Lockout/Tagout Procedure: The Steps OSHA 1910.147 Requires

What Lockout/Tagout Is, and Why OSHA Requires It

Lockout/tagout is the set of practices that protect workers from the unexpected startup of machinery, or the release of stored energy, during service and maintenance. OSHA regulates it under the Control of Hazardous Energy standard, 29 CFR 1910.147. The standard applies to electrical, hydraulic, pneumatic, mechanical, thermal, and chemical energy, any source that could injure a worker if it were released while the machine was being serviced.

The requirement is not just to have locks. It is to have a documented, machine-specific energy control procedure, and to train every authorized employee to execute it correctly on the equipment they work on.

The Six Steps of the LOTO Procedure

1. Prepare for shutdown. Identify every energy source on the specific machine and the correct method to control each one. This is the step workers miss most, a secondary energy source that is never isolated.
2. Shut down the machine. Use the normal stopping procedure. Never rely on the control switch as the isolation point.
3. Isolate energy sources. Operate the disconnects, valves, and blocks that physically separate the machine from its energy.
4. Apply lockout/tagout devices. Each authorized employee applies their own lock and tag to each isolation point, so the machine cannot be re-energized by anyone else.
5. Release stored energy. Bleed, block, or discharge residual energy, capacitors, springs, hydraulic pressure, elevated parts, until the machine is at a true zero-energy state.
6. Verify isolation. Attempt to start the machine using normal controls, confirm it will not operate, then return controls to off. Only now is it safe to begin work.

Who Must Be Trained, and How Often

OSHA distinguishes authorized employees (who perform LOTO), affected employees (who operate the machines), and other employees (who work in the area). Authorized employees need the deepest training. Retraining is required whenever the machine, the procedure, or the employee's role changes, and whenever an audit reveals a deviation. A periodic inspection of the energy control procedure is required at least annually.

Where LOTO Training Usually Falls Short

A LOTO procedure learned from a generic video does not transfer to a specific press or processing unit with its own energy sources in their own locations. The worker leaves with a completion record and no verified ability to isolate the machine they will actually service. That gap, between knowing the six steps and performing them correctly under pressure on real equipment, is exactly what immersive practice closes. In VR, a worker performs the full sequence on a virtual replica of their machine, repeatedly, until the data shows they can do it, with a simulated consequence rather than a real one.

If you are evaluating how to build that competency at scale, see our VR lockout/tagout training and our broader manufacturing VR training programs.

What the Procedure Controls

Hazardous energy control exists to prevent machinery starting or releasing stored energy while someone is working on it.

The hazard is not only electrical, since hydraulic, pneumatic, mechanical, thermal and gravitational energy all have to be addressed.

A program that covers only the main disconnect leaves the other sources live, which is a common and serious gap.

Machine Specific Procedures

Generic procedures fail because they cannot list the isolation points, stored energy and verification steps for a particular machine.

Each machine should have a written procedure identifying every energy source, its isolation point and how to verify isolation.

Procedures written once and never reviewed stop matching machines that have been modified since.

The Sequence

Notification, orderly shutdown, isolation of each source, application of locks and tags, release of stored energy and verification form the sequence.

Verification by attempting to operate the machine is the step that converts assumed isolation into confirmed isolation.

Stored energy in accumulators, capacitors, springs and raised components has to be released or restrained rather than assumed dissipated.

Locks, Devices and Accountability

Each person working applies their own lock, and group arrangements require a method that preserves individual protection.

Locks should be identifiable to the person, and no one removes another person lock under normal circumstances.

Removal procedures for an absent worker exist precisely because informal removal is where fatalities occur.

Restoring the Machine

Restoring energy requires checking that tools are removed, guards replaced and everyone clear before locks come off.

Notification of restart is part of the procedure rather than a courtesy, since others may be nearby.

Sequence matters here as much as during isolation, and shortcuts at this point are common under schedule pressure.

Keeping the Program Credible

Periodic inspection of the procedures, training of affected and authorized personnel and review after machine changes are ongoing obligations.

Simulation and structured practice let workers rehearse isolation and verification before performing it on live equipment.

Applicable energy control regulations, machinery safety requirements and inspection obligations should be confirmed with the relevant authority.

Common Mistakes and How to Avoid Them

Common errors include isolating only the electrical source, using generic procedures that do not match the machine, skipping verification, assuming stored energy has dissipated and removing another person lock informally.

Supervisors can help by making it acceptable to pause and ask. A culture where questions are treated as competence rather than weakness produces fewer errors in hazardous energy control.

How Employers Evaluate Readiness

Employers assess this through periodic procedure inspections, audit findings, near miss and incident records, training records by role and observed practice during maintenance.

Keeping Skills Current

Machines, guarding and energy sources change. Reviewing procedures after modifications prevents isolating against a configuration the equipment no longer has.

Planning and Preparation

Preparation includes inventorying machines and energy sources, writing machine specific procedures, supplying identifiable locks and devices, defining group and absent worker arrangements and scheduling periodic inspection.

Documentation That Holds Up

Machine specific written procedures with revision dates, periodic inspection records, training records for authorized and affected personnel and incident reports are what an inspection examines first.

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Lockout Tagout Procedure Steps: what to know

This guide covers what it is, who is required to complete it, how it is usually delivered, and what The Prime VR changes when the same material is rebuilt as scored practice in a headset. Every attempt is logged, so competence is something you can see rather than assume.

Frequently Asked Questions