and acquire the knowledge and skills needed for safe application, use and removal of energy controls. Authorized employees must receive training in the recognition of hazardous energy sources, the type and magnitude of energy, and the methods and means necessary for isolation and control.[^osha-standard]
Training failure often shows up when operators, sanitation workers, temporary workers or maintenance helpers are expected to perform tasks that are actually covered servicing or maintenance activities, but they have not been trained as authorized employees.
**Real OSHA example:** OSHA cited National Carwash Solutions in 2025 under 1910.147(c)(7)(i)(A). OSHA inspection records state that an employee required to operate a bandsaw and change the blade when necessary had not received lockout/tagout training as an authorized employee and was exposed to unexpected electrical energy hazards.[^national-carwash]
How to reduce this failure:
- Separate authorized, affected and other employee training.
- Train authorized employees on the actual energy sources and equipment they service.
- Provide training in a language and format workers understand.
- Retrain when equipment, procedures, job assignments or observed deficiencies change.
- Keep training certification records with employee names and training dates.
Evidence you would want to retain: employee training records, training date, role classification, procedure-specific training where needed, retraining triggers and supervisor review of competency.
## Violation 8: Missed annual periodic inspections
OSHA requires periodic inspection of each energy control procedure at least annually. OSHA's eTool explains that the inspector should determine whether the procedure is being followed, whether employees know their responsibilities and whether the procedure provides the necessary protection.[^periodic-etool]
This is where many programs quietly degrade. Equipment is modified. Isolation points change. Workers add informal workarounds. A procedure may still exist in the binder, but it no longer reflects how the job is actually performed.
**Real OSHA example:** OSHA cited R & C Foltz LLC in 2025 under 1910.147(c)(6)(i). OSHA inspection records state that the employer did not conduct an annual periodic inspection of lockout/tagout procedures.[^foltz]
How to reduce this failure:
- Maintain a review schedule for every energy control procedure.
- Assign an authorized employee other than the one using the procedure to inspect it.
- Observe the procedure being used where required.
- Review responsibilities with the relevant authorized employees.
- Correct deviations or inadequacies found during the inspection.
- Certify the inspection with the machine or equipment, date, employees included and inspector.
Evidence you would want to retain: procedure reviewed, equipment, date, inspector, employees included, review findings, corrective actions and new procedure version if changes are made.
For a deeper workflow, see [Periodic LOTO Review: How to Prove Your Lockout/Tagout Procedures Are Still Working](/resources/blog/periodic-loto-review-prove-procedures-work).
## Violation 9: Group LOTO failures
Group LOTO is harder to control than one-person LOTO because there are more people, more handoffs and more assumptions. OSHA says group lockout/tagout operations typically require more coordination and communication than personal lockout/tagout operations.[^group-etool]
Under 1910.147(f)(3), group LOTO must provide each employee with protection equivalent to a personal lockout or tagout device. OSHA requires, among other things, primary responsibility assigned to an authorized employee, a way to ascertain the exposure status of individual group members, coordination when more than one crew, craft or department is involved, and each authorized employee affixing and removing their personal lockout/tagout device on the group lockout device, group lockbox or comparable mechanism.[^osha-standard]
**Real OSHA example:** OSHA cited Alpha Baking in 2025 under 1910.147(f)(3)(ii)(D). OSHA inspection records state that employees troubleshooting, adjusting and installing guarding on a conveyor did not affix personal lockout/tagout devices for group lockout, exposing them to caught-in hazards.[^alpha]
**Another example:** OSHA cited Kinder Morgan in 2024 under the same section. OSHA inspection records state that all authorized employees did not apply locks to the group lockout box during maintenance at a compressor station, exposing employees to re-energization and hazardous flammable gas, fire and explosion hazards.[^kinder]
How to reduce this failure:
- Assign one authorized person with overall responsibility.
- Use a group LOTO procedure that provides equivalent protection to personal lockout.
- Require each authorized employee's personal lock/tag where required.
- Maintain a clear sign-on/sign-off record.
- Know who is still working under the lockout before release.
- Control contractor and multi-crew participation.
Evidence you would want to retain: responsible person, group LOTO procedure, sign-on register, personal lock status, worker sign-off history, closeout confirmation and any owner/supervisor override record.
Related reading: [Group Lockout/Tagout: How to Manage Multi-Person LOTO Without Losing Visibility](/resources/blog/group-lockouttagout-how-to-manage-multi-person-loto-without-losing-visibility) and [Digital LOTO Sign-On: How to See Who Is Working Under a Lockout Plan](/resources/blog/digital-loto-sign-on-how-to-see-who-is-working-under-a-lockout-plan).
## Violation 10: Poor contractor LOTO coordination
Contractor work is a common LOTO weak point. OSHA 1910.147(f)(2) requires the on-site employer and outside employer to inform each other of their respective lockout or tagout procedures when outside servicing personnel are engaged in covered work. OSHA's eTool also states that contractors and other outside servicing personnel performing covered tasks must adhere to the standard's requirements.[^contractor-etool]
The risk is obvious: the contractor assumes the host has controlled the energy; the host assumes the contractor understands the site's procedure; or both parties have procedures but nobody has reconciled them before work starts.
**Real OSHA example:** OSHA cited EFX Industrial in 2025 under 1910.147(f)(2)(i). OSHA inspection records state that employees of EFX were not informed of the host employer's lockout/tagout procedures while working in a facility in Baytown, Texas.[^efx]
How to reduce this failure:
- Exchange LOTO procedures before work starts.
- Clarify who isolates, who verifies, who applies locks and who authorizes release.
- Include contractor workers in sign-on/sign-off records where they work under the lockout.
- Make sure the host and contractor understand each other's restrictions and prohibitions.
- Do not rely only on permit paperwork if the energy control steps are unclear.
Evidence you would want to retain: contractor procedure exchange, work scope, responsible persons, sign-on register, verification evidence, lock/tag status and final closeout record.
## Violation 11: Poor release and closeout control
Release from lockout/tagout is one of the most important stages of the job. OSHA requires actions before energy is restored, including inspecting the work area, ensuring employees are safely positioned or removed, notifying affected employees and controlling lockout/tagout device removal. OSHA's eTool summarises those release requirements clearly.[^release-etool]
The failure here is not just "someone forgot to remove a lock." The real risk is restoring energy while tools, parts, guards, workers or temporary work conditions are still in the danger zone.
**Real OSHA example:** OSHA cited Amentum Services in 2025 under 1910.147(e)(2)(i). OSHA inspection records state that employees were exposed to a crushing hazard while standing underneath the wing of an Army C-12 aircraft as it was being lowered from jacks, without all landing gear locked to support the plane's weight.[^amentum]
How to reduce this failure:
- Use a post-execution checklist before release.
- Confirm all workers have signed off or are clear.
- Confirm tools, parts and nonessential items are removed.
- Confirm guards and components are restored where required.
- Notify affected employees before restart.
- Ensure each lock/tag is removed by the person who applied it, or follow a documented exception process.
- Retain a closeout record.
Evidence you would want to retain: post-execution checklist, sign-off status, work-area inspection, affected-employee notification, device-removal evidence, exception record if applicable and final closeout timestamp.
Related reading: [LOTO Execution Checklist: Pre-Execution and Post-Execution Checks](/resources/blog/loto-execution-checklist-pre-execution-and-post-execution-checks) and [LOTO Audit Trail: What Evidence Should a Digital Lockout System Capture?](/resources/blog/loto-audit-trail-what-evidence-should-a-digital-lockout-system-capture).
## What evidence should a strong LOTO program retain?
A LOTO program should not depend on reconstructing the story after an audit, near miss or incident. The evidence should be captured as the work happens.
A strong record should be able to answer practical questions:
| Question | Evidence to retain |
|---|---|
| Which equipment was involved? | Asset, location and procedure reference |
| Which procedure was used? | Procedure ID, title and version |
| Was the correct procedure current? | Approval status, review date and version history |
| Who performed the lockout? | Authorized employee identity and timestamps |
| Were all isolation points controlled? | Step confirmations, lock/tag evidence and comments |
| Was stored energy controlled? | Stored-energy steps, verification and measurements where relevant |
| Was isolation verified before work? | Verification method, result, person and time |
| Who worked under the lockout? | Sign-on register and sign-off history |
| Were contractors involved? | Contractor coordination record and worker visibility |
| Was the job closed safely? | Post-execution checklist, affected-employee notification and closeout record |
| Was the procedure reviewed? | Periodic inspection evidence, findings and corrective actions |
This is where an effective [LOTO audit trail](/resources/blog/loto-audit-trail-what-evidence-should-a-digital-lockout-system-capture) matters. The goal is not simply to create more records. The goal is to retain the right records so the site can understand what happened, correct weaknesses and demonstrate control.
## How digital LOTO helps reduce workflow breakdowns
Digital LOTO software does **not** replace physical locks, tags, lockboxes, isolation, verification, training or site procedures. It also does not guarantee OSHA compliance. Those controls still need to be designed, implemented and followed by trained people.
What digital LOTO can do is help teams manage and evidence the workflow more consistently.
For example, a digital lockout/tagout system can help with:
- Controlled, versioned LOTO procedures.
- Asset-specific isolation steps.
- Pre-execution checklist controls.
- Digital sign-on registers for worker visibility.
- Multi-person LOTO execution.
- Contractor and shift visibility.
- Evidence capture during the job.
- Post-execution checklists before release.
- LOTO audit trails.
- Periodic LOTO review workflows.
- Exportable records for audits, investigations and internal reviews.
That matters because many LOTO violations are workflow failures. The procedure is not enough if workers cannot find it. Training is not enough if the task is not recognized as covered servicing. A lock is not enough if stored energy is not controlled. A completed job is not enough if there is no evidence of who was signed on, who verified isolation or how release was controlled.
Zentri is built to manage this digital LOTO workflow: controlled procedures, execution checklists, multi-person sign-on, worker visibility, audit trail evidence and periodic review. Learn more on our [digital lockout/tagout software](/lockout-tagout) page.
## Bottom line
LOTO violations usually happen when one of five things breaks down: the procedure, the person, the isolation step, the verification or the evidence.
A stronger program controls all five. It gives workers clear procedures, trains them for the actual hazards, verifies that equipment is isolated, controls group and contractor work, manages release carefully and retains evidence that the process was followed.
**See how Zentri helps teams manage digital lockout/tagout procedures, execution evidence, sign-on visibility and periodic review.**
[Book a demo](/demo)
[^osha-top-10]: OSHA, [Top 10 Most Frequently Cited Standards for FY2025](https://www.osha.gov/top10citedstandards).
[^osha-standard]: OSHA, [29 CFR 1910.147 — The control of hazardous energy (lockout/tagout)](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.147).
[^osha-ecp]: OSHA eTool, [Energy Control Program](https://www.osha.gov/etools/lockout-tagout/tutorial/energy-control-program).
[^safety-health-top10]: Safety+Health, [OSHA's Top 10 — FY2025 Lockout/Tagout](https://www.safetyandhealthmagazine.com/articles/27597-the-most-frequently-cited-standards-in-fy-2025).
[^family-fresh]: OSHA inspection record, [Family Fresh Pack, Inc. — 1910.147(c)(1)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=02001&id=1798422.015).
[^ascend]: OSHA inspection record, [Ascend Elements, Inc. — 1910.147(c)(4)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01002&id=1806379.015).
[^huestis]: OSHA inspection record, [Huestis Machine Corporation — 1910.147(c)(4)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=02002B&id=1758654.015).
[^miracapo-release]: OSHA news release, [Illinois pizza manufacturer faces $2.8M in penalties after investigation into sanitation worker's death](https://www.osha.gov/news/newsreleases/osha-national-news-release/20230615).
[^osha-circuit]: OSHA eTool, [Specific Procedures for Energy Control and Control Circuitry Prohibition](https://www.osha.gov/etools/lockout-tagout/hot-topics/energy-control-program/energy-control-circuitry-prohibition).
[^tms]: OSHA inspection record, [TMS International, LLC — 1910.147(d)(4)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01003B&id=1812211.015).
[^graham]: OSHA inspection record, [Graham Packaging PET Technologies, Inc. — 1910.147(d)(5)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01001&id=1802626.015).
[^skids]: OSHA inspection record, [Skids, Crates, & Pallets Incorporated — 1910.147(d)(5)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01001B&id=1809708.015).
[^domtar]: OSHA inspection record, [Domtar Paper Company, LLC — 1910.147(d)(6)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01001B&id=1781976.015).
[^repcon]: OSHA inspection record, [Repcon, Inc. — 1910.147(d)(6)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01003B&id=1781440.015).
[^national-carwash]: OSHA inspection record, [National Carwash Solutions, Inc. — 1910.147(c)(7)(i)(A)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01001&id=1810263.015).
[^periodic-etool]: OSHA eTool, [Periodic Inspections](https://www.osha.gov/etools/lockout-tagout/hot-topics/energy-control-program/periodic-inspections).
[^foltz]: OSHA inspection record, [R & C Foltz LLC — 1910.147(c)(6)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01002A&id=1811826.015).
[^group-etool]: OSHA eTool, [Group Lockout-Tagout Procedures](https://www.osha.gov/etools/lockout-tagout/hot-topics/group-lockout-tagout/procedures).
[^alpha]: OSHA inspection record, [Alpha Baking Co., Inc. — 1910.147(f)(3)(ii)(D)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01001&id=1821731.015).
[^kinder]: OSHA inspection record, [Kinder Morgan — 1910.147(f)(3)(ii)(D)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01003&id=1716070.015).
[^contractor-etool]: OSHA eTool, [Outside Personnel (Contractors)](https://www.osha.gov/etools/lockout-tagout/tutorial/outside-personnel).
[^efx]: OSHA inspection record, [EFX Industrial, LLC — 1910.147(f)(2)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01004&id=1834646.015).
[^release-etool]: OSHA eTool, [Release from Lockout/Tagout](https://www.osha.gov/etools/lockout-tagout/tutorial/release-from-lockout-tagout).
[^amentum]: OSHA inspection record, [Amentum Services, Inc. — 1910.147(e)(2)(i)](https://www.osha.gov/ords/imis/establishment.violation_detail?citation_id=01002&id=1767588.015).
