Does OSHA require a written lockout/tagout procedure for every machine?

Federal OSHA doesn't require a separate written lockout/tagout procedure for every machine. 29 CFR 1910.147(c)(4) requires procedures that are developed, documented, utilized and specific, and OSHA's directive CPL 02-00-147 lets similar machines share one when they're listed in its scope and shut down, lock out and verify the same way. In California, 8 CCR §3314(g)(2) requires written procedures with separate steps for each machine unless one of two conditions is met.

A plant runs six case packers under one written lockout procedure. Each has a 480-volt disconnect and a lockable air dump valve. An auditor asks for six separate procedures. The maintenance supervisor needs to check whether the shared procedure identifies every packer and gives steps that work on each one.

Under federal OSHA, the count isn't the test. 29 CFR 1910.147 never says how many machines a procedure may cover. It asks for specific steps to shut down, isolate, block and secure the machine, to place, remove and transfer the locks, and to verify that the energy is controlled. If the six packers shut down, isolate and verify the same way, and the procedure names all six, OSHA's own enforcement directive accepts one procedure for them. If the sixth packer was rebuilt without a start/stop button and the procedure uses that button to shut down and verify, the procedure doesn't work for that machine. That example comes from OSHA's directive, page 3-45, and it's covered below.

What does 1910.147(c)(4) require?

Paragraph (c)(4) opens with the duty:

(4) Energy control procedure. (i) Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. (29 CFR 1910.147(c)(4)(i))

Each verb is a separate duty. A procedure that sits in a binder and never comes out at the machine hasn't been utilized. One that lives in the head of your best mechanic hasn't been documented.

Paragraph 1910.147(c)(4)(ii) says what goes in it. The procedures "shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance," including at least:

• (A) "A specific statement of the intended use of the procedure"
• (B) "Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy"
• (C) "Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them"
• (D) "Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures"

The word specific is in all four items. OSHA's enforcement directive for the standard, CPL 02-00-147, explains it on page 3-42: "OSHA used the word specific in the standard to describe the elements of the procedure. This was done to emphasize the need for detailed procedures because over-generalization does not provide authorized employees sufficient information to effectively control the hazardous energy to which they are exposed." The same page adds that "a written energy control procedure need not be complicated and detailed, if the system to be controlled is not complex or does not require unusual control measures."

The requirements in 1910.147(c)(4) concern the content and use of the procedure. The nonmandatory Appendix A template allows a company-wide procedure or identification of equipment when multiple procedures are used. The directive explains the conditions under which machines can share one procedure.

Can one LOTO procedure cover several machines?

Yes, when the machines are similar in the ways that matter to the person holding the lock. CPL 02-00-147, effective February 11, 2008, puts it this way on page 3-44:

Although the standard requires the procedure to be written in detail, this does not mean that a separate procedure must be written for each and every machine or piece of equipment. Similar machines and/or equipment (such as those using the same type and magnitude of energy), which have the same or similar types of controls, and which can be rendered safe using the same sequential procedural steps, can be covered by a single procedure, if that procedure satisfactorily addresses the hazards and specifies the measures for controlling the hazards.

The same page sets the test for grouping. The machines all have to be "listed or identified in the scope of the energy control procedure," and they all have to share the same or similar:

1. steps for shutting down, isolating, blocking, securing and dissipating stored energy,
2. steps for placing, removing and transferring the locks or tags, and the responsibility for them,
3. requirements for testing the machine to verify that the lockout devices and other control measures work.

Those three lines track 1910.147(c)(4)(ii)(B), (C) and (D) almost word for word. The directive's example is a woodworking shop where table saws, radial arm saws, planers, routers, grinders and conveyors use the same or similar types of energy ("120 VAC and 240 VAC, nominal electric disconnect switches"), have the same or similar isolating controls, and use the same sequence of steps. For that shop, "a single energy control procedure may be used for this group of woodworking machines, as long as the procedure includes each machine within its scope and has sufficient specificity to allow employees to effectively isolate the hazardous energy source(s) and safely return each of the machine(s) to service."

Two details in that test are easy to miss. The first is the scope. "All packers" in a heading isn't a scope if nobody on second shift can tell which packers it means. The directive is flexible about how machines are named: "Any method of identification (e.g., by machine type and location or by machine type and model number) that enables an authorized employee to determine which energy control instructions, operating controls and energy isolating devices apply to a particular machine or piece of equipment is acceptable" (page 3-42). The second is that what a machine makes doesn't count. Page 3-45 says "the nature of the machine or piece of equipment (i.e., its production function) is not a significant factor," and names a mechanical conveyor, an electrically powered ironworker, a table saw and a multi-spindle milling machine as machines that "may be covered by a single procedure" when the lockout measures are the same or similar.

OSHA gave the same answer in an interpretation letter of January 14, 2003, now archived, to a Dallas engineer who asked: "Does the lockout/tagout standard require procedures for every single piece of equipment or is a procedure for each type of equipment sufficient?" The reply opens with "No, energy control procedures are not required for every single piece of equipment if certain criteria are met," and it warns that "Over-generalization can result in a document that has little or no utility for employees who must follow the procedure."

You may also have read that similar machines "can be covered with a single written procedure." That sentence is real. It comes from OSHA Instruction STD 1-7.3 of September 11, 1990, now numbered STD 01-05-019, which CPL 02-00-147 cancels. OSHA keeps it among its archived directives, under a notice that it "may no longer represent OSHA Policy." The current directive says "single procedure" and attaches the conditions above.

Writing one procedure per machine is still a sound choice, and page 3-45 says so: "OSHA recognizes that some employers choose to develop 'machine-specific' energy control procedures for individual machines or pieces of equipment because this approach provides an optimum level of detail, enhancing overall employee safety during servicing operations." The auditor in line 3's case can recommend it as company policy. She can't call it a federal requirement.

Keep the weight of the directive in mind too. It tells inspectors how to apply the standard, and it says of itself that it "is not a standard, regulation or any other type of substantive rule." The rule is 1910.147(c)(4). The directive shows how OSHA reads it.

When do similar machines need more than one procedure?

When the steps stop matching. Page 3-45 of the directive says an employer "may be required to develop more than one procedure when variations in machine types, energy sources, or energy control methods mandate additional specificity," and gives two cases.

The first is the start/stop button. A group procedure uses the start/stop button to shut down the machines and to verify isolation, but one machine in the group has no button "because it is wired directly to an electronic on-demand signal." For that machine, the directive says, "the single procedure will not provide sufficient employee guidance on how to effectively shut down the machine and verify energy isolation." A shared procedure would need instructions that also work for that machine.

The second is lumping together systems that don't belong together. The directive's example is "an ammonia refrigeration vs. a natural gas fuel heating system," which "would not be permitted" in one procedure "if the procedure did not sufficiently specify the hazards and specific control measures pursuant to the LOTO standard's energy control procedure provisions."

The fix doesn't have to be a new binder tab. On the same page, OSHA says the employer is required "to develop more than one procedure (or to supplement a single, generic procedure with supplemental means such as checklists, appendices, or work authorization permits) for unique or different energy sources, particularly when the associated control measures are dissimilar."

The 2003 letter adds a warning about plant-wide procedures built around parts. OSHA wrote that "a plant-wide approach for controlling hazardous energy that is based on system components (e.g., valves)," instead of a hazard review of each process and machine, "may be seriously flawed." A sheet that tells a mechanic how to close a valve doesn't tell him which valves stand between him and the energy in the machine in front of him.

Is a generic procedure or the Appendix A template enough?

Only if the machine detail is in there somewhere. The directive accepts a facility-wide base: "OSHA recognizes that many portions of an energy control procedure may be standardized for an entire facility." Where machines, energy types, isolating devices or hazards vary, the generic procedure has to be supplemented "with checklists or other supplemental means (e.g., a checklist, work authorization permit system, or manufacturers' servicing and maintenance guidelines)." The passage on page 3-46 closes with a note that leaves no room: "NOTE: The use of generic energy control procedures alone are unacceptable, if generic procedures do not meet the provisions set forth in §1910.147(c)(4)(ii)."

Placards at the machine can carry that detail. Discussing the sample placards in the ANSI Z244.1-2003 consensus standard, page 2-23 says that "An employer who chooses to develop a single, generic energy control procedure can supplement its generic procedure with similar placards to comply with 29 CFR 1910.147(c)(4)(ii)." Page 3-46 gives an example of what a checklist might add, "if not apparent": "the number and locations of the energy isolating devices in order to achieve total de-energization."

Appendix A to 1910.147 is a model, and a minimal one. The directive calls it a "non-mandatory Typical Minimal Lockout Procedure guideline," a "flexible template" that "may be used when there are limited numbers or types of machines or where there is a single power source. The user would simply need to fill in the blanks with the machine-specific data" (page 3-43). The standard says the same of its appendix: "Nothing in the appendix adds to or detracts from any of the requirements of this section."

Filling in the blanks is the whole job. On page 3-43, the directive cites a Review Commission decision, Drexel Chemical Co. (1997), in which the employer's procedure "appeared to be derived from Appendix A to §1910.147," but "company officials failed to fill in any of the blanks." As the directive reports it, the form needed the names of affected employees, the types and magnitude of energy, the hazards, the methods to control the energy, the types and locations of machine operating controls and of energy isolating devices, the types of stored energy and how to dissipate it, and the method of verifying isolation. The Commission affirmed the violation of 1910.147(c)(4)(ii), and the directive adds that it reaffirmed the position in a 2007 General Motors case.

That leaves templates sold as "OSHA-approved." In the 2003 letter, OSHA wrote that it "does not test, approve, certify, or endorse any procedure, equipment, or product." A template is a starting point. The machine data is what makes it a procedure.

Which machines don't need a written procedure?

Only machines that meet every element of the Note to 1910.147(c)(4)(i). It opens: "Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist." In the order of the text, the eight elements are:

1. no potential for stored or residual energy, or for reaccumulation of stored energy after shutdown, that could endanger employees
2. a single energy source "which can be readily identified and isolated"
3. isolating and locking out that source "will completely deenergize and deactivate the machine or equipment"
4. the machine is isolated from that source and locked out during servicing or maintenance
5. "a single lockout device will achieve a locked-out condition"
6. the lockout device is "under the exclusive control of the authorized employee performing the servicing or maintenance"
7. the servicing or maintenance "does not create hazards for other employees"
8. the employer, in using the exception, "has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance"

The verb in the Note is document. The directive spells out what that means on page 3-40: "the procedure would need to be developed and utilized, but it would not need to be documented." The authorized employee still follows a procedure at that machine. It just isn't on paper. The same page calls a written procedure "necessary in most situations" and gives OSHA's example of a machine that can qualify: "a motor in a shop may be wired to an electrical disconnect. The authorized employee can isolate the motor from the electric energy source and lock it out, using her personal lockout device on the disconnect switch in accordance with the procedures set forth in the standard."

Element 8 is the one that can change on a Tuesday afternoon. One accident of unexpected start-up during servicing takes the machine out of the exception. Page 3-40 again: "procedure documentation becomes necessary if an accident involving hazardous energy occurs (in utilizing this exception) because such an occurrence indicates the need for more formal treatment of the energy control procedure."

A single energy source doesn't qualify a machine by itself. In a letter of April 11, 2000, now archived, OSHA looked at an oven heated with natural gas and called the exception "inapplicable": "Since it appears that the oven has at least two energy sources, and it is unlikely that a single lock-out device can be used to effectively lock-out the oven, at least two of the eight conditions which are essential to the application of the exception are not met." The letter adds that the gas, "if unexpectedly released and ignited, would produce potentially hazardous thermal energy," so a procedure under 1910.147(c)(4)(i) is required for it.

The size of the company doesn't change the answer either. Page 3-42 of the directive: "From the standpoint of safety, there is no basis for concluding that a small employer is inherently less likely to need a detailed written procedure than a large employer. Thus, the performance oriented requirements for written procedures are appropriate for all employers, regardless of size."

Which servicing tasks fall outside 1910.147?

The Note keeps the machine inside the standard and waives the paper. Paragraph 1910.147(a)(2) works differently: it takes some tasks out of the standard altogether, each under its own conditions.

• Normal production operations aren't covered. Servicing during production is covered only when an employee has to remove or bypass a guard or other safety device, or place part of the body where work is done on the material (the point of operation) or in an associated danger zone (1910.147(a)(2)(ii)). The Note to that paragraph excludes "minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations," if they're "routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection."
• Work on cord and plug connected electric equipment is outside the standard when unplugging the equipment controls the hazard and the plug stays under the exclusive control of the employee doing the work (1910.147(a)(2)(iii)(A)).
• Hot tap operations on pressurized pipelines that carry gas, steam, water or petroleum products are outside it when the employer demonstrates that continuity of service is essential, that shutdown of the system is impractical, and that "documented procedures are followed, and special equipment is used which will provide proven effective protection for employees" (1910.147(a)(2)(iii)(B)).

An exclusion holds only while every one of its conditions does. A cord and plug job where the plug lies on the floor across the shop, out of the employee's control, is back under 1910.147.

Does California require a written procedure for each machine?

As the default, yes, and the federal directive doesn't change that. California runs its own state plan, which "received initial approval on May 1, 1973" (29 CFR 1952.7(a)) and covers private-sector employers in the state "with several notable exceptions," along with state and local government employers (29 CFR 1952.7(c)). Its lockout rule is 8 CCR §3314. CPL 02-00-147 says of state plans that it "describes a Federal Program change for which State adoption is not required, but is recommended," so the grouping guidance above doesn't carry over to California by itself.

§3314(g) has the employer develop and use a hazardous energy control procedure, and §3314(g)(1) lists the same four kinds of content as the federal 1910.147(c)(4)(ii). Then §3314(g)(2) goes further:

(2) The employer's hazardous energy control procedures shall be documented in writing. (A) The employer's hazardous energy control procedure shall include separate procedural steps for the safe lockout/tagout of each machine or piece of equipment affected by the hazardous energy control procedure. (8 CCR §3314)

The exception to §3314(g)(2)(A) lets the same steps serve "a group or type of machinery or equipment, when either of the following two conditions exist":

• Condition 1, all three parts together: "(A) The operational controls named in the procedural steps are configured in a similar manner, and (B) The locations of disconnect points (energy isolating devices) are identified, and (C) The sequence of steps to safely lockout or tagout the machinery or equipment are similar."
• Condition 2: "The machinery or equipment has a single energy supply that is readily identified and isolated and has no stored or residual hazardous energy."

Two things change from the federal rule. §3314 has no counterpart to the federal Note, so nothing in it lets an employer skip writing the procedure for a machine that meets eight elements. And in California, a single energy supply with no stored energy doesn't waive the writing. It lets machines share steps.

§3314 does have exceptions, written for its subsections (c) and (d), the lockout and tagout duties, and numbered 1 to 3. Exception 1 covers minor servicing during normal production, in nearly the same words as the federal Note to 1910.147(a)(2)(ii). Exception 2 covers work on cord and plug connected equipment. Exception 3 drops the tags where an employer has a uniform system of unique, personally identifiable locks placed on the energy source. §3314 has no hot tap exception.

Cal/OSHA's Division of Occupational Safety and Health reads the rule the same way in its October 2022 guide, "Controls for Hazardous Energies Including Lockout/Tagout": "Employers must develop and provide a separate lockout/tagout procedure for each machine or piece of equipment on which the regulated work operations are conducted." The guide also says it "is neither a substitute for, nor a legal interpretation of, the occupational safety and health regulations." The binding text is §3314.

Do these rules apply on a construction site?

Not the federal one. 29 CFR 1910.147(a)(1)(ii) reads "This standard does not cover the following: (A) Construction and agriculture employment." OSHA's hazardous energy standards page lists three construction standards: 1926.417, "Lockout and tagging of circuits," 1926.702, "Requirements for equipment and tools," and 1926.64, "Process safety management of highly hazardous chemicals." Section 1926.417 is about tags. Controls to be deactivated during the work "shall be tagged," deenergized equipment and circuits "shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized," and tags "shall be placed to identify plainly the equipment or circuits being worked on." None of its three paragraphs asks for a written procedure. The question has its own article: does 1910.147 apply to construction.

California again goes its own way. §3314 doesn't use the word construction, and the Construction Safety Orders don't cite it. But Construction Safety Orders §1502(c) says "Machines, equipment, processes, and operations not specifically covered by these Orders shall be governed by other applicable general Safety Orders," and General Industry Safety Orders §3202(a) says those orders "apply to all employments and places of employment in California as defined by Labor Code Section 6303." The Construction Safety Orders have no general rule of their own on hazardous energy for machines, and the Appeals Board has applied §3314 to construction employers. In Drill Tech Drilling & Shoring, a decision after reconsideration filed August 7, 2025, the Board wrote: "The ALJ accordingly determined, and we agree, that section 3314 applied to the drill rig in question." In A. Teichert and Son, filed July 10, 2025, a construction company had been cited under "section 3314, subdivision (d) [failure to lock-out/tag-out machinery]." Neither decision is designated precedential, and neither discusses §1502. On a California job, plan on §3314, written procedures included.

How do you tie each lockout to the right procedure?

Whatever the count, the procedure that protects anyone is the one in hand when the lock goes on. HazComFast ties every isolation point to its energy control procedure, and a lockout on a point with no active procedure is refused, with the point named in the refusal. A procedure starts from one point and lists the machines it covers under "Equipment covered," so a procedure written for a group of similar machines names each of them. It has a responsible person and an inspection date, and it can't be activated until its energy sources and steps are filled in: the screen lists what's "Still needed before activation." When a machine changes, "Revise the procedure" creates a new version that replaces the active one.

The exclusions in 1910.147(a)(2) are claimed on the lockout itself, every condition ticked and a reason written: five conditions for minor servicing during normal production, three for cord and plug equipment, four for a hot tap. Leave one out and the claim is refused. On a California jobsite, minor servicing is the only exclusion the form accepts.

At the machine, each point has its own QR label. Scanned by someone in your organization, it opens the point's page: who holds the lockout, since when, the lock number and the procedure it runs under. Anyone else who scans it learns that the point is locked out, never by whom. Rename the point and the label already posted opens the corrected name.

A procedure also has to say how locks are placed, removed and transferred, and who is responsible for them (1910.147(c)(4)(ii)(C)). For crews, 1910.147(f)(3)(ii)(D) has each authorized employee "affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work." For shift changes, 1910.147(f)(4) asks for "the orderly transfer of lockout or tagout device protection between off-going and oncoming employees." In a HazComFast group lockout, the holder verifies zero energy and each member puts a personal lock on the box after acknowledging the procedure. The group lockout can't come off while a personal lock is still on it. At shift change it passes with both signatures, and the personal locks stay where they are. A single lockout goes to the incoming employee, who accepts it at the equipment.

Testing is the other moment the locks come off. 1910.147(f)(1) sets the order for testing or positioning a machine: clear it of tools and materials, remove employees from the area, remove the lockout or tagout devices, energize and proceed with the test, then deenergize and reapply the energy control measures. In HazComFast, a test with the lockout off follows those steps in order, and the lockout can't be removed or handed over until it's back on. The lockout form also suggests the next free lock number and refuses a lock that's already in use.

The lock left on a Friday doesn't wait for someone to spot it on Monday. Once a lockout runs past its planned duration, its holder gets an alert, and four hours later the jobsite's managers get one too. The periodic inspection of 1910.147(c)(6) sits on each procedure as well, with a reminder as it comes due, and the inspector has to be someone other than the employees using the procedure.

Related reading: The complete LOTO guide · Does 1910.147 apply to construction? · Near misses, JHAs and LOTO