The 6 Lockout Tagout Steps, in Order
The order matters more than most people realise. 1910.147(d) does not present six things to do, it presents six things to do “in the following sequence,” and every one of the LOTO incidents I have looked at involved a sequence that got compressed. Locks applied before the energy was isolated. Work started before anyone verified. Stored energy bled after the guard came off instead of before.
So this page walks the six steps in the order OSHA sets them, with the paragraph reference for each one, plus the two things that are not steps and get treated like they are: releasing the locks at the end, and re-energising in the middle to test your work. If you would rather your crew saw it demonstrated, our Lockout Tagout Training Program covers the whole sequence, and there are free lockout tagout training videos as well.
Quick Answer: What Is the First Step in a Lockout Tagout Procedure?
Preparation for shutdown. Before anyone turns the machine off, OSHA 1910.147(d)(1) requires the authorized employee to know the type and magnitude of the energy involved, the hazards that energy presents, and the method or means to control it. Not the lock, not the switch. Knowing what you are about to isolate.
Search this and you will be told four steps, five, seven, eight, even ten. All of those are somebody’s training material. OSHA 1910.147(d) sets out six elements and requires them “in the following sequence.”
Use six. Your written procedure and your training should match the document a compliance officer will be holding.
| # | Step | What the standard actually requires | What gets missed | Citation |
|---|---|---|---|---|
| 1 | Preparation for shutdown | The authorized employee must know the type and magnitude of the energy, the hazards it presents, and the method or means to control it. | Treating this as paperwork. It is a knowledge requirement, and it applies before anyone touches the machine. | 1910.147(d)(1) |
| 2 | Machine or equipment shutdown | Shut down using the procedures established for that machine. An orderly shutdown is required to avoid creating a new or increased hazard. | Hitting the E-stop and calling it a shutdown. Some processes create a worse hazard if stopped abruptly. | 1910.147(d)(2) |
| 3 | Machine or equipment isolation | All energy isolating devices needed to control the energy must be physically located and operated so the machine is isolated from its energy sources. | Finding one disconnect and stopping. “All” means every source, and most machines have several. | 1910.147(d)(3) |
| 4 | Lockout or tagout device application | Devices affixed to each isolating device by authorized employees, holding it in the safe or off position. | One lock for a crew. Each authorized employee applies their own. | 1910.147(d)(4) |
| 5 | Stored energy relief | After the devices are on, all potentially hazardous stored or residual energy must be relieved, disconnected, restrained, or otherwise rendered safe. | Accumulators, capacitors, springs and raised loads. If energy can reaccumulate, verification continues until the work is done. | 1910.147(d)(5) |
| 6 | Verification of isolation | Before starting work, the authorized employee must verify that isolation and de-energization have actually been accomplished. | Skipping the try-out. This is the step that catches the breaker you locked that fed nothing. | 1910.147(d)(6) |
Removing the locks is a separate procedure, not step seven. Release from lockout or tagout is governed by 1910.147(e), and each device is removed by the employee who applied it.
What OSHA Requires Before You Start: The Energy Control Program
The six steps do not exist on their own. 1910.147(c)(1) requires the employer to establish an energy control program made up of three things: energy control procedures, employee training, and periodic inspections. The steps below are what the procedure part looks like in practice.
And the procedure has to be written. 1910.147(c)(4)(i) requires procedures to be developed, documented and used. There is an exception in the note to that paragraph, but it only applies when all eight of its conditions are met, including no potential for stored or residual energy, a single readily identifiable energy source, a single lockout device achieving the locked-out condition, and no accidents involving unexpected activation during servicing. Most machines fail at least one. If yours is borderline, write the procedure.
One more thing before step one. 1910.147(c)(9) requires affected employees to be notified before the devices are applied and again after they are removed. Two notifications. People remember the first and forget the second, and the second is the one that stops an operator walking up to a machine they believe is still locked out.
Step 1: Preparation for Shutdown
1910.147(d)(1) is short and it is worth reading exactly: before an authorized or affected employee turns off a machine, the authorized employee shall have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy.
Three things, and all three are knowledge, not action. Type: is it electrical, hydraulic, pneumatic, thermal, chemical, mechanical, or gravity, and usually it is several at once. Magnitude: 480 volts is a different problem from 24, and 3,000 psi in an accumulator is a different problem from shop air. Method: which energy isolating device controls each of those, and where is it.
In practice this step is your machine-specific procedure. If someone has already walked the machine and written down that hydraulic power comes from the pump skid disconnect at panel P-4, the air comes from the valve on the north wall, and there is an accumulator that has to be bled at the pump, then step one takes ninety seconds. If nobody has, step one is the longest step you will do that day, and it should be, because everything after it depends on the list being complete.
What step one is not is a troubleshooting pass. You are not looking for the fault yet. You are cataloguing the energy that could hurt you while you look for the fault.
Step 2: Machine or Equipment Shutdown
1910.147(d)(2) requires the machine to be turned off or shut down using the procedures established for that machine, and it adds a condition people skip: an orderly shutdown must be used to avoid any additional or increased hazard to employees as a result of the equipment stopping.
That second half is not filler. Slamming an E-stop on a loaded conveyor can pile product up. Killing a furnace fan can leave heat with nowhere to go. Cutting power to a pump mid-cycle can leave a line pressurised in a place your procedure did not anticipate. Whatever the normal shutdown sequence is for that machine, use it. The emergency stop is for emergencies.
This is also the point where 1910.147(c)(9) kicks in for the first notification. Affected employees, meaning the operator and anyone working in the area, get told before the devices go on. Not as a courtesy. Because the person who runs that machine every day is the one most likely to walk over and try to start it.
Step 3: Machine or Equipment Isolation
1910.147(d)(3): all energy isolating devices that are needed to control the energy to the machine or equipment shall be physically located and operated in such a manner as to isolate hazardous energy from the energy sources.
Two words carry the weight. All, and physically.
All, because the single most common failure in this step is finding one disconnect and stopping. A press has electrical, hydraulic, pneumatic and gravity. A packaging line has drives, air, and product in a heated tunnel. Every source needs its own isolating device operated, and step one is where you found out how many there were.
Physically, because an energy isolating device is defined in 1910.147(b) as a mechanical device that physically prevents the transmission or release of energy. The standard names them: a manually operated circuit breaker, a disconnect switch, a manually operated switch that disconnects all ungrounded supply conductors, a line valve, a block, and similar devices. And it excludes the ones people reach for: push buttons, selector switches and other control circuit type devices are not energy isolating devices. A stop button asks the machine to stop. A disconnect stops the energy arriving.
Note the order. You are operating the isolating devices here, at step three. The locks do not go on until step four, because you cannot hold a device in the safe position until it is in the safe position.
Step 4: Lockout or Tagout Device Application
1910.147(d)(4)(i) requires lockout or tagout devices to be affixed to each energy isolating device by authorized employees. (d)(4)(ii) requires lockout devices to be affixed in a manner that will hold the isolating device in a safe or off position. (d)(4)(iii) requires tagout devices to be affixed so as to clearly indicate that operating or moving the isolating device from the safe or off position is prohibited.
Each device. If step three had you operating four isolating devices, step four has you applying four locks, and if there are three of you working on the machine, that is each of you on each point, or a hasp, or a group lock box. Our full lock out tag out equipment list covers which device fits which isolation point.
The rule about who owns the lock lives in 1910.147(c)(8): lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance. Your lock, your key, your hands in the machine. Not a supervisor applying it on your behalf, and not borrowing a colleague’s lock because yours is in the truck.
If a tag has to be used instead of a lock, 1910.147(d)(4)(iii)(A) requires the tag attachment to be fastened at the same point the lock would have gone. Where a tag cannot be attached directly to the isolating device, (d)(4)(iii)(B) requires it to be located as close as safely possible and positioned so it is immediately obvious to anyone attempting to operate the device. And remember that under 1910.147(c)(2)(ii), if the device is capable of being locked out, tagging it instead is only available where you can demonstrate equivalent protection.
Step 5: Stored Energy Relief
1910.147(d)(5)(i): following the application of lockout or tagout devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, or otherwise rendered safe.
Note where this sits. After the locks go on, not before. The isolating device is locked, and now you deal with what is already trapped on your side of it.
The four verbs are the four options. Relieved: bleed the hydraulic line, dump the air receiver, let the steam out. Disconnected: pull the leads on a capacitor bank. Restrained: block the raised ram, pin the blade, chock the wheel. Rendered safe by other means: let a flywheel coast to a stop, wait out the DC bus discharge on a variable frequency drive, let a hot surface cool.
Restrained is the one that matters most and gets the least attention. No amount of bleeding a hydraulic circuit holds up a platen. Gravity does not care that the pump is locked out. Put something solid under it.
Then there is 1910.147(d)(5)(ii), which almost nobody quotes: if there is a possibility of reaccumulation of stored energy to a hazardous level, verification of isolation shall be continued until the servicing or maintenance is completed, or until the possibility no longer exists. That is a live obligation for the length of the job, not a one-time check. Steam systems, gas that migrates back through a leaking valve, a hydraulic accumulator with a slow recharge: on those machines you keep watching.
Step 6: Verification of Isolation
1910.147(d)(6): prior to starting work on machines or equipment that have been locked out or tagged out, the authorized employee shall verify that isolation and de-energization of the machine or equipment have been accomplished.
Verify. Not assume, not review the checklist. Prove it, physically, for each energy source.
In the field this step is called the try-out, which is where the acronym LOTOTO comes from: lock out, tag out, try out. What the try-out looks like depends on the energy. Press the start button with everyone clear and the guards in place, and confirm nothing moves. Meter the conductors at the point you will be working, not at the panel. Crack a bleed valve and watch the gauge. Try to move the blocked component by hand.
The failure this step exists to catch is the one that gets people killed while doing everything else right: you locked out a breaker that turned out not to feed the circuit you are working on. Mislabelled panels are everywhere. I have found them in plants with immaculate written programs. The only thing that catches a mislabelled panel is testing at the point of work.
One caution on metering. Test your meter on a known live source before and after you use it to prove a circuit dead. A meter that has quietly failed reads zero on everything, and zero is exactly what you are hoping to see.
Releasing the Locks: Why This Is Not Step 7
This is worth being clear about, because it is where the “seven steps” and “eight steps” counts online usually come from. Release from lockout or tagout is not the seventh element of 1910.147(d). It is its own paragraph, 1910.147(e), with its own requirements. The application sequence has six elements. Removing the devices is a separate procedure.
Before the devices come off and energy is restored, 1910.147(e) requires three things:
- 1910.147(e)(1). The work area is inspected to ensure nonessential items have been removed and that machine components are operationally intact. Tools out, guards back on, panels closed.
- 1910.147(e)(2)(i). The work area is checked to ensure all employees have been safely positioned or removed.
- 1910.147(e)(2)(ii). After the devices have been removed and before the machine is started, affected employees are notified that the devices are off. This is the second half of the 1910.147(c)(9) notification pair, and it is the one that gets forgotten.
Then 1910.147(e)(3): each lockout or tagout device shall be removed from each energy isolating device by the employee who applied it.
There is an exception and it is deliberately narrow. Where the authorized employee who applied the device is not available to remove it, the device may be removed under the direction of the employer, but only if specific procedures and training for that removal have been developed, documented and incorporated into the energy control program, and the employer can demonstrate the procedure provides equivalent safety. The procedure has to include verifying that the employee is not at the facility, making all reasonable efforts to contact them to tell them their device has been removed, and ensuring they know before they resume work there.
Read that last element again, because it is the part everyone drops. The worker has to know their lock was cut before they come back and start working on that machine. A bolt cutter and a shrug is not the exception. It is a citation.
What If You Have to Re-Energise to Test Your Work?
You almost always do. 1910.147(f)(1) gives a five-action sequence for temporarily removing the devices so the machine can be energised for testing or positioning:
- Clear the machine or equipment of tools and materials, per (f)(1)(i)
- Remove employees from the machine or equipment area, per (f)(1)(ii)
- Remove the lockout or tagout devices, per (f)(1)(iii)
- Energise and proceed with testing or positioning, per (f)(1)(iv)
- De-energise all systems and reapply energy control measures in accordance with paragraph (d) to continue the work, per (f)(1)(v)
Step five is the one that gets short-cut, and it is the whole point. You do not resume where you left off. You go back through all six elements of 1910.147(d) again. Preparation, shutdown, isolation, devices, stored energy, verification. Every time.
I know how that sounds on a job where you are cycling the machine four times to dial something in. The honest answer is that if you are testing repeatedly, the sequence is short each time because step one is already done and written down. It is the plants without a machine-specific procedure where this becomes unbearable, and that is an argument for writing the procedure, not for skipping the reapplication.
What Happens at Shift Change?
1910.147(f)(4) requires specific procedures during shift or personnel changes to ensure continuity of lockout or tagout protection, including provision for the orderly transfer of device protection between off-going and oncoming employees.
Orderly transfer means there is never a moment when the isolation point is unlocked. The oncoming crew’s locks go on before the off-going crew’s locks come off. If the job runs across three shifts, that overlap happens twice, and it happens at the machine, not in the office.
Where I see this break down is on jobs that were supposed to finish in one shift and did not. Nobody planned the handover, the day crew went home, and the isolation is now held by locks belonging to people who left the site. That is exactly the situation the 1910.147(e)(3) exception was written for, and exactly the situation you do not want to be relying on it in.
Who Has to Be Trained on These Steps?
1910.147(c)(7)(i)(A) is the one that applies to the six steps directly: each authorized employee gets training in recognising applicable hazardous energy sources, the type and magnitude of energy available in the workplace, and the methods and means necessary for energy isolation and control. That is steps one, three and five, in training form.
Affected employees get instructed in the purpose and use of the procedure under (c)(7)(i)(B), and everyone else who works where energy control procedures may be used gets instructed about the procedure and about the prohibition on attempting to restart or re-energise anything locked or tagged out, under (c)(7)(i)(C).
Retraining is triggered rather than scheduled. 1910.147(c)(7)(iii)(A) requires it whenever there is a change in job assignment, a change in machines, equipment or processes that presents a new hazard, or a change in the energy control procedures. (c)(7)(iii)(B) adds retraining whenever a periodic inspection reveals, or the employer has reason to believe there are, deviations or inadequacies in an employee’s knowledge or use of the procedures.
And 1910.147(c)(7)(iv) requires the employer to certify that training has been done and is up to date, with each employee’s name and training dates. If you need material to run that training with, our Lockout Tagout PowerPoint walks the six steps in about fifteen minutes.
The Bottom Line
Six steps, in the order OSHA sets them, every time. Preparation for shutdown, machine shutdown, isolation, device application, stored energy relief, verification. Then a separate procedure to release, and a full reapplication of all six if you re-energise to test.
If you take one habit from this page, take the machine-specific procedure. Every step above gets faster and more reliable when someone has already walked the machine and written down where the energy comes from and which device controls it. Without that list, step one is guesswork and step three is incomplete, and no amount of care further down the sequence fixes an isolation point nobody knew about.
If you need a short version to run with a crew on the floor, our Lockout Tagout Toolbox Talk covers the same sequence in talk form.
Frequently Asked Questions About Lockout Tagout Steps:
Preparation for shutdown. Under OSHA 1910.147(d)(1), before the machine is turned off the authorized employee must have knowledge of the type and magnitude of the energy involved, the hazards of the energy to be controlled, and the method or means to control it. It is a knowledge requirement rather than a physical action, and everything after it depends on the energy inventory being complete.
Six. OSHA 1910.147(d) lists six elements and requires them in the stated sequence: preparation for shutdown, machine or equipment shutdown, machine or equipment isolation, lockout or tagout device application, stored energy relief, and verification of isolation. Other counts come from training materials that either split a step or fold in the release procedure, which OSHA treats separately under 1910.147(e).
The last of the six application steps is verification of isolation under 1910.147(d)(6), where the authorized employee physically confirms that isolation and de-energization have actually been accomplished before work begins. Releasing the locks afterwards is not step seven. It is a separate procedure under 1910.147(e), with its own requirements for inspecting the area, positioning employees, and notifying affected employees before the machine is started.
Lock out, tag out, try out. It is industry shorthand rather than an OSHA term, and the try out refers to the verification required by 1910.147(d)(6). The point of the phrasing is that verification is not optional and not a paperwork review. It is a physical test at the point of work, which is the only thing that catches a mislabelled panel or a breaker that does not feed the circuit you are about to touch.
Yes. OSHA 1910.147(f)(1) sets out the sequence for temporarily removing devices to test or reposition equipment, and its final action requires you to de-energise all systems and reapply energy control measures in accordance with paragraph (d) before continuing the work. That means all six steps again, not resuming from where you stopped.
