Summary
In short
- Three categories with different content: authorised employees who apply energy control, affected employees who operate the equipment, and other employees who work in the area.
- Authorised employee training covers recognition of hazardous energy sources, the type and magnitude of energy available, and the methods and means for isolation and control.
- Where tagout is used instead of lockout, additional training is required covering the limitations of tags, because a tag is a warning device with no physical restraint.
- Retraining is required on change of assignment, change in machines or processes presenting a new hazard, change in the energy control procedure, and whenever a periodic inspection reveals inadequacies.
- Certification must contain the employee name and the dates of training, and it must be kept current as people move between roles.
- The periodic inspection under (c)(6) is where inadequacies surface, and it feeds retraining directly. Where inspections never find anything, the retraining trigger never fires.
What it is
What it is
What does lockout tagout training cover?
Under 1910.147(c)(7), recognition of hazardous energy sources, the type and magnitude of energy in the workplace, and the methods and means for isolation and control, delivered at a depth appropriate to whether the person is authorised, affected or neither.
Who is an affected employee?
Someone whose job requires them to operate or use a machine on which servicing is performed under lockout, or who works in an area where such servicing occurs. They must be instructed in the purpose and use of the energy control procedure, and specifically must not attempt to restart equipment that is locked or tagged out.
When to use it
When to use it, and when not to
This record covers energy control training. The procedures and the isolation records sit separately.
Use it for
- Initial training before an employee is assigned duties involving energy control
- Training affected employees who operate equipment serviced under lockout
- Instructing other employees who work in areas where energy control is used
- Retraining on change of role, machine, process or procedure
- Retraining where a periodic inspection identifies deviations or inadequate knowledge
Not for
- Machine-specific energy control procedures, which state how each machine is isolated
- The periodic inspection under (c)(6), which certifies that procedures are being followed
- Group lockout records, which manage people during a specific job
- The permit to work, where the activity also requires authorisation
- Contractor energy control information exchange, which is a separate obligation
Standards
What it is built against
Training requirements sit within the energy control standard and are tied to the periodic inspection.
| Clause | Requirement | Where it lands |
|---|---|---|
| 1910.147(c)(7)(i)(A) | Authorised employees: recognition of hazardous energy sources, type and magnitude, and methods for isolation and control | Theory content |
| 1910.147(c)(7)(i)(B) | Affected employees: purpose and use of the energy control procedure | Roles covered |
| 1910.147(c)(7)(i)(C) | All other employees: instruction about the procedure and the prohibition on restarting locked or tagged equipment | Roles covered |
| 1910.147(c)(7)(ii) | Additional training where tagout is used, covering the limitations of tags | Theory content |
| 1910.147(c)(7)(iii) | Retraining on change of assignment, machines, processes or procedures, or where inspection reveals inadequacies | Outcome |
| 1910.147(c)(7)(iv) | Certification of training with employee names and dates | Outcome |
| 1910.147(c)(6) | Periodic inspection at least annually, certifying that procedures are followed | Practical assessment |
| 1910.147(f)(2) | Contractor energy control information exchange in both directions | Related records |
What it does not cover
- Machine-specific energy control procedures, stating how each machine is isolated and verified.
- The periodic inspection under (c)(6), certifying that procedures are being followed.
- Group lockout records, managing exposure during a specific job.
- Permit to work, where the activity requires separate authorisation.
- Contractor information exchange, a distinct obligation under (f)(2).
Filling it in
Filling it in well
Train to the category, cover tag limitations honestly, and let the periodic inspection drive retraining.
Authorised, affected and other employees receive different content at different depth, and the record should say which category each person was trained in. Someone moving from operator to maintenance changes category and requires the fuller training, which is a change of assignment and an explicit retraining trigger.
The standard requires recognition of the type and magnitude of energy available in the workplace, which means the actual voltages, pressures, stored energy and gravitational hazards on the equipment people work on. Generic content about hazardous energy does not meet a requirement written in those terms.
A tag is a warning device that provides no physical restraint, can be removed by anyone, and depends entirely on everyone understanding what it means. Where tagout is used, the standard requires training on those limitations specifically, and it is the element most often omitted because it is uncomfortable content.
The annual periodic inspection exists partly to identify deviations and inadequacies, and finding them is an explicit retraining trigger. Where inspections consistently record that everything is satisfactory, either the programme is exemplary or the inspection is not looking, and the retraining trigger never fires either way.
Audit findings
Common audit findings
Energy control training findings concentrate on category coverage and on retraining triggers.
| Finding | Clause | What fixes it |
|---|---|---|
| Only authorised employees trained; affected and other employees not covered. | 1910.147(c)(7)(i) | Three categories with different content; affected employee instruction is short and specific. |
| Training generic rather than covering actual energy types and magnitudes. | 1910.147(c)(7)(i)(A) | The requirement names type and magnitude; cover the equipment people actually work on. |
| Tag limitations not covered where tagout is used. | 1910.147(c)(7)(ii) | Additional training is explicitly required and is the element most often skipped. |
| No retraining on change of assignment. | 1910.147(c)(7)(iii) | Category change is a trigger; an operator becoming a technician needs the fuller training. |
| Periodic inspection findings not feeding retraining. | 1910.147(c)(7)(iii) | Inadequacies identified in inspection are an explicit trigger. |
| Certification lacking employee names or dates. | 1910.147(c)(7)(iv) | Both are specified; a course attendance list is not certification. |
| Periodic inspections consistently finding nothing. | 1910.147(c)(6) | Either exemplary or not looking; observe an actual isolation rather than reviewing paperwork. |
| Contractors working under site procedures without information exchange. | 1910.147(f)(2) | Exchange in both directions and record it. |
| Training not repeated after a machine or procedure change. | 1910.147(c)(7)(iii) | New machines and revised procedures are both explicit triggers. |
| Practical application never observed. | 1910.147(c)(6) | Watch an isolation performed; knowledge of the steps is not the same as performing them. |
Worked case
Case in point: the operator who got it started
A maintenance technician isolated a conveyor to clear a blockage, applied his lock at the local isolator, and went to fetch a tool. The line had been stopped for around ten minutes and product was backing up behind it.
An operator, wanting to keep the line moving and finding the conveyor would not start from the panel, went to the motor control centre and started it from there. He had not been told what a lock on a local isolator meant, because the site trained maintenance staff as authorised employees and covered everyone else in general induction.
The standard requires affected employees to be instructed in the purpose and use of the energy control procedure, and all other employees to be instructed about the prohibition on attempting to restart equipment that is locked or tagged out. That instruction takes a few minutes and had never been given.
Definitions
Definitions and key terms
- Authorised employee
- A person who locks out or tags out machines to perform servicing or maintenance, receiving the fullest training.
- Affected employee
- Someone who operates equipment serviced under lockout, or works in the area, requiring instruction in the procedure's purpose and use.
- Other employees
- Anyone who may be in an area where energy control is used, requiring instruction about the prohibition on restarting.
- Tagout limitations
- That a tag is a warning device with no physical restraint, requiring additional training where tagout is used.
- Periodic inspection
- The annual inspection under (c)(6) certifying procedures are followed, which feeds retraining triggers.
- Retraining trigger
- Change of assignment, machine, process or procedure, or inadequacies revealed by periodic inspection.
- Type and magnitude
- The specific energy present, which the standard requires training to address rather than energy in general.
- Certification
- The training record containing employee names and dates, required explicitly by the standard.
FAQ
Frequently asked questions
Who needs lockout tagout training?+
Three categories, at different depth. Authorised employees who apply energy control receive the fullest training. Affected employees who operate the equipment or work in the area are instructed in the purpose and use of the procedure. All other employees are instructed about the procedure and the prohibition on attempting to restart equipment that is locked or tagged out.
Why does affected employee training matter so much?+
Because it prevents someone finding another way to energise an isolated machine. It is the shortest content in the standard and it addresses a recurring fatal mechanism: an operator who does not know what a lock means, wants the line running, and starts the equipment from a different point. A few minutes of instruction stands between those two facts.
What extra is required for tagout?+
Training on the limitations of tags. A tag is a warning device offering no physical restraint. It can be removed by anyone, and it works only if everyone who sees it understands and respects what it means. The standard requires this to be covered specifically, and it is routinely omitted because it amounts to explaining that the control is weak.
When is retraining required?+
On change of job assignment, change in machines, equipment or processes that presents a new hazard, change in the energy control procedures, and whenever a periodic inspection reveals or the employer believes there are deviations from procedures or inadequacies in knowledge. That last trigger connects the annual inspection directly to training.
What should the periodic inspection actually do?+
Observe an isolation being performed and review the procedure with the authorised employee, rather than checking that paperwork exists. Where inspections consistently certify that everything is satisfactory, either the programme is exceptional or the inspection is reviewing records rather than watching work, and in the second case the retraining trigger never fires.
The agents
What the agents do with it
The record certifies training by category. What fails is the two populations nobody trained and the inspection that found nothing.
Records training by category with names and dates, and triggers retraining on assignment, machine, process and procedure change.
Connects periodic inspection findings to retraining, so identified deviations produce a training obligation rather than an observation.
Links machine-specific procedures to the people trained on them, so a new machine raises a training requirement.
Covers the two-way energy control information exchange with contractors working under or alongside site procedures.
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Sources
- 29 CFR 1910.147(c)(7), training and communication, OSHA
- 29 CFR 1910.147(c)(6), periodic inspection, OSHA
- 29 CFR 1910.147(f)(2), contractor information exchange, OSHA
- 29 CFR 1910.147(c)(4), energy control procedures, OSHA
- CSA Z460, control of hazardous energy (Canada)