Lockout/Tagout (LOTO) Complete Guide: Energy Control for General Industry & Construction

Why Lockout/Tagout Matters in Construction

OSHA estimates that compliance with its lockout/tagout standard, 29 CFR 1910.147, prevents about 120 fatalities and 50,000 injuries each year, and that workers injured by hazardous energy lose an average of 24 workdays to recover. The standard ranks third on OSHA's preliminary list of the most frequently cited standards for fiscal year 2026 (October 1, 2025 to August 31, 2026), and a serious violation carries a maximum penalty of $16,550 (29 CFR 1903.15(d)).

Construction caveat: 29 CFR 1910.147 does not apply to construction: 1910.147(a)(1)(ii) expressly excludes "construction and agriculture employment." There is no single construction-industry LOTO standard equivalent to 1910.147. In construction, energy control is governed by 29 CFR 1926.417 (electrical lockout/tagging of circuits, Subpart K), equipment-specific 1926 standards (e.g., 1926.702(j) in Subpart Q, Subpart V), 1926.20/1926.21, and the General Duty Clause (Section 5(a)(1)). The general-industry practices below (six energy types, 8-step procedure, group LOTO, annual periodic inspection) can serve as best-practice models on construction sites, but the codified construction obligations flow from the 1926 standards above, not 1910.147. Our article on whether 1910.147 applies to construction walks through them.

This guide covers the elements of an energy control program under 1910.147 and what carries over to a jobsite: equipment maintenance, electrical work, mechanical systems, and any servicing where unexpected energization could cause injury.

Free Tool: Use our LOTO Procedure Generator to create machine-specific energy control procedures in minutes, with general-industry or construction citations.

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What Is Lockout/Tagout?

Lockout is the placement of a lock on an energy-isolating device to hold it in a safe position. Tagout is the placement of a warning tag on the device. Together, they make up the energy control procedure that protects workers during servicing and maintenance.

Key Definitions (1910.147(b))

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The 6 Types of Hazardous Energy

OSHA's standard defines an energy source as "any source of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy" (1910.147(b)), a non-exhaustive list rather than a fixed count. The grouping into "6 types" below is a common training aid. Every energy control procedure must address all energy sources present in the equipment; missing even one can be fatal.

1. Electrical Energy

Electrical energy includes:

• AC/DC power circuits: motors, lighting, control systems
• Capacitive storage: capacitors that retain charge after disconnection
• Battery backup systems: UPS, emergency lighting

Isolation method: Open disconnect switches, trip circuit breakers, remove fuses. Verify with a calibrated voltage tester on all phases.

2. Hydraulic Energy

High-pressure fluid systems that can cause severe injuries:

• Hydraulic presses, lifts, and cylinders
• Accumulators that store pressurized fluid
• Elevated components held in position by hydraulic pressure

Isolation method: Close and lock isolation valves, bleed pressure from accumulators and lines. Verify with pressure gauges (must read 0 PSI). Block elevated components.

3. Pneumatic Energy

Compressed air and gas systems:

• Air compressor supply lines
• Pneumatic tools and actuators
• Air receivers and tanks

Isolation method: Shut off air supply, close and lock isolation valves, bleed residual pressure. Verify with pressure gauges and by attempting to actuate controls.

4. Thermal Energy

Heat sources that can cause burns:

• Steam lines and boilers
• Electric heaters and ovens
• Exothermic chemical processes

Isolation method: Shut down heat source, close and lock steam valves, allow cool-down time. Verify with infrared thermometer or contact probe.

5. Chemical Energy (Stored)

Chemical reactions and stored chemicals:

• Chemical feed lines and reaction vessels
• Hazardous material pipelines
• Corrosive or toxic chemical storage

Isolation method: Stop pumps, close and lock valves, drain or purge lines, flush with inert material. Verify with atmospheric monitoring.

6. Gravity / Mechanical Energy

Stored energy from position or tension:

• Suspended loads (cranes, hoists, elevators)
• Springs and tensioned components
• Material that could slide, fall, or collapse

Isolation method: Lower loads, insert mechanical blocks/pins/cribbing, engage mechanical stops. Verify by attempting to move blocked components.

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The 8-Step LOTO Procedure

1910.147(d) sets six elements that every energy control procedure covers, in a fixed sequence: preparation for shutdown, shutdown, isolation, application of the lockout or tagout devices, stored energy, and verification of isolation. Paragraph (c)(9) adds the notification of affected employees before the devices go on and after they come off. With notification and the servicing itself, they make the 8 steps below.

Step 1: Preparation

Identify all energy sources, types, and magnitudes, and the hazards of the energy to be controlled (1910.147(d)(1)). Determine which employees will be affected. Gather all necessary lockout/tagout devices.

Step 2: Notification

Notify all affected employees that the equipment will be shut down and locked out, before the devices are applied (1910.147(c)(9)). Explain the reason and expected duration.

Step 3: Equipment Shutdown

Shut down the equipment using its established stopping procedure, in an orderly way that adds no hazard (1910.147(d)(2)). Opening a disconnect under load is one such hazard.

Step 4: Energy Isolation

Locate and operate all energy-isolating devices needed to isolate the equipment from every energy source (1910.147(d)(3)): electrical disconnects, valves, and blocks.

Step 5: Lockout/Tagout Application

Authorized employees affix lockout or tagout devices to every energy-isolating device (1910.147(d)(4)(i)). A lock is the rule where the device can take one; a tag alone is used only where it cannot, or where the employer shows that tagout gives full employee protection (1910.147(c)(2), (c)(3)). Each device shows the identity of the employee who applied it (1910.147(c)(5)(ii)(D)).

Step 6: Stored Energy

Relieve, disconnect, restrain or otherwise render safe all stored or residual energy (1910.147(d)(5)(i)):

• Discharge capacitors
• Bleed hydraulic/pneumatic lines
• Block elevated components
• Allow thermal cool-down

If stored energy could build back up to a hazardous level, keep verifying isolation until the work is done (1910.147(d)(5)(ii)).

Step 7: Verification of Isolation

Before work starts, the authorized employee verifies that the equipment is isolated and de-energized (1910.147(d)(6)). OSHA's sample procedure does it by operating the normal controls to make sure the equipment will not run, then returning them to "off." Trying the controls is not enough on its own for electrical work: under 1910.333(b)(2)(iv)(B), a qualified person uses test equipment to verify that the circuit elements and parts employees will be exposed to are de-energized, including from induced voltage or backfeed.

Try, then test: what to write down for each isolation point

The rule speaks of the machine: the authorized employee verifies "that isolation and deenergization of the machine or equipment have been accomplished" (1910.147(d)(6)). It doesn't name a method. OSHA's November 16, 2000 interpretation letter names three: "a deliberate attempt to start up the machine or equipment," "visual inspection techniques," and "testing the machine or equipment with an appropriate test instrument."

On equipment with three isolation points, though, the machine isn't verified until each source is. So the record worth keeping goes point by point. Which method was used at the main disconnect, which at the air valve, which at the hydraulic block. For a meter, which meter and what it read. And for stored energy, the answer to (d)(5)(i): relieved, disconnected or restrained, or no stored energy on this point, and why.

In HazComFast, each isolation point you select on a lockout gets its own "Verify zero energy" line. You pick the method (test instrument reading, attempted restart, visual inspection, pressure gauge at zero, or another you describe) and answer the stored-energy question for that point. A test instrument reading asks for the make and model, the ID, the reading and its unit, and whether the meter was checked on a known live source before and after. Select two points and verify one, and the lockout won't save: the message names the point still open, "Zero-energy verification incomplete for:" followed by its name. On an electrical point, only a test instrument reading is accepted. That one is our rule, set in the product.

On a jobsite, 1910.147 doesn't apply (1910.147(a)(1)(ii)(A)). 1926.417(b) still wants deenergized circuits "rendered inoperative" with tags "at all points where such equipment or circuits can be energized," and 1926.702(j)(1) wants "all potentially hazardous energy sources" locked out and tagged before maintenance on concrete and masonry equipment. A point-by-point record answers both.

Step 8: Perform Servicing

With all energy sources isolated, locked, and verified, servicing may begin.

Before the locks come off

The eight steps end at the work, and many procedures stop there. 1910.147(e) picks up at the other end: before the devices come off and energy is restored, the authorized employee makes sure of two things. (e)(1), the machine: "The work area shall be inspected to ensure that nonessential items have been removed and to ensure that machine or equipment components are operationally intact." (e)(2)(i), the people: "The work area shall be checked to ensure that all employees have been safely positioned or removed." Then each device comes off, removed by the employee who applied it (1910.147(e)(3)). When that employee has left the site, the exception and its steps are in our article on an employee who left a lockout lock on.

The two checks take a minute. A wrench left on a conveyor frame, a guard set aside and never bolted back, an apprentice still behind the panel: (e)(1) and (e)(2) are written for those.

In HazComFast, the removal dialog carries both checks in the rule's own words: "Work area inspected: nonessential items removed and components operationally intact" and "All employees safely positioned or removed". Confirm Removal stays grayed out until both are ticked, even with the signature and the reason filled in. The server refuses a removal recorded without them, so the check holds outside the screen too.

Taking the locks off: who has to be told

In general industry the answer is written twice. 1910.147(c)(9): "Affected employees shall be notified by the employer or authorized employee of the application and removal of lockout devices or tagout devices. Notification shall be given before the controls are applied, and after they are removed from the machine or equipment." And (e)(2)(ii): "After lockout or tagout devices have been removed and before a machine or equipment is started, affected employees shall be notified that the lockout or tagout device(s) have been removed."

Affected employees are defined in 1910.147(b): the people whose job is to operate or use the machine, or who work in the area where the servicing is done. That's the operator on the next shift and the crew working beside the line, not only their foreman.

In construction, 1926.417 and 1926.702(j) say nothing about telling anyone. Your own program decides who hears that the locks are off. One person is easy to forget there: the supervisor of the permit that counted on that lock. A confined space entry, a hot work job or an excavation can rely on a lockout to keep a pump, an agitator or a conveyor still.

In HazComFast, a lockout can be linked to a hot work, confined space or excavation permit. When it's removed, the permit's supervisor gets a notification in the app, "Lockout removed on permit" followed by the permit number, with the time of removal in your organization's time zone, written next to it (UTC when none is set). It also says when the person removing the lock marked the permit as closed.

The link works the other way too. A permit that names isolation points won't issue until each one is locked out under that permit, and it won't close while one of those locks is still on.

Shift changes, testing, and contractors

• Shift or personnel changes: specific procedures keep the protection continuous, including an orderly transfer of devices between off-going and oncoming employees (1910.147(f)(4)).
• Testing or positioning: when the machine must be energized during the work, clear it, remove employees, remove the devices as in (e)(3), test or position, then de-energize and reapply the controls (1910.147(f)(1)).
• Outside servicing personnel: the on-site employer and the contractor inform each other of their procedures, and the on-site employer's employees follow the contractor's restrictions (1910.147(f)(2)).

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Group Lockout/Tagout

When a crew, craft or department services the same equipment, it uses a procedure that gives each worker protection equivalent to a personal lock (1910.147(f)(3)(i)):

1. One authorized employee carries primary responsibility for a set number of workers under the group lockout device (1910.147(f)(3)(ii)(A))
2. That employee can confirm the exposure status of each group member (1910.147(f)(3)(ii)(B))
3. When several crews or crafts are involved, one authorized employee coordinates them and the continuity of protection (1910.147(f)(3)(ii)(C))
4. Each authorized employee puts a personal lock or tag on the group lockout device or lockbox when starting work and removes it when stopping (1910.147(f)(3)(ii)(D))
5. The equipment is not re-energized until every personal device is off

Group LOTO Requirements

• A procedure addressing group lockout, written into the energy control procedures (1910.147(f)(3)(ii))
• A designated primary authorized employee
• A personal lockout or tagout device for each group member
• An accountability system for all employees

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Periodic Inspections (Annual Audit)

In general industry, 29 CFR 1910.147(c)(6) requires a periodic inspection at least annually of each energy control procedure. 1910.147 excludes construction (1910.147(a)(1)(ii)(A)), so on a jobsite the same inspection is voluntary best practice:

What the inspection should catch

• Procedures not updated for equipment modifications
• Employees skipping stored-energy release or verification
• Shared locks instead of personal, identifiable devices
• Tagout used where lockout is feasible
• No certification of past inspections

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Ten LOTO Citation Traps

Each of these is a written requirement of 1910.147:

1. No written energy control procedures for specific equipment (1910.147(c)(4)(i)). A narrow exception applies only when all eight conditions listed in that paragraph exist, among them a single energy source, no stored or residual energy, a single lockout device under the servicing employee's exclusive control, and no accident from unexpected activation during servicing
2. Failure to train authorized and affected employees (1910.147(c)(7)(i))
3. No annual periodic inspection of procedures (1910.147(c)(6)(i))
4. Using tagout when lockout is feasible: lockout is required unless the employer can demonstrate full protection with tagout (1910.147(c)(2)(ii), (c)(3))
5. Not verifying isolation before work starts (1910.147(d)(6))
6. Missing stored-energy controls: failing to bleed pressure, block components, or discharge capacitors (1910.147(d)(5)(i))
7. Anonymous or shared locks: each device must identify the employee who applied it (1910.147(c)(5)(ii)(D))
8. No group LOTO procedure for multi-person maintenance (1910.147(f)(3))
9. No training certification: the employer certifies training with each employee's name and dates (1910.147(c)(7)(iv))
10. No retraining after changes in job assignments, equipment, processes or procedures (1910.147(c)(7)(iii)(A))

OSHA does not publish which paragraphs it cites most across all industries. In its fiscal year 2025 inspections of employers classified in construction, the most cited 1910.147 paragraphs were (c)(1), the energy control program (6 citations), (c)(4)(i), the written procedures (5), and (c)(7)(i), training (4) (HazComFast count from U.S. Department of Labor enforcement data, federal inspections, NAICS 23, extracted September 26, 2026).

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LOTO Training Requirements

Initial Training

Every employee receives training appropriate to their role (1910.147(c)(7)(i)):

• Authorized employees: recognition of the applicable hazardous energy sources, the type and magnitude of the energy, and the methods and means of isolation and control (1910.147(c)(7)(i)(A))
• Affected employees: the purpose and use of the energy control procedure (1910.147(c)(7)(i)(B))
• Other employees who work where energy control may be used: the procedure, and the prohibition on attempts to restart or re-energize locked-out or tagged-out equipment (1910.147(c)(7)(i)(C))

Where tagout is used, employees also learn the limits of tags: a tag is a warning, not a physical restraint, and it is never removed without authorization or bypassed (1910.147(c)(7)(ii)).

Retraining Triggers

Retraining is required for authorized and affected employees when (1910.147(c)(7)(iii)):

• Their job assignments change
• A change in machines, equipment or processes presents a new hazard
• Energy control procedures change
• A periodic inspection reveals, or the employer has reason to believe there are, deviations or gaps in an employee's knowledge or use of the procedures

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LOTO vs. HazCom: The Connection

Lockout/Tagout and Hazard Communication meet on the jobsite and in the plant:

• Chemical energy isolation draws on SDS Section 7 (Handling and Storage) and Section 10 (Stability and Reactivity)
• Hazardous chemical pipelines must be identified, drained, and purged, which takes accurate chemical inventory data
• Training integration: LOTO training should reference the chemical hazards specific to the equipment being serviced

Build your LOTO procedures: Use our free LOTO Procedure Generator to create machine-specific energy control procedures with all 6 energy types.

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Tools, standards & related reading

Build your program: LOTO Procedure Generator · HazCom Compliance Scorer · OSHA Fine Calculator

Related guides: Lockout/Tagout hub · Does OSHA's LOTO 1910.147 Apply to Construction? · Electrical Safety in Construction (Subpart K & NFPA 70E) · Crane & Rigging Safety · When safety software manufactures evidence against you

Penalties: 2026 OSHA penalty schedule · penalties by state

Primary sources (1910.147(c)(4)(i), (e), (f), 1910.333(b)(2)(iv), OSHA FS-3529 and OSHA's top 10 list re-read on October 14, 2026): 29 CFR 1910.147 (general industry; excludes construction per (a)(1)(ii)) · 29 CFR 1926.417, lockout and tagging of circuits (construction) · OSHA Lockout/Tagout Fact Sheet (FS-3529)