LOTO Compliance

Removing a Lockout Device When the Authorized Employee Is Absent: OSHA 1910.147(e)(3)

Published June 25, 2026 by LOTO Compliance

Quick answer: Removing a lockout device 1910.147 normally requires the employee who applied it to remove it. The lone exception, 1910.147(e)(3), lets the employer remove an absent employee's device only after verifying that employee has left the facility, making all reasonable efforts to contact them, and ensuring they know the device is gone before they resume work. It requires a specific written procedure and documentation.

The default rule in lockout is one of the cleanest in the standard. The authorized employee who put the lock on takes the lock off. 1910.147(e)(3) says each lockout or tagout device shall be removed from each energy isolating device by the employee who applied it. That single-owner rule is the whole point of a personal lock. It guarantees that the person whose body was exposed to the hazard is the person who decides the machine is safe to re-energize. Break that link and the lock stops protecting anyone.

So what happens when the lock is still on the disconnect at 6 a.m., the machine is needed for first shift, and the maintenance tech who applied it left at 11 p.m. and is not answering the phone? The standard anticipated exactly that. It built one exception, and it built it narrow on purpose. This guide walks through how 1910.147(e)(3) actually works, who is allowed to remove the device, the three conditions the employer has to clear, the documentation an auditor expects, and the convenience-removal habit that turns a safe shop into an enforcement case.

The Default Rule and Why It Exists

Under 1910.147(e)(3), removal is personal. The device comes off by the hand that put it on. This is not bureaucracy. It is the engineering control that makes a personal lock meaningful. When a worker climbs inside a press or reaches into a conveyor nip point, their own lock on the disconnect is the physical guarantee that no one re-energizes the machine while they are exposed. If a supervisor could pull that lock, the guarantee evaporates.

The standard reinforces this everywhere. The lock has to be standardized, durable, and identify the individual who applied it under 1910.147(c)(5)(ii). The whole accountability chain assumes a one-to-one match between a lock and a person. Removing a device the authorized employee left on is the single place where the standard allows another party to break that match, and it permits it only because there are real situations, an employee who drives home with the only key, a worker taken to the hospital mid-shift, where the applying employee genuinely cannot return to remove the device. ANSI Z244.1, the consensus standard behind much of 1910.147, takes the same position: personal lock removal by anyone other than the applier is an exception, controlled by procedure, never a routine convenience.

The 1910.147(e)(3) Exception: Three Conditions

The exception lives in a note to 1910.147(e)(3). It permits removal by the employer, not by a coworker and not by a shift lead acting on their own, and only when the employer follows a specific procedure that is documented in the energy control program. That procedure has to incorporate three elements, and all three are mandatory. Miss one and the removal is a violation, even if the machine was genuinely needed.

ConditionWhat the employer must doWhy it matters
Verify absenceConfirm that the authorized employee who applied the device is not at the facilityIf the employee is on site, they remove their own lock. The exception does not apply to someone on break or in the breakroom
Reasonable contactMake all reasonable efforts to contact the authorized employee to inform them the device is being removedThe applying employee may know the machine is mid-repair, partly disassembled, or otherwise unsafe to start
Knowledge before returnEnsure the authorized employee knows the device has been removed before they resume work at the facilityA worker who returns and assumes their lock is still protecting them will reach into a live machine

That third condition is the one people forget. Verification and contact happen on the day of the removal. The knowledge-before-return obligation reaches forward in time. If the tech who left at 11 p.m. comes back for second shift and walks straight to the machine believing their lock is still on the disconnect, the employer has failed 1910.147(e)(3) even though the removal itself was handled correctly. The procedure has to include a step that intercepts that employee at the start of their next shift and tells them their device was removed.

The Written Procedure Requirement

The exception is not self-executing. 1910.147(e)(3) only permits the removal when the employer has developed a specific procedure for it and the procedure is incorporated into the energy control program. OSHA also expects that procedure to be at least as safe as having the applying employee remove the device personally. That is a high bar, and it is why a real removal procedure reads like a controlled sequence rather than a permission slip.

A defensible written procedure names the following:

  1. The triggering condition. A device remains applied, the machine or area is needed, and the applying employee cannot be located on site.
  2. The responsible role. A named position, typically the EHS manager, plant manager, or a designated supervisor, who is the only person authorized to direct removal. Not whoever is closest to the panel.
  3. The absence verification step. How the facility confirms the employee has left, including a check of the time system, sign-out log, or direct confirmation from the shift lead.
  4. The contact attempt. The phone numbers tried, the times, and any message left, so reasonable effort is provable, not asserted.
  5. The pre-removal safety check. A qualified person inspects the machine to confirm it is reassembled, that no one is exposed, and that re-energization is safe. The applying employee's absence does not waive zero-energy verification.
  6. The removal and notification record. Who removed the device, when, and how the employer will inform the applying employee before they resume work.

This procedure sits inside the broader machine-specific framework. If your facility has not yet documented its energy control procedures to the level 1910.147(c)(4) requires, the absent-employee removal step has nothing to attach to. Our guide on the machine-specific energy control procedure covers that foundation, and the absent-employee removal language belongs in the same program document.

Who Can Remove the Device

Only the employer, through the named role in the written procedure, can authorize removing another person's lock. This matters because the most common real-world failure is a coworker deciding on their own that the machine is needed and the absent worker "won't mind." That is not a permitted removal. It is an unauthorized one, and it carries the full weight of the standard's enforcement.

The distinction between authorized and affected employees runs straight through this rule. The person directing the removal must understand the energy control program, the specific machine, and the verification steps. An affected employee who merely operates the machine has no authority to remove a lock and no training to confirm the machine is safe. If you are unclear on where those roles divide, our breakdown of authorized versus affected employees draws the line the standard expects you to hold.

Group jobs add another layer. When several workers lock onto a single lockbox, the absence of one of them does not let anyone clear the box. The group lockout procedure carries its own accountability rules for a missing member, and they sit alongside, not instead of, the 1910.147(e)(3) requirements. Our piece on group lockout/tagout procedures covers how the lockbox sequence handles a worker who has left without clearing their personal lock.

The Convenience Removal Trap

Convenience removal is the habit that the entire exception exists to prevent, and it is where shops get people killed. It looks like this. A lock is on the disconnect. The worker who applied it is on lunch, ran to the parts store, or clocked out twenty minutes early. The line is down, the schedule is slipping, and a supervisor or a coworker cuts the lock off so production can keep moving. No absence verification. No contact attempt. No pre-removal safety check. The machine starts.

Every element of 1910.147(e)(3) is skipped, and the worst-case version of this is not theoretical. If the applying employee was inside the machine when the lock was cut, or returns to a machine they believe is locked out, the result is amputation or death. OSHA treats convenience removal as one of the gravest lockout failures precisely because it defeats the personal lock at the exact moment it is supposed to work.

There is a cultural tell that gap analysis surfaces fast. Ask a maintenance crew what they do when a lock is left on and the owner is gone. If the honest answer is "we cut it" rather than "we call the EHS manager and run the procedure," the program has a 1910.147(e)(3) hole regardless of what the binder says. Bolt cutters in the toolbox near the lockout station are a quiet sign that convenience removal is the real procedure. This is the same enforcement pressure we tracked in the contractor lockout coordination context, where a second crew on the floor multiplies the chances a lock gets pulled by the wrong person.

Employer Documentation

The standard requires the procedure to exist in the energy control program. Sound practice requires you to document each removal event, because an undocumented removal is indistinguishable from convenience removal when an inspector or an attorney looks back at it. Keep a removal record that captures the following for every instance.

FieldWhat it records
Device and locationThe machine, the energy isolating device, and the lock identifier removed
Applying employeeThe name of the authorized employee who applied the device
Absence verificationHow and when the facility confirmed the employee had left the site
Contact attemptsNumbers called, times, and outcomes, demonstrating reasonable effort
Safety checkThe qualified person who confirmed re-energization was safe
Removal authorizationThe named role who directed removal and the date and time
Return notificationHow and when the applying employee was informed before resuming work

This record does two things. It proves compliance if the removal is ever questioned, and it creates a paper trail that surfaces patterns. A facility removing absent-employee locks twice a week does not have an attendance problem. It has a lock-accountability problem, and the record is what lets the EHS team see it.

How This Ties Into a Program Audit

The annual periodic inspection under 1910.147(c)(6) reviews the energy control procedures in use and the authorized employees who run them. A thorough LOTO program audit checks the absent-employee removal procedure as a specific line item. The reviewer confirms the procedure exists, names a responsible role, includes all three statutory conditions, and that any removal events on record were documented to the field list above.

Gaps here are rarely isolated. A missing removal procedure usually travels with weak lock standardization, undocumented periodic inspections, and authorized-employee training that never covered the exception. ECPL's gap analysis pulls the removal procedure, walks the floor for bolt cutters and shared locks, and interviews the maintenance crew about what actually happens when a lock is left on. That field check, not the binder, is what tells you whether 1910.147(e)(3) is a written rule or a lived one. The findings feed the same program management we run through LockStep, where each removal event and periodic inspection is logged and tracked rather than left in a drawer.

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ECPL audits your energy control program against 1910.147, including the absent-employee removal procedure and lock accountability across the floor. Chicago, Detroit, Indianapolis, national travel.

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Frequently Asked Questions

Can an employer remove a lockout device the authorized employee left on?

Yes, but only under the narrow 1910.147(e)(3) exception and only when that employee is not available to remove it themselves. The employer must follow a specific written procedure, verify the employee is not at the facility, make all reasonable efforts to contact them, and ensure the employee knows the device was removed before they resume work at the facility.

What are the conditions for removing an absent employee's lockout device?

1910.147(e)(3) names three. First, verify that the authorized employee who applied the device is not at the facility. Second, make all reasonable efforts to contact that employee and inform them the device will be removed. Third, ensure the employee knows the device has been removed before they resume work at the facility. All three must be documented in the energy control program.

Who is allowed to remove another employee's lockout device?

Only the employer, acting through the specific procedure required by 1910.147(e)(3), and only after verifying the applying employee is unavailable. A coworker cannot cut a lock off because the shift needs the machine. The removal is an employer-authorized act with documentation, not a floor-level decision, and it has to be assigned to a named role in the written program.

Does OSHA require a written procedure to remove an absent employee's lock?

Yes. 1910.147(e)(3) only permits the removal when the employer has a specific procedure in the energy control program and that procedure is at least as safe as the employee removing the device personally. The procedure must include the three verification and notification elements and the documentation the employer keeps for each removal event.

What is convenience removal and why is it a citation risk?

Convenience removal is cutting or bypassing a lock because the worker who applied it is on break, off shift, or simply not nearby, without verifying they have left the facility or attempting contact. It skips every condition in 1910.147(e)(3), strips the lock's protection, and is one of the most dangerous and most cited lockout failures because it can re-energize a machine while someone is still inside it.

How does lockout removal tie into a LOTO program audit?

The annual periodic inspection under 1910.147(c)(6) reviews the energy control procedures in use, and a compliant program audit confirms the absent-employee removal procedure exists, names a responsible role, and has documentation for any removal that occurred. Missing or undocumented removal events are a finding, and they often signal deeper gaps in lock accountability across the floor.

About LOTO Compliance: We are the lockout/tagout division of Equipment Compliance Placards Ltd (ECPL), serving manufacturers nationwide from Chicago, Detroit, and Indianapolis. ECPL builds OSHA 1910.147 programs from the ground up: gap analysis, machine-specific energy control procedures, authorized and affected employee training, annual periodic inspections, and LockStep software for ongoing program management. Phone 847-232-6067.