OSHA lockout/tagout training requirements

Who needs the training

Paragraph (c)(7)(i) of 29 CFR 1910.147 sets different training for three groups of people. What you owe each group depends on how their work relates to the machines being serviced.

• Authorized employees: people who lock out or tag out machines or equipment to do servicing or maintenance. An affected employee becomes an authorized employee when their duties include that servicing or maintenance.
• Affected employees: people whose job requires them to operate or use a machine on which servicing or maintenance is done under lockout or tagout, or to work in an area where that servicing happens. Machine operators are the usual example.
• Other employees: everyone else whose work operations are or may be in an area where energy control procedures may be used. The standard does not give this group a definition in paragraph (b), only the training duty in (c)(7)(i)(C).

What each group must be taught

The training must make sure employees understand the purpose and function of the energy control program and acquire the knowledge and skills for the safe application, usage and removal of energy controls. By group:

1. Authorized employees, (c)(7)(i)(A): recognition of applicable hazardous energy sources, the type and magnitude of energy in the workplace, and the methods and means necessary for energy isolation and control.
2. Affected employees, (c)(7)(i)(B): they must be instructed in the purpose and use of the energy control procedure.
3. Other employees, (c)(7)(i)(C): they must be instructed about the procedure, and about the prohibition on attempts to restart or reenergise machines or equipment that are locked out or tagged out.

If you use tags, paragraph (c)(7)(ii) adds training on their limitations. Employees must learn that:

1. Tags are warning devices and do not give the physical restraint that a lock does
2. A tag is not removed without authorisation from the authorized person responsible for it, and is never bypassed, ignored or defeated
3. Tags must be legible and understandable to all authorized, affected and other employees in the area
4. Tags and their attachment must withstand the environment where they are used
5. Tags may create a false sense of security, so their meaning must be understood as part of the energy control program
6. Tags must be attached securely so they cannot be detached by accident

How often: retraining and inspections

The standard does not set a fixed annual retraining cycle. Retraining under (c)(7)(iii) is triggered by events. It applies to all authorized and affected employees whenever:

• Their job assignment changes
• A change in machines, equipment or processes presents a new hazard
• The energy control procedures change
• A periodic inspection reveals, or the employer has reason to believe, that there are deviations from or inadequacies in an employee's knowledge or use of the procedures

Retraining must reestablish employee proficiency and introduce new or revised control methods and procedures as necessary. Many employers add a yearly refresher as good practice, but that is a choice, not a rule in the standard.

Do not confuse this with the periodic inspection in (c)(6). The employer must inspect each energy control procedure at least annually, using an authorized employee who does not use that procedure. Where lockout is used, the inspection includes a review with each authorized employee of their responsibilities. Where tagout is used, it also includes a review with each affected employee, covering the tag limitations in (c)(7)(ii). The inspection must be certified with the equipment, the date, the employees included and the inspector.

How it can be delivered

The text of (c)(7) does not say whether training may be online, live or hands-on. The test is the outcome: employees must understand the program and acquire the knowledge and skills the paragraph describes.

For affected and other employees the content is awareness: what the procedure is for, how it works for them, and the rule never to restart locked or tagged equipment. A short course with workplace-specific details (who the authorized employees are, what your locks and tags look like) can deliver this.

For authorized employees the standard calls for skills, not only awareness. OSHA has said in an interpretation letter that each authorized employee must be able to safely perform the work required in any energy control procedure they may be asked to use. Plan machine-specific, practical training for them. A general awareness course does not replace it.

Our template is the awareness training for affected and other employees. It does not replace procedure training for authorized employees.

Who can deliver it

The standard does not name a qualification for the trainer. Because authorized employees must learn your own energy control procedures, the person training them should know those procedures and the machines they cover. A named LOTO coordinator or the authorized employees themselves can brief affected and other employees on the local details.

What records to keep

Under (c)(7)(iv) the employer must certify that employee training has been accomplished and is being kept up to date. The certification must contain each employee's name and dates of training.

The standard does not state how long to keep the certification. Keep the periodic inspection certifications from (c)(6)(ii) alongside them.

Where the standard does not apply

Two exceptions matter for training scope. Minor tool changes and adjustments and other minor servicing during normal production are outside the standard if they are routine, repetitive and integral to using the equipment for production, and effective alternative measures protect the worker. Work on cord and plug connected electric equipment is also outside it when unplugging the equipment controls the hazard and the plug stays under the exclusive control of the person servicing it. Check each task against the exact wording before you leave it out of your program.

Sources

• 29 CFR 1910.147, The control of hazardous energy (lockout/tagout)
• 29 CFR 1910.147 on eCFR
• OSHA directive STD 01-05-019, Inspection procedures and interpretive guidance
• OSHA interpretation, 20 June 1996