Lockout Tagout Violations: OSHA's #5 Most Cited

Last updated: April 2026

In fiscal year 2024, OSHA issued 2,443 lockout tagout citations, making it the #5 most-cited standard in the country. That was a 24% jump from the prior year. Between October 2022 and September 2023, LOTO violations across 1,368 inspections resulted in $20.7 million in total penalties. Lockout tagout violations occur when employers fail to establish, document, or enforce energy control procedures that prevent unexpected equipment startup during servicing or maintenance. The violations follow predictable patterns. Here are the most common failures, what they cost, and exactly how to fix each one.

The 10 Most Common Lockout Tagout Violations

OSHA's LOTO citations cluster around the same failures year after year. Each one maps to a specific subsection of 29 CFR 1910.147. If your program has any of these gaps, fix them before an inspector finds them.

1. No Written, Machine-Specific Procedures (1910.147(c)(4))

The single most-cited LOTO violation. Employers have a generic lockout policy but no documented procedure for each piece of equipment. OSHA requires a written procedure that identifies the specific energy sources, isolation devices, and step-by-step lockout/verification methods for each machine. A one-page policy that says "lock out equipment before servicing" does not satisfy this requirement. If you have 30 machines with different energy configurations, you need 30 machine-specific procedures.

2. Inadequate Training (1910.147(c)(7))

Three categories of workers need LOTO training: authorised, affected, and other employees. The most common training gap is failing to train affected employees (operators who use locked-out equipment but do not apply locks). If an operator does not know what a lock on a disconnect switch means, your training program has failed. OSHA also cites employers for not certifying training with employee names and dates.

3. No Periodic Inspection (1910.147(c)(6))

OSHA requires an annual inspection of each energy control procedure. The inspection must be conducted by an authorised employee who is not using the procedure being reviewed. Many employers write procedures and never review them. If equipment has been modified since the procedure was written, the procedure is outdated, and the inspection would have caught it.

4. Failure to Verify Isolation (1910.147(d)(6))

Workers apply locks and tags but skip the verification step. They assume the equipment is de-energised because the breaker is off. Then a capacitor discharges, or backup power kicks in, or hydraulic pressure drifts. The standard requires the authorised employee to verify de-energisation by testing (try the start controls, check pressure gauges, test with a voltage meter) before starting work.

5. Using Tagout When Lockout Is Feasible (1910.147(c)(3))

If an energy-isolating device can accept a lock, you must use a lock. Tagout alone is only permitted when the device physically cannot be locked. Even then, the employer must demonstrate that the tagout program provides full employee protection. OSHA strongly prefers lockout, and any equipment installed after January 2, 1990, must be designed to accept a lock.

6. Locks Not Individually Keyed or Identified (1910.147(c)(5))

Lockout devices must be singularly identified. Each authorised worker must have their own lock with a unique identifier. Shared locks, combination locks, or locks without identification are violations. In Alberta, OHS Code s. 214 explicitly requires personal lock assignment with a maintained written list.

7. No Group Lockout Procedures (1910.147(f)(3))

Turnarounds, shutdowns, and large maintenance jobs involving multiple workers and multiple energy sources require group lockout procedures. The standard requires a single authorised employee to coordinate the group lockout and each worker to apply their own personal lock (typically to a group lockbox). Employers who use a single lock for the entire crew are in violation.

8. Improper Lock Removal (1910.147(e)(3))

Only the authorised employee who applied a lock should remove it. Supervisors who remove locks because a worker went home, or crews that use master keys to clear lockout at shift change, are violating the standard. OSHA requires a specific procedure for lock removal when the authorised employee is unavailable, including verification that the employee is not at the facility and reasonable efforts to contact them.

9. Not Controlling Stored Energy (1910.147(d)(5))

Isolating the energy source is not enough if residual energy remains. Capacitors hold charge after electrical disconnect. Hydraulic cylinders hold pressure after valves close. Springs store mechanical energy whether power is on or off. The standard requires that stored energy be dissipated, discharged, restrained, or otherwise rendered safe before work begins.

10. No Procedures for Contractor Coordination (1910.147(f)(2))

When outside contractors work on equipment, the employer and the contractor must inform each other of their respective lockout procedures. Inspectors cite employers who allow contractors to work without verifying that the contractor's LOTO procedures are compatible with the host employer's procedures.

LOTO Penalty Amounts (2025 Rates)

United States (OSHA)

OSHA penalty amounts are adjusted annually for inflation. Current rates as of January 15, 2025:

Source: OSHA Penalties, effective Jan 15, 2025.

A single inspection can yield multiple citations. In the food manufacturing sector alone, LOTO violations accounted for 384 citations and $7.5 million in penalties during FY2023. Willful violations, where OSHA determines the employer knowingly disregarded the standard, carry penalties nearly 10x higher than serious violations.

Employers placed in OSHA's Severe Violator Enforcement Program (SVEP) face mandatory follow-up inspections, corporate-wide enforcement action, and public listing. LOTO willful violations are a common trigger for SVEP placement.

Canada

Canadian penalties vary by province but can be equally severe:

• Alberta: Administrative penalties of up to $10,000 per offence and $10,000 per day the offence continues (OHS Act s.41). Conviction penalties: up to $500,000 and 6 months imprisonment for a first offence (OHS Act s.48(1)).
• British Columbia: WorkSafeBC administrative penalties based on employer size and violation history. Maximum penalties for repeat serious violations can reach hundreds of thousands of dollars.
• Ontario: Maximum fines of $100,000 for individuals and $1,500,000 for corporations under the OHSA. Directors and officers can be held personally liable.

Beyond direct penalties, LOTO violations in Canada can affect WCB premium rates, COR certification status, and prequalification standing with major operators. For contractors bidding through ISNetworld or Avetta, a LOTO violation on record can disqualify you from bid lists.

How to Fix Each Violation Before an Inspection

Every violation on the list above has a fix. Here is the practical path from gap to compliance for the most common failures.

No written procedures? Start with an energy survey of every machine. Write one procedure per machine using a standardised template. Prioritise equipment with the highest energy levels and most frequent servicing.

Training gaps? Classify every worker as authorised, affected, or other. Deliver role-appropriate training. Document names, dates, content covered, and trainer. Certify the training per OSHA requirements. See our full guide on LOTO training requirements.

No annual inspections? Schedule them now. Assign inspectors (who are not using the procedures they inspect). Use a checklist. Document findings and corrective actions. Set calendar reminders for next year.

Verification being skipped? Make verification a checklist item on every LOTO procedure. Train authorised employees to always try the start controls, check gauges, and test circuits before starting work. Treat skipped verification as a safety stop: if it did not happen, the lockout tagout procedure is not complete.

Shared or unmarked locks? Issue individually keyed, uniquely marked locks to every authorised employee. Maintain a written assignment list. In Alberta, this is explicitly required under OHS Code s. 214.

If you are managing LOTO compliance across multiple sites, consider EHS software that tracks procedures, training records, inspection dates, and lock assignments in one system. Spreadsheets work until they do not, and the gap between "works" and "does not" is usually discovered during an inspection.

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