The 6 Steps of Lockout/Tagout Under OSHA 1910.147

Published July 30, 2026 by LOTO Compliance

Ask ten maintenance workers to describe a lockout and most will name the lock. The lock is one step out of six, and it is not even the one that keeps people alive. What keeps people alive is the sequence around it: knowing the energy before you start, isolating every source, bleeding down what is stored, and then testing that the machine is actually dead. OSHA wrote that sequence into 29 CFR 1910.147(d), the application-of-controls section, and it is the backbone of every compliant energy control procedure.

This guide walks the six steps in order, in plain language, then covers the release-from-lockout sequence in 1910.147(e) that restores the machine when the work is done. If your authorized employees can recite these six and demonstrate them on the hardware they actually service, most of your program is already sound.

What 1910.147(d) Actually Requires

The standard breaks the establishment of lockout or tagout into a numbered sequence at 1910.147(d)(1) through (d)(6). It is written as a procedure, not a checklist to skim, and the order is deliberate. You cannot lock a device you have not isolated, and you cannot trust an isolation you have not verified. Every one of the six exists because a real incident showed what happens when it is skipped.

One point up front: these six steps are the application of controls. They bring a running machine down to a safe, locked, zero-energy state so servicing can start. They are the front half of a lockout. The back half, restoring the machine, is a separate sequence in 1910.147(e), and we cover it below. Confusing the two is a common source of gaps.

The Six Steps, in Order

Step 1: Preparation for Shutdown

Before anything is switched off, the authorized employee identifies the type and magnitude of the energy the machine holds, the hazards that energy presents, and the methods to control it. Electrical, hydraulic, pneumatic, mechanical, thermal, gravity, chemical: a single machine often has several. This is a knowledge step, and it is where a machine-specific procedure earns its keep, because it lists the sources so nothing is discovered the hard way. Get this wrong and every step after it is aimed at the wrong target.

Step 2: Machine or Equipment Shutdown

The machine is shut down by its normal stopping procedure, in an orderly way. That means using the stop button, the operational controls, or the documented shutdown routine, not yanking a disconnect on a machine under load. An orderly shutdown avoids the additional hazards that an abrupt stop can create, like a sudden release of stored energy or damage that leaves the equipment in an unpredictable state. Calm and by-the-book beats fast.

Step 3: Machine or Equipment Isolation

Now the energy isolating devices are operated to isolate the machine from every energy source identified in step one. This is the physical break: opening the disconnect, closing the block valve, disconnecting the line, discharging to a safe state. The word every matters. A machine fed by a 480-volt disconnect and a pneumatic supply is not isolated until both are addressed. Isolation is about the device that breaks the energy path, which is why the electrical disconnect gets so much attention, but it is never electrical alone.

Step 4: Application of Lockout or Tagout Devices

With the energy isolated, the authorized employee affixes a lockout or tagout device to each energy isolating device. Lockout devices hold the isolating device in the safe or off position and are the primary method under the standard. The devices themselves have to be durable, standardized, and substantial, and identify who applied them, a set of requirements we break down in lockout/tagout device requirements. Where a lock cannot hold a device by itself, a tagout device may be used, but only under the stricter conditions we cover in tagout-only systems. The lock is the visible symbol of a lockout, but on its own it protects no one. The five steps around it do.

Step 5: Control of Stored Energy

Isolating a machine from its source does not empty it. Hydraulic accumulators hold pressure, capacitors hold a charge, springs stay compressed, a raised ram holds gravity, flywheels keep spinning, and lines can hold trapped air or fluid. Step five requires that all potentially hazardous stored or residual energy be relieved, disconnected, restrained, or otherwise rendered safe. If stored energy can re-accumulate, verification has to continue until the servicing is done or the hazard no longer exists. This is the step that kills when skipped, and we go deep on it in stored energy isolation.

Step 6: Verification of Isolation

The final step before work begins is proof. The authorized employee verifies that isolation and de-energization have actually been accomplished. In practice that is a try-out: confirm no one is exposed, then operate the normal operating controls or otherwise test to make sure the equipment will not start, and return the controls to the off or neutral position afterward. Push the button. If the machine stays dead, the lockout worked. If it starts, something in steps one through five was wrong, and you just found it safely instead of with a hand in the machine. Verification is the step that turns an assumption into a fact.

Release From Lockout: The Other Sequence

When the servicing is finished, the machine has to come back to life just as deliberately as it went down. 1910.147(e) sets that sequence, and it is not simply the reverse of application. Before any device comes off, three things happen. First, the work area is inspected to confirm nonessential items are removed and the machine is intact and assembled. Second, the work area is checked to ensure all employees are safely positioned or clear, and affected employees are notified that the lockout is being removed before the machine is started. Third, each lockout or tagout device is removed by the authorized employee who applied it.

That last rule is firm: your lock, your removal. The only path around it is the narrow, documented exception for when the authorized employee is absent from the facility, which carries its own verification and notification requirements. We cover exactly how that works in removing a lockout device when the authorized employee is absent. Skipping the area inspection or the employee-clear check is how a restart injures someone during what everyone assumed was the safe part of the job.

Where the Sequence Breaks Down

Most citations do not come from a facility that has never heard of lockout. They come from a sequence that is real but incomplete. The patterns repeat:

• Isolating one source, not all of them. The electrical disconnect gets locked and the pneumatic or hydraulic supply is forgotten. Step three says every source.
• Skipping stored energy. The disconnect is off, the lock is on, and a charged accumulator or a raised platen still holds enough energy to injure. Step five is the one workers rush.
• No verification. The lock is treated as proof. Nobody pushes the button to confirm the machine is dead. Step six is skipped precisely because it feels redundant, right up until it is not.
• No written procedure to sequence it. The steps live in individual habits instead of a documented, machine-specific procedure, so they are performed differently by different people. This is why a machine-specific energy control procedure exists: to fix the order for each machine so it is done the same way every time.

The through-line is that lockout is a sequence, not an object. A program audited only for locks on a wall will miss the steps that actually protect people. A program audited against all six, plus the release sequence, holds up when an inspector walks the floor and asks an authorized employee to demonstrate.

Frequently Asked Questions

What are the six steps of lockout/tagout?

The six steps in OSHA 1910.147(d) are preparation for shutdown, machine shutdown, machine isolation, application of lockout or tagout devices, control of stored energy, and verification of isolation. They run in order, from knowing the energy before you touch anything to proving the machine is at a zero-energy state before work begins.

What is the last step of a lockout procedure?

Verification of isolation is the last step before servicing begins. The authorized employee confirms the machine is fully de-energized, ensures no one is exposed, and operates the normal start controls to test that the machine will not start, then returns those controls to off. It is the step that proves the first five worked.

What does verification of isolation mean under 1910.147(d)(6)?

It means the authorized employee verifies, before starting work, that isolation and de-energization have actually been accomplished. In practice that is a try-out: confirm no personnel are exposed, operate the normal operating controls to test that the equipment will not start, and return the controls to the neutral or off position. A locked disconnect is an assumption until you test it.

What is the difference between lockout application and release from lockout?

Application is the six-step sequence in 1910.147(d) that brings a machine to a safe, locked, zero-energy state before work. Release from lockout is the sequence in 1910.147(e) that restores the machine afterward: inspect the work area, clear and warn employees, then remove the devices. One takes the energy away, the other gives it back safely.

Who is allowed to remove a lockout device?

Each lockout or tagout device is removed by the authorized employee who applied it. That is the general rule in 1910.147(e)(3). The only exception is a specific, documented procedure for when that employee is absent from the facility, which requires verifying they are gone, making a reasonable effort to reach them, and informing them before their next shift.

Does OSHA require the six steps in a specific order?

Yes, the order matters. You cannot apply a lock before you isolate, and you cannot verify before you control stored energy. 1910.147(d) lists the sequence deliberately: prepare, shut down, isolate, lock, control stored energy, verify. A machine-specific energy control procedure documents that order for each machine so it is followed the same way every time.