OSHA Lockout/Tagout Training Requirements Under 29 CFR 1910.147

Does OSHA require LOTO training certification?

There is an important distinction between a commercial “LOTO certification card” and what OSHA actually requires under 1910.147. The standard does not establish a universal outside credential that makes someone permanently “LOTO certified.” Instead, the employer must provide the required training and certify that employee training has been accomplished and is being kept up to date. That certification must contain each employee’s name and the dates of training.

Authorized employee training

An authorized employee is the person who locks out or tags out machines or equipment to perform servicing or maintenance. OSHA requires authorized employees to be trained to recognize applicable hazardous-energy sources, understand the type and magnitude of energy present in the workplace, and know the methods and means necessary for energy isolation and control.

That means the knowledge/skill requirement is tied to the hazardous energy and control methods the worker will actually encounter—not merely to completing a generic video or quiz.

Affected employee LOTO training requirements

Does OSHA require annual LOTO training or retraining?

No blanket annual retraining rule appears in 1910.147(c)(7). Retraining for authorized and affected employees is triggered when:

• job assignments change;
• machines, equipment or processes change and present a new hazard;
• energy-control procedures change; or
• a periodic inspection—or other information—shows deviations from or inadequacies in an employee’s knowledge or use of the procedure.

Do not confuse training frequency with the annual procedure inspection. Under 1910.147(c)(6), the employer must conduct a periodic inspection of each energy-control procedure at least annually.

Authorized vs. affected employee: the distinction matters

An authorized employee applies lockout or tagout devices and performs servicing or maintenance under the energy-control procedure. An affected employee operates or uses equipment being serviced, or works in the area where the servicing occurs. OSHA requires different training depth for these roles, so employers should identify the role before assigning LOTO training.

Tagout requires additional training

Where tagout is used, employees must also understand its limitations. OSHA emphasizes that tags are warning devices and do not provide the physical restraint of a lock. The standard also addresses legibility, durability, secure attachment and the prohibition on bypassing or ignoring tags.

Contractor coordination matters

When outside servicing personnel perform work covered by 1910.147, the on-site employer and outside employer must inform each other of their respective lockout/tagout procedures. The on-site employer must ensure its employees understand and comply with restrictions and prohibitions of the outside employer’s energy-control program.

1910.147 does not cover construction employment

This is a common source of bad online guidance. The scope paragraph of 1910.147 specifically excludes construction employment. OSHA’s construction standards contain hazardous-energy controls for particular work, including 1926.417 for lockout and tagging of circuits, plus other task-specific standards.

A company can therefore use a strong hazardous-energy-control program across operations, but it still needs to identify which regulatory standard applies to the actual work.

What should an employer retain?

Can online LOTO training qualify an authorized employee by itself?

Online training can efficiently teach the standard, terminology, roles, hazardous-energy concepts and general control sequence. But a course that has never seen the employer’s equipment cannot verify every isolating device, stored-energy source, zero-energy verification method or site-specific procedure.

For authorized employees, the defensible approach is to combine knowledge training with employer-specific instruction and evaluation sufficient to establish that the employee has the knowledge and skills required to safely apply the actual energy-control procedures.