Building a compliant lockout/tagout (LOTO) program takes six clear steps: write a formal energy-control program, develop machine-specific procedures, select standardised devices, train your people, apply the isolation steps consistently, and inspect the program every year. This guide walks through each one.
Step 1 — Write the energy-control program
Start with a documented policy that defines scope, responsibilities, and the rules everyone follows. It should name who is authorised to apply locks, describe the device standard, and set out the inspection and training requirements. This is the backbone OSHA 1910.147 requires. See our OSHA 1910.147 guide.
Step 2 — Develop machine-specific procedures
For each piece of equipment, write a procedure that lists every energy source, its isolation point, and the exact steps to shut down, isolate, lock, release stored energy, and verify. Photos and laminated procedure cards kept at the machine make these easy to follow.
Step 3 — Select and standardise your devices
Choose one consistent device standard across the facility so locks are instantly recognisable. A typical program uses:
- Safety padlocks — keyed-different, one per authorised worker.
- Hasps for points that need multiple locks.
- Device-specific lockouts for valves, cables, and breakers.
- LOTO stations and shadow boards to keep devices organised at the point of use.
A ready-made LOTO kit is an easy way to equip each authorised worker.
Step 4 — Train your employees
OSHA defines three roles. Authorised employees perform LOTO and must be trained in the full procedure. Affected employees operate the equipment and must recognise when LOTO is in effect. Other employees in the area need awareness training. Retrain whenever procedures or assignments change.
Step 5 — Apply the isolation steps consistently
Every shutdown follows the same sequence: prepare, shut down, isolate, lock and tag, release stored energy, and verify zero energy before work begins. Our guide on what lockout/tagout is covers these six steps in detail.
Step 6 — Inspect the program every year
OSHA requires a periodic inspection at least annually, performed by an authorised employee who does not use the procedure being reviewed. Document findings, correct any deviations, and update procedures as equipment changes.
Common mistakes to avoid
- Generic, one-size-fits-all procedures instead of machine-specific ones.
- Using master-keyed or shared padlocks (prohibited — one lock, one key, one worker).
- Skipping the verification step before starting work.
- No annual inspection or training records.
We can help you build it
As the authorised distributor of LOTO Safety Products in Uzbekistan, we supply the full device range and offer a free on-site LOTO assessment — we walk your facility, identify energy sources and isolation points, and recommend the exact devices and procedures you need. Contact our team to book an assessment.