7 LOTO Violations OSHA Cites Most Often

Lockout/tagout violations landed at number four on OSHA's most cited standards list in fiscal year 2025, with 2,177 violations issued under 29 CFR 1910.147. That number is climbing in 2026 as the agency ramps up enforcement under Assistant Secretary David Keeling, who has made clear that OSHA will continue inspecting and issuing citations to employers who fall short of compliance.

If you run a manufacturing facility, the question is not whether OSHA will inspect your LOTO program. It is when. Here are the seven violations inspectors find most frequently, along with what you can do to fix each one before it becomes a five- or six-figure penalty.

1. Missing or Incomplete Written Procedures

The single most common violation is a failure to develop and document machine-specific energy control procedures. OSHA requires a written procedure for each piece of equipment that details the type and magnitude of energy, the location of isolating devices, and the specific steps to shut down, isolate, block, and verify the machine is de-energized.

Generic, one-size-fits-all procedures do not meet the standard. Every machine with more than one energy source or more than one employee performing maintenance needs its own documented procedure. Inspectors look for this first, and it is the fastest path to a citation.

Fix it: Conduct a machine-by-machine energy survey and build machine-specific LOTO placards that are posted at each piece of equipment. This eliminates guesswork and gives inspectors exactly what they are looking for.

2. Inadequate or Missing Employee Training

OSHA requires three categories of LOTO training: authorized employees (those who perform lockout), affected employees (those who operate machines being serviced), and other employees (those working in areas where lockout is used). Each group needs distinct training tailored to their role.

The violation is often not that training was never done. It is that the training was generic, outdated, or undocumented. OSHA wants records showing who was trained, when, by whom, and on which specific procedures. Facilities that rely on informal on-the-job training get cited consistently.

Fix it: Build a formal training matrix that covers all three employee categories. Document every session with sign-in sheets, the procedures covered, and the trainer's credentials. Retrain whenever a procedure changes or an employee transfers to a new role.

3. Skipping the Annual Periodic Inspection

Section 1910.147(c)(6) requires employers to conduct a periodic inspection of their energy control procedures at least once per year. The inspection must be performed by an authorized employee other than the one using the procedure, and it must cover each energy control procedure in use.

Many facilities have written procedures on file but zero documentation that anyone ever reviewed them. That gap is easy for an inspector to spot and it generates citations quickly. Alpha Baking Co. in Ohio learned this the hard way in 2025 when OSHA slapped them with $326,276 in proposed penalties after finding repeat LOTO failures, including inadequate program oversight.

Fix it: Schedule your annual LOTO audit now. Document which procedures were reviewed, who conducted the review, the date, and any corrective actions taken. Use a standardized checklist to ensure consistency.

4. Failure to Verify De-Energization

After applying lockout devices, authorized employees must attempt to restart the machine or test circuits to confirm that all energy sources have been effectively isolated. This verification step is one of the most commonly skipped steps in the field and one of the most frequently cited violations.

Workers often assume the machine is safe because the power switch is off. But stored energy in hydraulic systems, capacitors, springs, and pressurized lines can release unexpectedly. Skipping verification puts lives at risk and draws immediate OSHA attention.

Fix it: Build the verification step directly into your written procedures with specific instructions for each machine. Include what to test, how to test it, and what tools are required. Make verification a non-negotiable part of every lockout.

5. No Procedures for Group Lockout

When multiple employees perform maintenance on the same machine, each person must apply their own lock. The standard requires a clearly defined process for group lockout that ensures continuous protection for every worker throughout the service activity.

The violation usually occurs when facilities use a single lock for an entire crew or rely on a supervisor to lock out on behalf of everyone. Both approaches fail to provide individual protection, and OSHA cites them aggressively. Poor communication about lockout status between shifts compounds the problem.

Fix it: Implement a group lockout procedure that uses a lockbox or hasp system. Every authorized employee applies their own lock. Designate a primary authorized employee to coordinate the group lockout and ensure all energy sources remain isolated until the last person removes their lock.

6. Not Updating Procedures After Equipment Changes

Facilities add new equipment, retrofit existing machines, and change production processes regularly. When LOTO procedures are not updated to reflect those changes, they become inaccurate and dangerous. An inspector who compares your written procedure to the actual machine configuration will issue a citation if they do not match.

This is especially common in facilities that have added robotics, automated systems, or new interlock gates. The energy sources on a retrofitted line may be completely different from what the original procedure documented.

Fix it: Build a management-of-change process that triggers a LOTO procedure review every time equipment is modified, replaced, or added. A comprehensive LOTO gap analysis can identify where your current procedures no longer match your actual equipment.

7. Using Tagout Instead of Lockout Without Justification

OSHA's standard allows tagout as an alternative to lockout only when the employer can demonstrate that the tagout program provides a level of safety equivalent to lockout. That is a high bar. Tags alone do not physically prevent a machine from being energized, which means they provide a warning but not actual protection.

Facilities that use tags without locks, and without the required documentation proving equivalent safety, face serious citations. The penalty structure for this violation has increased significantly, with OSHA's maximum penalty for a serious violation now exceeding $16,000 per instance and repeat violations reaching over $160,000.

Fix it: Default to lockout on every piece of equipment. If tagout is the only option because the machine physically cannot accept a lock, document the justification thoroughly and implement the additional safety measures OSHA requires for tagout-only programs.

2026 Enforcement Is Not Slowing Down

OSHA's enforcement posture in 2026 is more aggressive than it has been in years. Recent cases like the Midwest bakery that drew $395,000 in proposed fines for safety violations, including LOTO failures, signal that the agency is pursuing larger penalties and treating repeat violations harshly.

The best defense is a proactive compliance program. Facilities that have current written procedures, documented training, annual audit records, and machine-specific placards posted at every piece of equipment rarely face significant LOTO citations. The ones that treat lockout/tagout as a paperwork exercise instead of an operational discipline are the ones writing large checks to OSHA.