Food Manufacturing LOTO Failures: What OSHA Fines Reveal

Food manufacturing facilities face some of the highest lockout/tagout violation rates of any industry sector. Recent OSHA enforcement actions totaling more than $1.5 million in proposed penalties show exactly why: sanitation processes, high-speed production lines, and complex processing equipment create hazardous energy exposures that many facilities fail to control properly under 29 CFR 1910.147.

If your facility processes, packages, or manufactures food products, these cases should serve as a direct warning. The violations cited are not edge cases. They are the same gaps that exist in thousands of food plants across the country right now.

$1.1M Fine After Worker Fatality at Vegetable Processor

In late 2025, OSHA proposed $1,125,484 in penalties against Taylor Farms New Jersey Inc. after a worker was fatally injured while cleaning and sanitizing equipment at the company's Swedesboro facility. Inspectors found 16 safety violations, with the core issue being a complete failure to implement lockout/tagout procedures during sanitation activities.

The investigation revealed that the company had not established energy control procedures for the equipment involved, had not provided LOTO training to workers, and had no system in place to verify that hazardous energy was isolated before employees entered machine zones for cleaning.

OSHA also cited PL Solutions Group LLC, the on-site temporary staffing agency, for three serious violations totaling $33,100 for failing to implement or train workers on LOTO procedures. This is a critical detail: using contract labor does not transfer your LOTO obligations. The host employer and the staffing agency both carry responsibility.

Key takeaways from this case:

• Sanitation and cleaning activities require full lockout/tagout procedures, not just production changeovers
• Temporary and contract workers must receive the same LOTO training as permanent employees
• The absence of written energy control procedures for specific equipment is a citable violation on its own, even without an injury
• Host employers using staffing agencies must coordinate LOTO training and compliance

$395K in Penalties for Ohio Commercial Bakery

In December 2025, OSHA cited New Horizons Baking Company in Columbus, Ohio, for three repeat violations, nine serious violations, and one other-than-serious violation. Proposed penalties totaled $394,849.

The repeat violations are the most telling part of this case. The company was cited for failing to train workers on lockout/tagout procedures, failing to lock out and tag out machines during servicing, and failing to guard dangerous machines. "Repeat" means OSHA had previously cited the company for substantially similar violations within the past five years, and the company had not corrected the underlying problems.

For food manufacturers, this pattern is common. Initial citations often come with serious-level penalties in the $15,000-$16,550 range per violation. But when the same issues appear on a follow-up inspection, penalties escalate dramatically. Repeat violations can carry fines up to $165,514 each under current OSHA penalty structures.

What this case illustrates:

• OSHA tracks your citation history. Unresolved violations from prior inspections will be classified as repeat, with significantly higher penalties
• Bakery and food production equipment, including mixers, conveyors, slicers, and ovens, all require machine-specific LOTO procedures
• Training documentation matters. If you cannot prove employees were trained on current LOTO procedures, OSHA treats it as a training failure

Why Food Manufacturing Is a High-Risk Sector for LOTO Violations

Food processing facilities share several characteristics that make LOTO compliance especially challenging:

Sanitation cycles create unique exposure. Unlike most manufacturing environments where servicing happens during scheduled maintenance windows, food plants require daily or per-shift equipment cleaning. Workers interact with machines at close range during sanitation, often reaching into areas where moving parts, hydraulic systems, or electrical components remain energized. Without proper lockout procedures for these routine cleaning tasks, workers face caught-in and struck-by hazards every shift.

High turnover and contract labor. The food manufacturing sector has some of the highest employee turnover rates in industry. New hires and temporary workers frequently perform tasks involving hazardous energy without receiving adequate LOTO training. Under 29 CFR 1910.147(c)(7), employers must ensure all authorized and affected employees receive training on energy control procedures. This applies regardless of employment status.

Complex, multi-energy equipment. Industrial food processing lines often involve multiple energy sources on a single machine: electrical, pneumatic, hydraulic, thermal, and gravitational. A commercial bread oven, for example, may have electrical heating elements, gas supply lines, pneumatic conveyors, and motorized belts. Each energy source requires identification and isolation in the written LOTO procedure. Facilities that use generic or one-size-fits-all lockout procedures for different machines are not in compliance.

Production pressure overrides safety protocols. Fast turnaround times between production runs and sanitation cycles create pressure to skip or shortcut lockout procedures. When OSHA investigates a fatality or serious injury, they look at whether the company had procedures in place and whether those procedures were actually followed in practice. A binder full of LOTO procedures that employees do not use is almost as bad as having no procedures at all.

What a Compliant LOTO Program Looks Like in Food Manufacturing

Meeting OSHA's requirements under 1910.147 is not optional, and it is not as complicated as many facilities make it. A compliant program includes these core elements:

• Machine-specific written procedures for every piece of equipment with hazardous energy sources, including sanitation equipment, production lines, and utility systems
• Durable, standardized placards posted at each machine showing the exact lockout steps, energy sources, and isolation points specific to that equipment
• Initial and refresher training for all authorized employees (those who perform lockout), affected employees (those who work in areas where lockout is used), and other employees (those who work near lockout areas)
• Annual periodic inspections of each energy control procedure, conducted by an authorized employee other than the one who normally uses the procedure, with documentation of the inspection date, employees included, and the inspector's identity
• Contractor coordination ensuring that outside employers and staffing agencies understand and follow the host facility's energy control program
• Centralized documentation that is accessible, current, and audit-ready at all times

The most common gap in food manufacturing facilities is not a lack of awareness. It is the gap between having a program on paper and having a program that is implemented, maintained, and enforced on the floor every day.

How to Protect Your Facility Before OSHA Shows Up

OSHA does not need a complaint or an injury to inspect your facility. The agency conducts programmed inspections targeting high-hazard industries, and food manufacturing is consistently on that list. OSHA also released a Local Emphasis Program (LEP) specifically targeting food manufacturers, increasing the likelihood of inspections at processing facilities.

Steps you can take now to reduce your exposure:

• Audit your sanitation lockout procedures. Walk through every cleaning and sanitation task that involves contact with equipment. If there is no written LOTO procedure for that task, you have a gap that needs to be closed immediately.
• Review your placard program. Are your lockout placards machine-specific, durable, and posted at the point of use? Paper or laminated procedures stored in a binder do not meet the intent of the standard for point-of-use accessibility.
• Verify training records. Can you produce documentation showing that every authorized and affected employee has been trained on current LOTO procedures? If an employee was trained two years ago on a procedure that has since changed, that training is no longer valid.
• Conduct your annual periodic inspection. Under 1910.147(c)(6), this inspection must happen at least annually for each energy control procedure. Many facilities skip this requirement or perform it inconsistently. It is one of the most commonly cited violations in the standard.
• Address contract labor. If you use temporary workers from staffing agencies, document how LOTO training is coordinated between the host employer and the staffing provider. Both parties are liable.

The Cost of Non-Compliance vs. the Cost of Getting It Right

The math is straightforward. A single serious LOTO violation carries a maximum penalty of $16,550. A willful or repeat violation can reach $165,514. In the Taylor Farms case, 16 violations resulted in over $1.1 million in proposed fines, not counting the human cost of a worker's death, the legal liability, and the reputational damage.

A comprehensive LOTO gap analysis, placard program, and annual audit system costs a fraction of a single OSHA citation. More importantly, it protects the people who walk onto your production floor every day.