Written energy control program: what OSHA 1910.147 requires
OSHA's lockout/tagout standard requires an energy control program (1910.147(c)(1)): energy control procedures, employee training and periodic inspections. In practice you need a written program document that ties these together, plus the machine-specific procedures it refers to. Here is what belongs in it, mapped to the paragraphs of the standard.
| Program section | Where it comes from |
|---|---|
| Purpose and scope: which servicing and maintenance activities it covers, and the cord-and-plug exception | 1910.147(a) |
| Responsibilities: program administrator, supervisors, authorized, affected and other employees | (c)(7), (c)(8) |
| Machine-specific procedures, listed with their revision and review dates | (c)(4) |
| Lockout vs. tagout. Lockout is the rule when a device can accept a lock. Tagout only gives full protection with extra measures. | (c)(2), (c)(3) |
| Protective materials and hardware: locks and tags that are provided by the employer, durable, standardized, substantial and identifiable | (c)(5) |
| Sequence of applying lockout | (d)(1)–(6) |
| Release from lockout, including lock removal when the employee who applied it isn't there | (e)(1)–(3) |
| Testing or positioning while locked out | (f)(1) |
| Outside contractors | (f)(2) |
| Group lockout | (f)(3) |
| Shift and personnel changes | (f)(4) |
| Annual periodic inspection and its certification | (c)(6) |
| Training, retraining and training certification | (c)(7) |
| Notifying affected employees | (c)(9) |
The pieces people skip
Lock removal by someone else
Locks come off only by the person who put them on. The standard allows one exception, under the employer's direction, with a specific procedure. You must verify the employee isn't at the facility, make all reasonable efforts to contact them, and make sure they know before they resume work. Write it down before you need it.
Contractors
Before outside servicing personnel start, you and the contractor exchange lockout procedures. Your employees must understand and follow the contractor's program.
Group lockout and shift changes
Group work needs one authorized employee with primary responsibility, and each worker puts a personal lock on the group device. At shift change, protection must stay continuous: the incoming lock goes on before the outgoing lock comes off.
Training roles
- Authorized employees lock out equipment. They are trained to recognize hazardous energy sources, the type and magnitude of energy in the workplace, and how to isolate and control it.
- Affected employees operate or work around the equipment. They are trained in the purpose and use of the procedure.
- Other employees work in the area. They are told about the procedure and that they must never restart locked-out equipment.
Retraining is required when assignments, machines, processes or procedures change, when a new hazard appears, or when an inspection finds deviations. Certify training with each employee's name and the training dates.
Frequently asked questions
Is a written lockout/tagout program required?
Yes. 29 CFR 1910.147(c)(1) requires an energy control program made up of energy control procedures, employee training and periodic inspections, and (c)(4) requires the procedures to be documented.
Who should be the program administrator?
Someone with authority over maintenance and safety: often a maintenance manager, plant manager or EHS lead. They keep procedures current, issue locks and tags and keep inspection and training records.
How often should the program be reviewed?
Each procedure must be inspected at least annually under (c)(6). Review the written program at the same time and whenever equipment, processes or staffing change.
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This guide summarizes 29 CFR 1910.147 for general information. It is not legal advice. Read the standard itself, and check any state-plan or provincial rules that apply to you.