Minimal lockout procedure guidance

Tagout may be used only when the energy isolating device is not capable of being locked out. Employers must follow the additional training and inspection requirements that the standard requires for tagout, and if the device is lockable but tagout is used, the employer must provide the same level of employee protection as with lockout. See the guidance in Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the requirement for full employee protection in 1910.147(c)(3).

The purpose of the lockout procedure is to ensure machines are stopped, isolated from all hazardous energy sources, and locked out so employees can perform servicing or maintenance without the risk of unexpected energization or release of stored energy. The Appendix states this plainly as the objective for minimum lockout procedures; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the overall standard at 1910.147.

All employees must follow the lockout restrictions; authorized employees must perform lockout according to the procedure, and all other employees must not attempt to start, energize, or use equipment that is locked out. Appendix A states these compliance expectations clearly; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the requirements in the main 1910.147.

The employer should identify who the affected employees are and how they will be notified (for example, by name, job title, verbal announcement, written notice, or a tag at the machine). Appendix A directs employers to document the name(s)/job title(s) of affected employees and the method of notification in the procedure; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the overall communication requirements in 1910.147.

An authorized employee must know the types and magnitudes of the machine's energy, the hazards those energies present, and the methods to control them. Appendix A requires the authorized employee to refer to the company procedure to identify energy sources and control methods; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the standard at 1910.147.

You should shut the machine down using the machine's normal stopping procedure (for example, depress the stop button, open the switch, or close the valve). Appendix A specifies using the normal stopping method as the required first shutdown step; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the main standard at 1910.147.

Energy isolating devices include items like switchgear disconnects, line valves, and circuit breakers; you must deactivate those devices so the machine is isolated from its energy sources. Appendix A asks employers to identify the types and locations of energy isolating devices in the procedure and instructs deactivation as the lockout step; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the full standard at 1910.147.

Yes — locks must be applied with assigned individual locks so each authorized employee controls removal of their own device. Appendix A instructs locking out devices with assigned individual locks, and the main standard requires an employee-applied lockout/tagout system; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and 1910.147.

You must dissipate or restrain all stored or residual energy (for example, bleed down hydraulic lines, discharge capacitors, block moving parts, or release spring tension) before work begins. Appendix A gives examples of stored energy (capacitors, springs, elevated members, hydraulic pressure, etc.) and methods to dissipate or restrain them; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the broader standard at 1910.147.

Verify isolation by first ensuring no personnel are exposed, then operate the normal operating control (push button, switch, etc.) or otherwise test the machine to make certain it will not operate; return controls to neutral or "off" after verification. Appendix A describes this sequence for verifying isolation; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and consult the requirements in 1910.147.

Before removing lockout devices and reenergizing equipment, check the machine and area to ensure tools and nonessential items are removed, ensure all employees are safely positioned or removed, verify controls are in neutral, then remove lockout devices and reenergize. Appendix A lists this exact restoring-to-service sequence; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the main standard at 1910.147.

You may temporarily remove lockout devices and reenergize only when it is necessary to test or position the equipment, and you must follow a strict sequence: clear tools/materials, remove employees from hazard area, remove lockout/tagout devices, energize and provide employee protection during testing, then deenergize and reapply lockout if more servicing is required. OSHA explains this temporary reenergization exception in the October 21, 2024 Letter of Interpretation and the requirements are reflected in 1910.147.

"Full employee protection" means the employer must provide the same level of safety that lockout would provide — such as equivalent physical restraints, procedural controls, or verified administrative controls — so employees are not exposed to hazardous energy. The requirement for full protection is stated in 1910.147(c)(3) and Appendix A explains that when tagout is used but devices are lockable, additional protections, training, and inspections are required; see Typical Minimal Lockout Procedure, Appendix A to 1910.147.

An authorized employee is trained and permitted to lock out or tag out machines to perform servicing; an affected employee is someone whose job requires operating or using the machine or who works in the area and must follow the lockout procedure (for example, not starting locked equipment). Appendix A expects procedures to name affected employees and refers to authorized employees doing the lockout; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the definitions and roles in the overall 1910.147.

Yes — Appendix A notes that when tagout is used (particularly where devices are not lockable) the employer must provide additional training and more rigorous periodic inspections compared with lockout programs. See Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the inspection and training provisions in 1910.147.

You should document the company or equipment name, purpose of the procedure, compliance statement, names/job titles of affected employees and notification methods, types and magnitudes of energy and controls, location of operating controls and energy isolating devices, types of stored energy and dissipation methods, and method of verifying isolation. Appendix A provides these fields as a template; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the broader 1910.147.

If removing a block or restraint requires reenergizing the machine, follow the Appendix A restoring sequence: ensure the area and employees are safe, reenergize under controlled conditions, remove the blocking, then deenergize and reapply lockout before continuing servicing. Appendix A specifically notes that removal of some blocking may require reenergization and gives the sequence to follow; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the main standard at 1910.147.

If there is no normal operating control to operate, verify isolation by other positive means that demonstrate the machine will not operate (for example, attempt to activate the energy source at its isolation point, measure absence of voltage, or use other test methods) after ensuring no personnel are exposed and then return controls to neutral if applicable. Appendix A allows testing to make certain equipment will not operate and instructs returning controls to neutral after verification; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and 1910.147.

Employees must not attempt to start locked-out equipment, and employers must enforce compliance and take appropriate corrective action for violations. Appendix A requires employees to comply with lockout restrictions and not to start locked equipment; see Typical Minimal Lockout Procedure, Appendix A to 1910.147 and the enforcement and program responsibilities described in 1910.147.