Does OSHA Lockout/Tagout (1910.147) Apply to Construction? The Surprising Answer

No: 29 CFR 1910.147 does not apply to construction. OSHA's Control of Hazardous Energy standard expressly excludes construction in its own scope at 29 CFR 1910.147(a)(1)(ii). Construction hazardous-energy control is built from a patchwork instead: 29 CFR 1926.417 for electrical lockout and tagging, equipment-specific rules like 29 CFR 1926.702(j) and Subpart V, the safety and training duties in 29 CFR 1926.20 and 29 CFR 1926.21, and the General Duty Clause, Section 5(a)(1). If you copied a general-industry LOTO template onto your jobsite, you built it on the wrong standard.

The short answer: 1910.147 excludes construction by its own text

OSHA's standards are split by industry. The widely quoted Control of Hazardous Energy standard, 1910.147, lives in Part 1910 (General Industry), and its scope paragraph, 29 CFR 1910.147(a)(1)(ii), states the section does not cover construction (or agriculture) employment. So the detailed energy-control program, the 6-step sequence, group lockout, and the annual periodic inspection that safety pros quote from 1910.147 are not, by themselves, your construction obligation.

Construction work falls under Part 1926. But here is the surprise that trips up even experienced EHS managers: there is no single, comprehensive construction LOTO standard equivalent to 1910.147. Instead, OSHA reaches hazardous energy on construction sites through several narrower rules, and fills the gaps with the General Duty Clause.

What decides which rule applies is the task, not the company's industry code. 1910.12(b) defines construction work as "work for construction, alteration, and/or repair, including painting and decorating," while 1910.147(a)(1)(i) covers "the servicing and maintenance of machines and equipment" in general industry. A contractor whose crew services machinery outside construction work is doing general-industry work.

The construction patchwork: which standards actually apply

The practical takeaway: a construction employer should not cite, train to, or audit against 1910.147 as its controlling rule for construction work. Anchor the program on 1926.417 for electrical work, layer in the equipment-specific rules for the energy sources you actually have on site, and use 1926.20/1926.21 plus the General Duty Clause to cover the rest.

Standard-by-standard comparison: general industry vs construction

What 1926.417 actually requires

The construction electrical standard is far shorter than the general-industry program, but its core duties are unambiguous. Under 29 CFR 1926.417:

• Controls tagged. Controls that are to be deactivated during work on energized or de-energized equipment or circuits must be tagged (29 CFR 1926.417(a)).
• Equipment and circuits rendered inoperative. Equipment or circuits that are de-energized must be rendered inoperative and have tags attached at all points where the equipment or circuits can be energized (29 CFR 1926.417(b)).
• Tags. Tags must plainly identify the equipment or circuits being worked on (29 CFR 1926.417(c)). That is all (c) says: 1926.417 does not say who may remove a tag.
• Verification. Test the equipment or circuit dead before work begins. 1926.417 does not spell this out; it is basic electrical practice, and general industry requires it in 1910.147(d)(6).

Notice what 1926.417 does not spell out: the machine-specific written procedure, the annual periodic inspection, the training of affected employees, and the formal group-lockout protocol that 1910.147 mandates. Those gaps are exactly why the General Duty Clause and 1926.20/1926.21 matter, and why borrowing the structure of 1910.147 as voluntary best practice is smart, even though it is not your legal hook.

What OSHA cites

In fiscal year 2025, federal OSHA cited 1926.417 7 times in inspections of construction employers: 5 times under (b), equipment and circuits rendered inoperative and tagged, and 2 times under (a), tagging the controls. In the same inspections, it cited 1910.147 31 times, most often (c)(1), the energy control program (6 times). Those 1910.147 citations show the point above: a construction industry code does not settle which rule applies; the task does.

Across all industries, 1910.147 ranked fourth on OSHA's list of the most frequently cited standards for fiscal year 2025, which is why so many training kits and templates are built around it.

Count: HazComFast, from the U.S. Department of Labor enforcement data (citations issued October 1, 2024 to September 30, 2025, deleted citations excluded, federal OSHA inspections of employers classified in NAICS 23, extracted September 26, 2026). Rank: osha.gov/top10citedstandards, which publishes the order but no counts.

Worked example: servicing a motor on a stationary concrete pump

A crew needs to service a motor on a stationary concrete pump on a high-rise jobsite. This is how the patchwork resolves, step by step:

1. Electrical isolation: 1926.417. The pump's electrical disconnect is opened and tagged, and the circuit is rendered inoperative with tags at every point it could be re-energized (1926.417(a) and (b)).
2. Verify de-energization (good practice). A qualified worker tests the circuit dead before any contact, rather than assuming it is dead. 1926.417 does not spell this out; general industry's rule is 1910.147(d)(6).
3. Every other energy source: 1926.702(j). A concrete pump is equipment that 1926.702(j)(1) names: before maintenance or repair, all potentially hazardous energy sources are locked out and tagged, and the tags read "Do Not Start" or similar (1926.702(j)(2)). In practice that means bleeding hydraulic accumulators and residual line pressure and blocking the hopper agitator against movement.
4. Program & training: 1926.20 / 1926.21. The contractor's accident-prevention program provides for frequent and regular inspections by a competent person (1926.20(b)(2)), and each worker is instructed to recognize and avoid these hazards (1926.21(b)(2)).

Wrong move: citing "our 1910.147 program" on the permit. Right move: a permit referencing 1926.417, the equipment-specific control and the training duty, which is what the construction mode of our LOTO Procedure Generator prints.

Why contractors get this wrong

The confusion is understandable. 1910.147 is the famous standard: it ranked fourth among OSHA's most-cited standards in fiscal year 2025, and most online LOTO training kits, generic written programs, and third-party templates are built around it. But applying a general-industry template wholesale to a construction site creates two real risks:

1. Citing the wrong rule. Your written program references a standard OSHA does not apply to construction work, signaling the program was never tailored to construction, a credibility problem the moment a compliance officer reads it.
2. Missing the right rules. You may overlook the specific tagging duties in 1926.417, the equipment controls in 1926.702(j) / Subpart V, and the program/training duties in 1926.20/1926.21.

OSHA can still hold a construction employer fully accountable. Where a recognized hazardous-energy hazard exists and no specific construction standard fully covers it, OSHA may rely on the General Duty Clause, Section 5(a)(1) of the OSH Act.

Common myths, corrected

• Myth: "1910.147 is the LOTO law for everyone." No: 1910.147(a)(1)(ii) excludes construction (and agriculture).
• Myth: "There's a construction version of 1910.147." There is no single equivalent; construction uses a patchwork (1926.417 + equipment-specific rules + GDC).
• Myth: "If 1910.147 doesn't apply, we have no LOTO duty." Wrong: 1926.417, equipment rules such as 1926.702(j), 1926.20/.21, and the General Duty Clause all create duties.
• Myth: "Annual periodic inspection is required on jobsites." It is a 1910.147(c)(6) general-industry requirement; on a jobsite it is best practice, not a codified Part 1926 mandate.
• Myth: "Tagout alone is fine in construction." 1926.417 is built around tagging plus rendering equipment inoperative (1926.417(b)): a tag is not isolation.
• Myth: "We're a construction company, so 1910.147 never applies to us." The task decides: servicing and maintenance outside construction work is general-industry work (1910.12(b); 1910.147(a)(1)(i)).

Penalty exposure (2026)

A hazardous-energy violation is a serious violation when there is a substantial probability that death or serious physical harm could result from it (29 U.S.C. 666(k)). For 2026, OSHA penalty maximums are unchanged from 2025: there was no inflation increase (BLS did not publish the required CPI-U figure; OMB Memo M-26-11). These are the 2025 amounts carried forward; 29 CFR 1903.15 identifies January 15, 2025 as their effective reference.

A single energy-control failure that injures a worker can pull multiple citation items, for example tagging under 1926.417 and training under 1926.21, and each serious item can reach $16,550. Want to model your exposure? Run the figures through the OSHA fine calculator.

Construction LOTO compliance checklist

• Write your program around 1926.417 and the equipment-specific rules, not 1910.147
• Map every energy source on site (electrical, hydraulic, pneumatic, gravity/mechanical, thermal, chemical) to a controlling rule
• De-energize and render inoperative equipment and circuits before work (1926.417(b))
• Apply tags at all points where equipment can be energized
• Use tags that plainly identify the equipment or circuits being worked on (1926.417(c)); adding the worker's name is good practice
• Remove tags only via the person who applied them (voluntary best practice, borrowed from 1910.147(e)(3))
• Verify de-energization before starting work (good practice; not written in 1926.417)
• Lock out and tag concrete and masonry equipment per 1926.702(j) and utility lines per Subpart V where applicable
• Instruct each employee per 1926.21(b)(2); run the inspections of your 1926.20(b) program
• Adopt 1910.147-style written procedures + periodic checks as voluntary best practice
• Keep documentation accessible on the jobsite for inspection

What to do next

1. Re-label your program. Strike "1910.147" as the controlling citation for construction work; anchor it on 1926.417 plus the equipment-specific Part 1926 rules you actually need.
2. Generate jobsite-correct procedures with the LOTO Procedure Generator and pair them with task permits: a Hot Work Permit or Confined Space Permit.
3. Train and document under 1926.20/1926.21, and keep the record on site.
4. Cross-read the Lockout/Tagout Complete Guide 2026 for the six energy types and best-practice 6-step sequence, the construction electrical safety + NFPA 70E guide, and the LOTO standard overview.

Note: This is general guidance, not legal advice. OSHA-approved State Plans may adopt construction requirements at least as effective as the federal rules; verify your state's standard.

Build a construction-correct LOTO program

Don't let a copied general-industry template become an audit finding. Generate jobsite-ready hazardous-energy procedures tied to the correct construction citations with the LOTO Procedure Generator and a Hot Work or Confined Space permit. Related reading: Lockout/Tagout hub · Lockout/Tagout Complete Guide 2026 · Construction Electrical Safety & NFPA 70E · Confined Spaces: Subpart AA vs 1910.146 · When safety software manufactures evidence against you.

Sources & verification: 29 CFR 1910.147(a)(1) (scope and construction exclusion); 29 CFR 1910.12(b) (construction work); 29 CFR 1926.417 (lockout and tagging of circuits); 29 CFR 1926.702(j) (Subpart Q); 29 CFR 1926 Subpart V; 29 CFR 1926.20(b) and 1926.21(b)(2); OSH Act Sections 5(a)(1) and 17(k); penalty maximums per 29 CFR 1903.15(d). Regulatory text read on the eCFR (title 29 current as of September 25, 2026) on October 2, 2026. Not legal advice.