In November 2025, a worker at a New Jersey food processing plant was killed while cleaning equipment that hadn't been properly locked out. OSHA cited the company for 16 violations and proposed a $1.1 million fine. The facility had a documented history of amputations stretching back to 2015.
It wasn't an isolated case. Lockout/tagout has ranked in OSHA's top five most-cited standards for over a decade. In fiscal year 2025, it generated 2,177 violations. The year before that, 2,554. The standard itself hasn't been materially updated since 1989, but the ways facilities fail at it keep evolving.
This guide covers what lockout/tagout actually is, when it applies, the six-step procedure, what a compliant program requires under OSHA 1910.147, and, most importantly, where real-world programs break down despite checking every box on paper.
## What Is Lockout/Tagout?
Lockout/tagout (LOTO) is a safety procedure designed to ensure that machines and equipment are fully de-energised and cannot restart while workers perform maintenance, servicing, or cleaning. The name describes the two physical controls involved: a lock physically prevents an energy-isolating device from being activated, while a tag identifies who applied it, when, and why.
The practice is governed by OSHA 29 CFR 1910.147, the Control of Hazardous Energy standard for general industry, first published in September 1989. OSHA estimates that compliance with this standard prevents approximately 120 fatalities and 50,000 injuries every year across the roughly three million US workers who routinely service equipment and face exposure to hazardous energy.
It is worth noting that while OSHA's standard has remained largely unchanged for over 36 years, the voluntary consensus standard ANSI/ASSP Z244.1 was revised in December 2024. That update now treats alternative energy control methods as co-equal with traditional lockout and introduces guidance on mobile applications and cybersecurity for the first time. This signals where the industry is heading, even if OSHA hasn't caught up yet.
## Types of Hazardous Energy Covered by LOTO
Lockout/tagout is not limited to electrical energy. A compliant procedure must account for every energy source present on a given machine or system. These include electrical energy (circuits, capacitors, batteries), mechanical energy (springs, flywheels, rotating gears), hydraulic energy (pressurised fluid in lines and cylinders), pneumatic energy (compressed air and gas systems), thermal energy (extreme heat or cold in pipes, vessels, and ovens), chemical energy (reactive substances in process lines), and gravitational energy (suspended loads and elevated components).
OSHA data indicates that roughly 10% of serious workplace accidents result from failure to control hazardous energy, and a significant share of those involve energy sources that were overlooked or not accounted for in the original written procedure. Getting the energy source identification wrong at the start makes every subsequent step unreliable.
## When Is Lockout/Tagout Required?
LOTO is required whenever a worker performs servicing or maintenance on machines or equipment where unexpected energisation, start-up, or release of stored energy could cause injury. This includes routine maintenance, cleaning, unjamming, and equipment adjustments that go beyond normal production operations.
There are limited exceptions. Minor tool changes and adjustments during normal production may be exempt, but only when the employer has documented alternative safeguards that provide effective protection. Cord-and-plug connected equipment is exempt only when the worker maintains exclusive control of the plug for the entire duration of the task.
OSHA's position on ambiguity is consistent: if there is any question about whether LOTO applies, the default is full lockout.
## The 6-Step LOTO Procedure
The standard lockout/tagout procedure follows six sequential steps. Each one depends on the one before it, and skipping any of them creates exposure.
**Step 1: Preparation.** Identify every energy source on the machine using the machine-specific written procedure. Notify all affected employees that a lockout is about to take place.
**Step 2: Shutdown.** Turn the machine off using its normal stopping procedure. This step sounds obvious, but it matters because pulling a disconnect under load can create arc flash or mechanical hazards.
**Step 3: Isolation.** Physically disconnect or isolate every energy source identified in Step 1. This means opening breakers, closing valves, disconnecting supply lines, and engaging any other isolation devices.
**Step 4: Lock and Tag Application.** Each authorised employee applies their own personal lock and tag to every energy isolation point. One worker, one lock. Tags must identify who applied the lock, when, and why. Shared locks or supervisor-applied locks on behalf of a crew do not meet the standard.
**Step 5: Stored Energy Verification.** Release, restrain, or dissipate any residual or stored energy. This includes bleeding hydraulic and pneumatic lines, blocking elevated components, discharging capacitors, and allowing thermal components to reach safe temperatures.
**Step 6: Verification.** Attempt to restart the machine using normal operating controls to confirm it is fully de-energised. After verification, return all controls to the off position.
Steps 5 and 6 are where most shortcuts happen and where most incidents occur. The Taylor Farms fatality involved equipment being cleaned without proper energy isolation verification. Workers injured from hazardous energy exposure lose an average of 24 workdays recovering, according to OSHA data.
## What OSHA Actually Cites Most
Most articles about lockout/tagout will tell you it ranked fourth on OSHA's most-cited list in FY2025. What they rarely tell you is which specific parts of the standard drive those citations. That breakdown changes the picture.
Based on FY2023 data from 1,368 inspections, the most-cited subsections of 1910.147 were:
- **(c)(4) Energy control procedures — 730 citations.** This is the requirement for written, machine-specific procedures. The number one citation is not a worker forgetting to apply a lock. It is the company not having a documented procedure for the machine in the first place. (For a step-by-step walkthrough, see our guide on [how to write a machine-specific LOTO procedure](https://www.zentri.cc/resources/blog/how-to-write-a-machine-specific-loto-procedure-step-by-step).)
- **(c)(7) Training and communication — 491 citations.** OSHA requires different training for three categories of employees: authorised (those who apply locks), affected (those who operate or work near locked-out equipment), and other (those in the general area). Failing to differentiate training across these groups is one of the most common citation triggers. (We cover what OSHA auditors actually look for in [how to prove LOTO training compliance during an OSHA audit](https://www.zentri.cc/resources/blog/how-to-prove-loto-training-compliance-during-an-osha-audit).)
- **(c)(6) Periodic inspections — 362 citations.** Annual inspections must be performed by an authorised employee who is not the one routinely using the procedure being inspected. Many companies either skip inspections entirely or fail to document them in a way that satisfies OSHA. (Our [LOTO audit compliance checklist](https://www.zentri.cc/resources/blog/how-to-prepare-for-a-loto-audit-compliance-checklist) covers exactly what you need to have documented.)
- **(c)(5) Application of controls — 231 citations.** This covers the actual execution of the lockout.
In that same fiscal year, LOTO citations totalled $20.7 million in penalties, a 29% increase from FY2022. Maximum penalties in 2025 stand at $16,550 per serious violation and $165,514 per willful or repeated violation.
The pattern is clear: the majority of citations are about the program, not the padlock. Missing procedures, inadequate training, and skipped inspections account for far more violations than the physical act of locking out. (For a deeper dive into each violation type, see [10 most common LOTO violations and how to avoid them](https://www.zentri.cc/resources/blog/10-most-common-loto-violations-and-how-to-avoid-them).)
## Where Real-World LOTO Programs Break Down
Understanding the standard is one thing. Maintaining a compliant program over time, across machines, shifts, contractors, and facilities, is where most organisations struggle.
**Procedure drift.** Machines get modified. Production lines reconfigure. Equipment is added, moved, or decommissioned. But the written LOTO procedure in the binder stays frozen. Within 12 months of creation, many procedures no longer reflect the actual equipment configuration. A procedure that does not match reality is not just unhelpful. It is a liability during an OSHA inspection and a safety risk on the floor.
**Paper-based tracking.** Binder-based programs make audits slow, inspections difficult to verify, and pattern recognition across shifts or sites nearly impossible. When OSHA asks for documentation of your last three annual inspections, a paper system forces a scramble. A digital system produces it in seconds. (We break down the full cost comparison in [how to build the business case for digital lockout tagout software](https://www.zentri.cc/resources/blog/how-to-build-the-business-case-for-digital-lockout-tagout-software).)
**Contractor handoffs.** Under 1910.147(f)(2), the host employer must coordinate LOTO procedures with outside contractors. In practice, many don't. Contractors follow their own procedures, or none at all. This was a contributing factor in the Taylor Farms case, where a temporary staffing agency was also cited for failing to train its workers on lockout/tagout.
**Group lockout complexity.** When multiple crews or shifts work on the same equipment, a single authorised employee must coordinate the group lockout. Transition between shifts is where coordination breaks down and exposure increases. The more workers and the longer the duration, the higher the risk of procedural gaps.
Food manufacturing led all industries with 384 LOTO citations in FY2023, followed by fabricated metal products at 377 and plastics and rubber at 202. These are not fringe industries. They are mainstream manufacturing operations dealing with the same challenges that affect every facility running a LOTO program.
## From Paper Binders to Digital LOTO
The shift from paper-based lockout/tagout to digital systems is accelerating, driven by the operational gaps outlined above. Digital LOTO platforms provide machine-specific procedures accessible on mobile devices, real-time audit trails with timestamps and user verification, automated periodic inspection tracking and reminders, and standardised procedures across multiple facilities.
The ANSI Z244.1-2024 revision explicitly added content on mobile applications for the first time, a clear signal that the standards bodies recognise this shift is already underway.
Platforms like Zentri replace static paper binders with guided, digital procedures that stay current as equipment changes, closing the compliance gaps that show up in OSHA's citation data year after year.
## The Bottom Line
Lockout/tagout is six steps. The procedure itself is not complicated. But building and maintaining a compliant program across every machine, every shift, every contractor, and every facility is where it gets hard, and where the citations pile up.
The standard hasn't changed since 1989. The enforcement hasn't slowed. The penalties are climbing. And the consequences of getting it wrong are measured in more than dollars.
Whether your program runs on paper today or you are evaluating digital tools, the fundamentals in this guide are the foundation everything else builds on.
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*Want to see how a digital LOTO platform handles procedures, training records, and inspections in one system? [Request a Zentri demo.](https://www.zentri.cc/demo)*
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