Machine-specific energy control procedures based on OSHA 29 CFR 1910.147
| Requirement | Cite | What it means in practice |
|---|---|---|
| Written, machine-specific procedures | (c)(4)(ii) | State intended use; shutdown, isolation and blocking steps; how devices are placed, removed and transferred; how you verify effectiveness |
| Devices used only for energy control | (c)(5)(ii) | Locks and tags are singularly identified and never double as tool locks or ID tags |
| Standardized devices | (c)(5)(ii) | At least one of color, shape, or size is consistent across the facility (tags: also print/format) |
| Durable and substantial | (c)(5)(ii) | Withstand the environment; locks resist removal without force, tag attachments one-piece, self-locking, 50-lb minimum unlocking strength |
| Identifiable | (c)(5)(ii) | Every device shows who applied it |
| Notify affected employees | (c)(9) | Before controls go on and again before they come off |
| Six-step application sequence | (d)(1)–(d)(6) | Prepare, shut down, isolate, apply devices, release stored energy, verify |
| Removal only by the applier | (e)(3) | Exception requires a documented equivalent-protection procedure when the employee is off-site |
| Group lockout | (f)(3) | A primary authorized employee controls the group lockout; each worker still adds a personal lock |
| Shift or personnel changes | (f)(4) | Orderly transfer of lockout protection between outgoing and incoming crews |
| Outside contractors | (f)(2) | Employers inform each other of their respective lockout procedures |
| Periodic inspection | (c)(6) | At least annually, by an authorized employee who doesn't use that procedure; certified with machine, date, employees, inspector |
| Training | (c)(7) | Authorized employees (detailed), affected employees (basics), all others (awareness) |
Name the machine, then check every energy source it carries — electrical, pneumatic, hydraulic, stored mechanical, gravity, thermal, chemical. Each source gets a line for the actual isolation device (the disconnect, the valve, the clamp), and those flow straight into the generated procedure: an energy control table, the six-step shutdown sequence from 1910.147(d) customized with your machine name and devices, stored-energy release steps per source, the verification step, and the restart sequence from paragraph (e).
Walk the machine with the manuals before filling this in — the two classic mistakes are missing an energy source (the 24V control circuit fed from a different panel) and naming a device that doesn't actually isolate (a start button is not an isolating device). Print the procedure, laminate it, and hang it at the machine; the annual inspection cert block at the bottom is what your auditor will date.
The default example — a CNC mill with electrical, pneumatic, and hydraulic sources checked — generates a 3-row energy table and a 9-step shutdown section: five base steps (prepare, notify affected employees, shut down, isolate, apply devices) plus one stored-energy line per source — bleed the air line, release hydraulic pressure and block the actuator, discharge the capacitor bank per the manual — and the verification step that attempts a start before hands go in. The restart section adds four paragraph (e) checks — inspect the work area, confirm employees are clear, notify affected employees, remove locks — for a two-page procedure that fits on one sheet front and back. Check all seven energy sources and the shutdown section grows to 13 steps.
OSHA's 1910.147(d) lays them out in order: (1) prepare for shutdown by identifying every energy source and its magnitude; (2) shut the machine down by its normal stop procedure; (3) isolate it from the energy source using disconnects, valves, or blocks; (4) apply your lockout or tagout devices to those isolation points; (5) release or restrain any stored or residual energy — bleed air, discharge capacitors, block suspended parts; and (6) verify the isolation is real before work starts, typically by attempting a normal start and returning the control to off.
1910.147(c)(4) requires documented procedures for the control of potentially hazardous energy, but it allows exceptions where a machine has a single energy source that is completely de-energized by one lockout device, is isolated during service, and shares no residual energy risk — in those cases a single procedure can cover a group of machines. Most real equipment collects several energy types, so in practice machine-specific procedures are the default.
At least annually, per 1910.147(c)(6)(i). The inspection is done by an authorized employee who does not use the procedure being reviewed; it verifies the steps are still accurate, employees still follow them, and each authorized employee knows their responsibilities. The employer must certify it — machine, date, employees included, and the inspector.
Under 1910.147(e)(3), each device is removed by the employee who applied it. The only exception is when that worker has left the site: the employer may direct removal only under a documented procedure that verifies the employee is gone, made reasonable efforts to reach them, and confirms they know the lock came off before they return to work.
Only when a lock can't physically be applied — and then the tag has to give full employee protection per 1910.147(c)(3): attached at the same point a lock would go, with the means to hold it there, plus extra measures like removing an isolating-circuit fuse or blocking a valve. Tags are warning devices, not restraints, and the standard treats the difference seriously: a tag can be removed by anyone, a lock can't.