Centers for Disease Control

and Prevention

National Institute for Occupational 

Safety and Health

Conducting a Periodic Inspection for 

Each Procedure in a Hazardous Energy 

Control (Lockout/Tagout) Program 

procedures. An authorized employee is 

defined in 29 CFR 1910.147(b) as a person who locks out or tags out machines 

or equipment in order to perform servicing or maintenance on that machine 

or equipment. The lockout and tagout 

procedures for each piece of equipment 

must be accurate and followed, in proper sequence, to prevent severe injury 

and death. 

Summary

Employers are required by 29 CFR* § 

1910.147(c)(6) to conduct a periodic 

inspection of written hazardous energy control (lockout/tagout) procedures. 

The inspection must be performed at 

least once annually [per 12-month interval, as stated in 1910.147(c)(6)(i)] 

because of the significant risks associated with inadequate energy control 

procedures or the failure to properly 

implement them [OSHA 2008].

In accordance with the Occupational Safety and Health Administration 

(OSHA) standard, the National Institute for Occupational Safety and 

Health (NIOSH) recommends best 

*

Code of Federal Regulations. See CFR in 

References.

practices for conducting an annual periodic inspection of each energy control procedure, as part of an energy 

control (lockout/tagout) program.

Legal requirements are established in 

29 CFR § 1910.147 and their enforcement is described in the OSHA document The Control of Hazardous 

Energy—Enforcement Policy and Inspection Procedures. OSHA Instruction 

Directive No. CPL 02‒00‒147 [OSHA 

2008]. However, compliance with the 

regulations is based solely on the CFR. 

No wording in this document, national 

standards, the directive or other document supersedes the requirements in 

the CFR.

Introduction

A required component of an effective energy control program [29 CFR 

1910.147(c)(1)] is an annual periodic inspection for each piece of equipment requiring lockout and tagout†

†

OSHA standards require the use of either 

lockout or tagout. However, NIOSH [1999] 

procedures in the work environment. The 

periodic inspection process evaluates the 

adequacy of the procedures and the ability 

of the authorized employee to follow the 

recommends that any hazardous control program include both lockout and tagout to 

ensure maximum protection. Also note that 

some state plans may have more stringent 

requirements that those found in 29 CFR 

1910.147.

All equipment installed, replaced, or 

having had a major repair, renovation, 

or modification after January 2, 1990, 

must be designed to accept a lockout device. In accordance with 29 CFR 

1910.147(c)(3)(i) and (ii), tagout devices 

can only be used as energy isolating device 

on equipment that is capable of being 

locked out if the employer can demonstrate that a level of safety is achieved in 

the tagout program which is equivalent 

to the level of safety obtained by using 

a lockout program. As a best practice, 

NIOSH recommends the application 

of a lockout device and a tag with the 

identity of the authorized employee 

performing the work. 

Hazardous energy releases can occur 

during the installation, maintenance, 

service, unexpected start up, or repair 

of machinery and equipment. Common 
Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tageout) Program

2

examples of stored energy sources include electrical, mechanical, hydraulic, gravity, steam, pneumatic, chemical, 

thermal, and gas. Workers are at risk of severe injury and 

death during equipment or machine maintenance and servicing if proper lockout/tagout procedures are not accurate 

or not followed [NIOSH 1999]. 

NIOSH previously recommended developing and implementing a hazardous energy control program including lockout 

and tagout procedures and worker training to prevent such incidents [NIOSH 1999, 2011]. This document recommends 

best practices for carrying out the annual periodic inspection 

as specified in 29 CFR 1910.147(c)(6)(i) through (ii).

Description of Exposure

In the United States, three million workers are at risk of serious injury or death if hazardous energy control procedures 

(lockout/tagout) are not properly executed [OSHA n.d.]. 

Workers may experience serious injury or death from the 

unexpected startup or release of equipment/machinery containing stored energy. 

From 2018 to 2020, more than 160 injuries and fatalities involving lockout and tagout of hazardous energy sources were 

reported in the OSHA Information System database.‡

 These 

‡

Fatality and Catastrophe Investigation Summaries, (OSHA 170 form), are 

developed after OSHA conducts an inspection in response to a fatality or 

incidents involved electrocutions, amputations, entanglement, crushing between machine parts, and being struck by 

objects while employees were servicing machines or clearing 

jams [OSHA n.d.; 29 CFR 1910.147(a)(2)]. 

Case Study 1 

In cooperation with the NIOSH Fatality Assessment and 

Control Evaluation (FACE§

) Program, the Oregon Health & 

Science University [Oregon State FACE¶Program 2019] investigated a fatality in which a technician was training a new 

employee to perform routine preventive and/or scheduled 

maintenance on a vertical storage machine. A roller used to 

support a carrier tray fell out, and the technician could not 

reinstall it from outside the machine. A carrier tray was removed to provide space for him to enter the unit. The technician climbed inside to lie on another carrier below the 

removed carrier. As the trainee cycled the machine to put 

the technician in a position to access and reinstall the roller, the machine malfunctioned. The technician asked the 

trainee to make another input to the controls. The machine 

advanced the technician over the top of the vertical storage unit, which had very limited space. The technician was 

crushed and killed. 

From the investigation, contributing factors to the incident 

included (1) failure to apply lockout and tagout procedures, 

(2) inadequate knowledge of safer methods to perform the

work (i.e., options to rotate carriers without power), and (3)

inadequate training and communication regarding specific

job hazards [Oregon State FACE Program 2019].

Investigators recommended the following: 

 Periodic inspections of lockout/tagout procedures at least

annually 29 CFR 1910.147(c)(6)

 Following lockout/tagout procedures to reduce the risk of

hazardous movement of machines (29 CFR 1910.147)

catastrophe. The summaries provide a complete description of the incident, generally including events leading to the incident and causal factors. These summaries can be easily searched by keyword, text in the 

summary description, event date, and industry (SIC). Information may 

also be obtained for specific investigation(s), (Insp Nr). Summaries currently available include completed investigations from 1984 through 1 

year earlier than today's date. Summaries for later dates are not included to provide time for OSHA staff to complete the investigation and revise the summary as necessary. Furthermore, summaries must undergo 

a process for screening personal information and adding keywords that 

may cause some additional delay in posting [OSHA n.d.]. §

Investigations conducted through the FACE program allow the identification of factors that contribute to fatal injuries at work. This information is used to develop comprehensive recommendations for preventing similar deaths [NIOSH 2021].

¶Oregon has an OSHA State Plan. State Plan regulations must be at least 

as effective as Federal OSHA’s (29 CFR 1910.147 for lockout/tagout), but 

they are codified according to the state’s legislative practices. Oregon 

OSHA’s lockout/tagout regulation is Rule Number 437–002–2303. 

Employers should check with their regulator for details if they are in a 

State-Plan state.
Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tageout) Program

3

 Routine assessment of job hazards and employees’ 

knowledge of control hazards (29 CFR 1910.147)

 Regular, periodic training and communications related 

to on site-specific hazards (such as potential sources of 

hazardous energy release) and safe work practices

Case Study 2

In cooperation with the NIOSH FACE Program, the California Department of Public Health [CA FACE** 2016] investigated a fatality in which a foreman was crushed between 

moving parts of a baling machine while he was clearing 

debris out of the machine.††

Portions of the machine’s moving parts, including the magazine area, were enclosed by a six-foot metal enclosure with 

access gates. The access gates were equipped with an interlock sensor so that the machine would shut off when the 

gates were opened. The hay baler was installed at the company by the manufacturer. The hay baler operator controlled 

the machine at a computerized panel. A bale of hay was automatically loaded onto the hay baler, to be resized. The 

bales were compressed, tied, weighed, and removed for storage and shipment. A magazine kicker arm moved the hay 

bale to an area for pickup after it had been compressed and 

tied. The baling machine used electrical and hydraulic energy to operate (a multi-energy source piece of equipment).

Before the incident, the victim told the machine operator 

that he was going to clean the baler with compressed air. 

The victim likely entered the magazine area through the access gate. It is not known whether the victim disabled the interlock sensor so the machine would not shut off when he 

opened the gate. The machine operator stated that he was 

at the control panel at the time of the incident; he was not 

aware that the victim was in the magazine area. A forklift 

operator noticed the victim in the magazine area between 

the kicker arm and the magazine frame. The kicker arm was 

manually operated to release the victim. The machine did 

not shut down at the time of the incident. The victim was 

transported to a hospital where he died from his injuries.

The company had not developed or implemented a written 

hazardous energy control program including specific procedures for locking out equipment to include the hay bal-

**California has an OSHA State Plan. State Plan regulations must be at 

least as effective as Federal OSHA’s (29 CFR 1910.147 for lockout/tagout or 29 CFR 1928.57 Guarding of farm field equipment, farmstead 

equipment, and cotton gins), but they are codified according to the 

state’s legislative practices. Cal OSHA’s lockout/tagout regulation is Title 8 § 3314. Employers should check with their regulator for details if 

they are in a State-Plan state. ††29 CFR 1910.147 doesn’t specifically apply to agriculture or construction, 

but this case study is included here as an example of (1) equipment with 

multiple sources of energy and (2) the need for hazardous energy control procedures that demonstrate good safety practices.

ing machine. Specific written procedural steps for shutting 

down, isolating, blocking, and securing machines or equipment to control hazardous energy are required for equipment that has multiple sources of energy. The California 

FACE investigator recommended developing and implementing a comprehensive hazardous energy control program including lockout/tagout procedures and training 

[CA FACE 2016].

Recommendations for Best 

Practices in Implementation

The periodic inspection is an audit/evaluation that 

provides a vital measure for worker safety by ensuring 

that proper lockout and tagout sequence is performed 

on each specific piece of equipment and that the written procedure is accurate. The following are best practices for implementing the legal requirement for an 

annual inspection.

General Information

 At a minimum, the periodic inspection process must contain two components: 

— an inspection of each energy control procedure and 

— a review of each authorized employee’s responsibilities under the energy control procedure being 

inspected [OSHA 2008].

 The goal of the periodic inspection is to

— verify that the procedures are adequate by ensuring that all energy sources are identified and controlled, de-energized, or otherwise made safe,

— verify that the procedures are being properly 

applied,

— ensure that the employees involved are familiar 

with their responsibilities, 

— ensure that the employees maintain proficiency in 

the energy control procedures that they are (individually) responsible for [OSHA 2008], and

— identify inaccuracies and deficiencies to correct 

them.

 The periodic inspection process will ascertain whether

— the steps in the written procedures are being 

followed, 

— the employees know how to follow the written procedures, and 

— the written procedures provide the necessary 

protections [OSHA 2008]
Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tageout) Program

4

 Energy control procedures used less frequently than once 

annually (per 12-month interval) must be inspected only 

when used [OSHA 2008].

Inspection

 The annual periodic inspection may be achieved through 

planned visual observations, random audits, or plant safety 

tours [OSHA 2008].

 A periodic inspection must include a demonstration 

of the procedures and must be performed while the authorized employee performs service/maintenance on 

machine/equipment [OSHA 2008]. 

 Each energy control procedure must be separately inspected to ensure that the procedure is adequate and 

is properly implemented by the authorized employee 

[OSHA 2008].

 Employers must certify that the inspections were performed. The certification must specify the following 

[OSHA 2008]: 

— The machine/equipment on which the energy control 

procedure was used 

— The date of the inspection 

— The name(s) of the employee(s) included in the 

periodic inspection

— The name(s) of the inspector(s). 

Equipment that Requires Written 

Procedures

 As outlined in 29 CFR § 1910.147, procedures shall be developed, documented, and used for the control of hazardous energy when ANY of the following elements exist: 

— The machine or equipment has the potential for 

stored or residual energy or re-accumulation of 

stored energy after shutdown. 

— The machine or equipment has a single energy 

source that is not readily identifiable or capable of 

being isolated. (Example: An electrical knife switch 

disconnect, that is not labeled and is located away 

from the equipment in a motor [mechanical] control center room or other location, would not be 

readily identifiable.)

— The isolation and locking out of that energy source 

does not completely deenergize and deactivate the 

machine or equipment. 

— The machine or equipment is not isolated from that 

energy source and is not locked out during servicing 

or maintenance. 

— A single lockout device will not achieve a lockedout condition. 

— The lockout device is not under the exclusive control of the authorized employee performing the servicing or maintenance. 

— The servicing or maintenance creates hazards for 

other employees. 

— The employer has had an incident involving the 

unexpected activation or re-energization of the 

machine or equipment during servicing or maintenance.

Written Energy Control Procedures

 Written energy control procedures should contain elements 

such as

— the scope of the procedures, 

— the intended purpose, 

— the names of authorized personnel, 

— rules for shift change, transfer of locks, etc., and 

— specific methods used to control hazardous energy.

Grouping Equipment

 An employer can group equipment-specific lockout/

tagout procedures into one procedure to comply with the 

standard [OSHA 2008]. 

 If equipment is categorized into the same group, the 

equipment/machinery must have a similar type, energy 

source, or energy control measures [OSHA 2008]. 

 A grouping of individual procedures would be considered 

one procedure for periodic inspection purposes [OSHA 

2008].

 If there are variations in the type, energy source, or energy 

control methods, it is recommended that specific, individualized procedures be developed [OSHA 2008]. 

 The employer should verify that the energy control 

procedure has not changed in a manner that is no longer 

covered by the group procedure.

Inspector/Authorized Employee

 The inspector must be a lockout/tagout-authorized employee who is knowledgeable and is NOT currently performing lockout/tagout on the energy control procedure 

actively being inspected. The inspector cannot implement 

any part of the procedure during the inspection. 

 The inspector must observe the implementation of the 

energy control (lockout/tagout) procedure for the equipment/machine being evaluated and talk with at least one 

authorized employee who is implementing the procedure, to ensure the employee understands the procedure 

[OSHA 2008]. 
Conducting a Periodic Inspection for Each Procedure in a Hazardous Energy Control (Lockout/Tageout) Program

5

 The inspector can either observe a representative number 

of employees implementing the procedure on the equipment or talk with all other authorized employees who implement the procedure, even though they may not be 

observed implementing the procedure.‡‡ 

Training

 If the periodic inspection process reveals deviations from 

the written procedures or inadequacies in an employee’s 

knowledge of the procedures, the employee must be 

retrained [OSHA 2008]. 

 Adequate and thorough retraining must be conducted to 

expand the employee’s knowledge of the procedures and 

to ensure the employee is capable of fully implementing 

the procedures in the appropriate sequence.

Acknowledgments

This document was prepared by Sarah Hughes, Division of 

Science Integration (DSI); Jeffrey Funke, Division of Safety 

Research; and Susan Afanuh (DSI), NIOSH.

Suggested Citation

NIOSH [2021]. Conducting a periodic inspection for each 

procedure in a hazardous energy control (lockout/tagout) 

program. By Hughes S, Funke J, Afanuh S. Cincinnati, OH: 

U.S. Department of Health and Human Services, Centers for 

Disease Control and Prevention, National Institute for Occupational Safety and Health, DHHS (NIOSH) Publication No. 

2022-106, https://doi.org/10.26616/NIOSHPUB2022106.

References

CA FACE [2016]. A foreman dies when he is crushed in a 

hay baling machine. Richmond, CA: California FACE Program, California Department of Public Health, Occupational Health Branch, Case Report 16CA002. FACE Program: 

California Case Report 16CA002 | NIOSH | CDC.

‡‡The OSHA [2008]. Compliance Directive indicates a representative number is typically defined as 25% of the LO/TO-authorized employees.

CFR. Code of Federal regulations. Washington, DC: U.S. 

Government Printing Office, Office of the Federal Register.

NIOSH [1999]. Preventing worker deaths from uncontrolled 

release of electrical, mechanical, and other types of hazardous energy. NIOSH Alert. Cincinnati, OH: U.S. Department of Health and Human Services, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and Health, https://www.cdc.gov/niosh/docs/99–

110/pdfs/99–110.pdf?id=10.26616/NIOSHPUB99110.

NIOSH [2011]. Using lockout and tagout procedures to prevent injury and death during machine maintenance. Workplace Solutions. Cincinnati, OH: U.S. Department of 

Health and Human Services, Centers for Disease Control 

and Prevention, National Institute for Occupational Safety and Health, https://www.cdc.gov/niosh/docs/wp–solutions/2011–156/pdfs/2011–156.pdf?id=10.26616/NIOSHPUB2011156.

NIOSH [2021]. Fatality Assessment and Control Evaluation (FACE) Program. Cincinnati, OH: U.S. Department of 

Health and Human Services, Centers for Disease Control 

and Prevention, National Institute for Occupational Safety 

and Health, https://www.cdc.gov/niosh/face/default.html.

Oregon State FACE Program [2019]. Maintenance mechanic 

crushed working inside of a vertical storage machine. Portland, OR: Oregon Institute of Occupational Health Sciences, Oregon Health and Science University, Report No. 2017–

22–1, https://www.cdc.gov/niosh/face/stateface/or/17or022.

html.

OSHA [2008]. The control of hazardous energy–enforcement policy and inspection procedures. OSHA Instruction. Washington, DC: U.S. Department of Labor, Occupational Safety and Health Administration, Directive No. 

CPL 02‒00‒147, https://www.osha.gov/sites/default/files/

enforcement/directives/CPL_02-00-147.pdf.

OSHA [no date]. Fatality and catastrophe investigation summaries. Washington, DC: U.S. Department of Labor, Occupational Safety and Health Administration, https://www.

osha.gov/pls/imis/accidentsearch.html.
6

For More Information

Find NIOSH products and get answers to workplace 

safety and health questions:

1–800–CDC–INFO (1–800–232–4636) 

TTY: 1–888–232–6348

CDC/NIOSH INFO: cdc.gov/info | cdc.gov/niosh

Monthly NIOSH eNews: https://www.cdc.gov/niosh/enews/

Mention of any company or product does not constitute 

endorsement by NIOSH. In addition, citations to websites 

external to NIOSH do not constitute NIOSH endorsement of the sponsoring organizations or their programs or 

products. Furthermore, NIOSH is not responsible for the 

content of these websites.

This document is in the public domain and may be 

freely copied or reprinted. NIOSH encourages all 

readers of the Workplace Solutions to make them 

available to all interested employers and workers.

As part of the Centers for Disease Control and Prevention, 

NIOSH is the Federal agency responsible for conducting 

research and making recommendations to prevent workrelated illnesses and injuries. All Workplace Solutions 

are based on research studies that show how worker exposures to hazardous agents or activities can be significantly 

reduced.

DOI: https://doi.org/10.26616/NIOSHPUB2022106

DHHS (NIOSH) Publication No. 2022–106

December 2021