Digital Facility Management

Compliance

Lockout tagout, and the part that gets missed

February 13, 2026 · 7 minute read

Lockout tagout is isolating a machine from its energy sources so it cannot start while somebody is working on it. In the United States the rule is 29 CFR 1910.147, the control of hazardous energy. Most programmes have locks, tags and training. The two things most often missing are equipment-specific procedures and the annual inspection.

What the standard asks for

  • A written energy control programme
  • Documented procedures specific to the machine, not one generic procedure for the site
  • Locks and tags that are durable, standardised and used only for this
  • Training for authorised, affected and other employees, with retraining when things change
  • A periodic inspection at least annually, by somebody other than the person using the procedure

The equipment-specific procedure is the common gap

A single site-wide procedure is not enough for machines with more than one energy source. The procedure has to name the machine, the energy sources, the isolation points, the order, and how to verify that isolation worked.

The standard does allow a documented procedure to be omitted for a narrow set of simple machines, and the conditions are specific: a single energy source that can be readily identified and isolated, no stored energy, and several other requirements all being met. That exemption is much narrower than it is usually assumed to be, and reaching for it is how sites end up with nothing written down.

Stored energy is what hurts people

Turning the power off does not empty a hydraulic accumulator, release a spring, drain a pressurised line, lower a raised platform, or stop a flywheel. The procedure has to say how each stored source is released or restrained, and verification has to prove it.

The annual inspection is a real task

It is not a paperwork review. Somebody has to observe the procedure in use, check it against what the machine actually needs, and correct any deviation. It has to be done by an authorised employee other than the one using the procedure being inspected, and it has to be certified with the machine, the date, the people involved and who performed the inspection.

Contractors are part of your programme

Where outside people work on your equipment, the standard requires the two employers to inform each other of their procedures, and for your people to understand and comply with the contractor’s restrictions. A contractor arriving with their own locks and no conversation is a common and serious gap.

How to make it stick day to day

Put the machine-specific procedure on the machine, reachable by scanning a code, rather than in a folder in an office. Attach the isolation points to the asset record so they arrive with the job. And make the annual inspection a scheduled item per procedure, not a single calendar entry for the site, or it will cover three machines and be recorded as covering forty.

This page describes the United States federal rule. Requirements differ elsewhere, and the underlying practice of isolate, secure, verify is the same everywhere.

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