Testing or Positioning Machines Under OSHA 1910.147(f)(1): The Temporary Removal Sequence

Published August 10, 2026

Almost every serious energy control program handles the straightforward jobs well. Shut the machine down, isolate it, lock it, verify it, do the work. The place programs quietly break down is the moment a technician needs the machine to move. A servo has to be jogged to a home position. A clutch has to be cycled to confirm the repair took. An alignment cannot be checked with the drive dead. That moment is governed by 29 CFR 1910.147(f)(1), and it is one of the least-read paragraphs in the standard.

It is also where people get hurt. The energy is live, the guards are often off, and the crew is impatient because the job is nearly done. This is a walkthrough of what (f)(1) actually requires, why the order matters, and how to write it into a procedure so the shop floor follows it when nobody from EHS is watching.

What (f)(1) Covers, and What It Does Not

The paragraph is titled "Testing or positioning of machines, equipment or components thereof." It applies in situations where lockout or tagout devices "must be temporarily removed from the energy isolating device and the machine or equipment energized to test or position the machine, equipment or component thereof." Two words carry the weight. Must, meaning there is no way to accomplish the check with the machine isolated. And temporarily, meaning the energized state ends and the locked-out state comes back.

What (f)(1) does not do is create a category of live maintenance. It does not let a technician keep a hand near a pinch point while a coworker bumps the drive. It does not let the crew leave locks off "for the rest of the shift because we will be testing on and off." And it is not the same thing as the minor servicing exception in the note to (a)(2)(ii), which is about routine, repetitive, integral production tasks and never involves removing a lock in the first place. If your program is using (f)(1) language to justify ongoing work on a live machine, the paragraph is being read backwards.

The distinction that matters is exposure. During the test window, nobody is servicing. Everyone is clear. The machine runs. Then it comes back down and the servicing resumes under a full application of energy control.

The Five Steps, in Order

The standard spells the sequence out in five sub-paragraphs, and each one points back to another part of the rule rather than restating it. That cross-referencing is easy to miss when the paragraph is read on its own.

Step five is the one people shorten. Paragraph (d) is not a suggestion to put the lock back on. It is preparation for shutdown, orderly shutdown, isolation, device application, stored energy control, and verification of isolation under (d)(6). All of it, again. If you want the full walkthrough of that sequence, we covered it in the six steps of lockout/tagout.

Why the Order Is Not Negotiable

Read the sequence as a set of gates and the logic becomes obvious. Tools come out before people leave, because a wrench left on a conveyor becomes a projectile the moment the drive turns and because you cannot inspect the work area properly once everyone has walked away. People leave before locks come off, because the lock is the last physical barrier and it should be the last thing to go. Locks come off before energization, because energizing against an applied lockout device is either impossible or it means the isolation was never real.

Reversing any two of those creates a specific, predictable injury. Energizing before clearing means loose parts get thrown. Removing devices before clearing the area means the machine can be started by someone at the panel who does not know a technician is still inside the guard. This is exactly the scenario that (e)(2)(ii) and (c)(9) are written to prevent, and it is why notification of affected employees is not paperwork.

Step five gets reversed constantly in a subtler way. The crew tests, the test looks good, and then someone reaches in to adjust "just one thing" while the machine is still energized because the drive is right there and the fix takes ten seconds. Nothing in (f)(1) permits that. The paragraph gives you an energized test window and then closes it.

Where Inspectors Find Problems

The violations that come out of testing and positioning tend to look like these.

• Jogging with devices still applied. If a machine can be bumped while a lockout device is on the energy isolating device, either the device is on the wrong point or a control circuit is being used as an isolation point. Push buttons and selector switches are explicitly not energy isolating devices under the definitions in paragraph (b).
• No documented test step. Paragraph (c)(4)(ii)(D) requires the procedure to include specific requirements for testing equipment to determine and verify the effectiveness of energy control measures. Many written procedures cover shutdown and isolation in detail and then say nothing about how a test is conducted or who authorizes it.
• Stored energy skipped on re-application. Reapplying under paragraph (d) includes (d)(5), and after a test run there is often more stored energy present than there was the first time. Accumulators recharge, capacitors recharge, and elevated components can be left in a raised position. We covered the failure modes in stored energy isolation.
• Group jobs treated as one lock. On a group lockout, the test cannot start until every group member has cleared personal devices from the lockbox, because (f)(1)(iii) routes through (e)(3) and each member's device is theirs alone. The mechanics are in our guide to group lockout/tagout procedures.
• Devices removed by the wrong person. Convenience removal during testing is still removal by someone other than the applier, which lands under the (e)(3) exception and its documented-procedure requirement. We wrote that one up in removing a lockout device when the authorized employee is absent.

Writing (f)(1) Into a Machine-Specific Procedure

The best defense here is a procedure that treats testing as a named step rather than an improvisation. When we build or review a machine-specific energy control procedure, the testing block gets its own section with four things in it.

1. The trigger. A plain statement of what conditions require an energized test on this machine, written specifically enough that a technician can tell whether it applies. "Verify servo home position after gearbox replacement" is a trigger. "As needed" is not.
2. The clearing checklist. The (e)(1) inspection made concrete for this equipment: which access doors, which guards go back on, which tools live inside the cell, which components must be reassembled before power returns.
3. Roles during the energized window. Who calls the test, who stands at the control station, who confirms the area is clear, and where each person physically stands. One person controls energization. That person does not also have hands in the machine.
4. The re-application step. An explicit instruction to return to the full paragraph (d) sequence, with the machine's own stored energy items and verification points listed again rather than referenced in passing.

If the procedure was written without this section, it is worth adding rather than assuming the crew will infer it. The format we recommend is covered in how to write a machine-specific energy control procedure, and OSHA's own non-mandatory Appendix A gives a baseline structure to work from.

Practical Controls That Hold Up on the Floor

Procedures fail quietly. A few controls tend to survive contact with a busy maintenance shop.

Give the test a verbal script. Something as short as "tools out, people out, locks off, my hand on the button, energizing in three" gives the crew a shared cue and makes the sequence audible to anyone nearby. Crews that say it out loud skip steps less often than crews that carry it in their heads.

Keep the test window physically bounded. A test that requires guards open should have a defined standing position outside the guard line, marked on the floor if the cell is large. If the machine has a maintenance or jog mode with reduced speed and hold-to-run control, use it, and document that the mode does not substitute for the (f)(1) sequence around it.

Re-verify after every test, not just the first time. Paragraph (d)(6) verification is the step that catches an isolation point someone reopened during the test. It takes seconds and it is the last thing standing between a technician and a live drive.

Finally, count how often testing actually happens. If the periodic inspection under (c)(6) never observes a test, and the machines in question clearly require testing, the inspection is not sampling the risky part of the job. That gap shows up in the citation data we track on our OSHA LOTO violations page.

Frequently Asked Questions

Does OSHA allow you to remove a lock to test a machine?

Yes, but only under the sequence in 1910.147(f)(1). The machine has to be cleared of tools and materials, employees have to be removed from the area, and only then may the devices come off. After the test, all systems are de-energized and full energy control is reapplied under paragraph (d) before servicing resumes.

What are the five steps of 1910.147(f)(1)?

Clear the machine of tools and materials per (e)(1). Remove employees from the machine area per (e)(2). Remove the lockout or tagout devices as specified in (e)(3). Energize and proceed with testing or positioning. De-energize all systems and reapply energy control measures per paragraph (d) to continue the work.

Can a machine stay energized while someone finishes the repair?

No. Paragraph (f)(1)(v) requires that the machine be de-energized and the full application sequence in paragraph (d) be repeated before servicing continues. Testing is a brief, controlled interruption of the locked-out state. It is not permission to work on a live machine.

Who removes the lock during a test?

Removal follows 1910.147(e)(3), which requires that each device be removed by the employee who applied it. The exception in (e)(3) for an absent authorized employee is a separate documented procedure, not a shortcut for routine testing. On a group job, every member has to clear the lockbox first.

Do affected employees need to be notified before a test?

Yes. Paragraph (e)(2)(ii) requires that affected employees be notified after devices are removed and before the machine is started, and (c)(9) requires notification on both application and removal. Operators and anyone working nearby need to know the machine is about to move.

Does the energy control procedure have to mention testing?

It should. Paragraph (c)(4)(ii)(C) requires specific steps for placement, removal, and transfer of devices, and (c)(4)(ii)(D) requires specific requirements for testing equipment to verify that energy control measures worked. A procedure that never addresses testing leaves the most dangerous step undocumented.