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 ranked fourth on OSHA's list of the most frequently cited standards for fiscal year 2025, 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 comprehensive 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.
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))
| Term | Definition |
|---|---|
| Energy-isolating device | A mechanical device that physically prevents the transmission or release of energy: a manually operated circuit breaker, a disconnect switch, a line valve, a block. Push buttons, selector switches and other control-circuit devices are not energy-isolating devices |
| Lockout device | A device that uses a positive means, such as a lock, to hold an energy-isolating device in a safe position |
| Tagout device | A prominent warning device, such as a tag and its means of attachment, securely fastened to an energy-isolating device to show it may not be operated until the tag is removed |
| Authorized employee | A person who locks out or tags out machines or equipment to service or maintain them |
| Affected employee | An employee who operates or uses the machine being serviced under lockout or tagout, or who works in the area where the servicing is done |
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.
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.
The 8-step energy-control sequence
- 1Prepare: ID every source
- 2Notify affected workers
- 3Shut down normally
- 4Isolate every energy source
- 5Apply locks + tags (one each)
- 6Release stored energy
- 7Verify zero: try to restart
- 8Service the equipment
Step 7 is 1910.147(d)(6): verify isolation before work starts. OSHA's sample procedure (Appendix A) operates the normal controls, then returns them to off.
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)). 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."
Step 8: Perform Servicing
With all energy sources isolated, locked, and verified, servicing may begin.
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)):
- One authorized employee carries primary responsibility for a set number of workers under the group lockout device (1910.147(f)(3)(ii)(A))
- That employee can confirm the exposure status of each group member (1910.147(f)(3)(ii)(B))
- When several crews or crafts are involved, one authorized employee coordinates them and the continuity of protection (1910.147(f)(3)(ii)(C))
- 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))
- 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
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:
| Requirement | Details |
|---|---|
| Frequency | At least annually for each procedure (1910.147(c)(6)(i)) |
| Inspector | An authorized employee other than the ones using the procedure (1910.147(c)(6)(i)(A)) |
| Scope | Review each authorized employee's responsibilities where lockout is used; each authorized and affected employee's where tagout is used (1910.147(c)(6)(i)(C), (D)) |
| Documentation | Certification naming the machine or equipment, the date, the employees included, and the inspector (1910.147(c)(6)(ii)) |
| Corrections | Correct any deviations or inadequacies found (1910.147(c)(6)(i)(B)) |
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
Ten LOTO Citation Traps
Each of these is a written requirement of 1910.147:
- No written energy control procedures for specific equipment (1910.147(c)(4)(i))
- Failure to train authorized and affected employees (1910.147(c)(7)(i))
- No annual periodic inspection of procedures (1910.147(c)(6)(i))
- 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))
- Not verifying isolation before work starts (1910.147(d)(6))
- Missing stored-energy controls: failing to bleed pressure, block components, or discharge capacitors (1910.147(d)(5)(i))
- Anonymous or shared locks: each device must identify the employee who applied it (1910.147(c)(5)(ii)(D))
- No group LOTO procedure for multi-person maintenance (1910.147(f)(3))
- No training certification: the employer certifies training with each employee's name and dates (1910.147(c)(7)(iv))
- 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).
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
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.
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: 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)
Frequently Asked Questions
What OSHA standard covers Lockout/Tagout?
In general industry, 29 CFR 1910.147, The Control of Hazardous Energy, requires employers to establish energy control procedures, train employees, and conduct periodic inspections. 1910.147(a)(1)(ii) expressly excludes construction. There is no single comprehensive construction LOTO standard; construction energy control is governed by 29 CFR 1926.417 (electrical, 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.
When is LOTO required?
In general industry, 29 CFR 1910.147 applies to the servicing and maintenance of machines and equipment where unexpected energization, start-up or release of stored energy could injure employees (1910.147(a)(1)(i)). Servicing includes setting up, adjusting, lubricating, cleaning, unjamming and tool changes (1910.147(b)). During normal production, it applies only when an employee removes or bypasses a guard or puts a body part into the point of operation or a danger zone (1910.147(a)(2)(ii)).
What are 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 (29 CFR 1910.147(b)), a non-exhaustive list, not a fixed count. As a common training shorthand these are often grouped into six: electrical, hydraulic, pneumatic, thermal, chemical (stored energy), and gravity/mechanical (stored energy). Each requires specific isolation and verification methods.
What is the difference between lockout and tagout?
Lockout uses a lock to hold an energy-isolating device in a safe or off position; tagout uses a prominent warning tag (29 CFR 1910.147(b)). If the device can be locked out, the program must use lockout unless the employer can demonstrate that tagout gives full employee protection under the conditions of 1910.147(c)(3) (1910.147(c)(2)(ii)). Tagout alone is the rule only where the device cannot be locked (1910.147(c)(2)(i)).
Who is an authorized employee under LOTO?
Under 29 CFR 1910.147(b), an authorized employee is a person who locks out or tags out machines or equipment to service or maintain them. Each one must be trained to recognize the 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)).
How often must LOTO procedures be inspected?
At least annually, under general industry 29 CFR 1910.147(c)(6)(i), by an authorized employee other than the ones using the procedure. Where lockout is used, the inspector reviews each authorized employee's responsibilities; where tagout is used, each authorized and affected employee's (1910.147(c)(6)(i)(C) and (D)). The employer certifies each inspection (1910.147(c)(6)(ii)). This is a general-industry requirement; construction employers should treat it as best practice.
OSHA figures and citations here come from our regulatory source-of-truth modules, last checked against the eCFR, OSHA.gov, and the Federal Register on October 5, 2026. Last reviewed October 2, 2026.
About This Article
Published by: HazComFast
Published: March 9, 2026
Last Updated: October 2, 2026
This content is for informational purposes only and does not constitute legal advice.
