Lockout/Tagout in California and Federal OSHA, Explained
Lockout/tagout is the standard employers are most confident they already comply with, and the one where the compliance usually turns out to be partial. The locks are on the wall, the training happened at some point, and the two things the standard actually gets cited for are missing: an equipment-specific written procedure, and a certified annual inspection of it.
There is also a jurisdictional trap at the front of this subject that catches contractors in particular. The standard everyone quotes does not apply to construction work.
Every citation on this page was checked against the regulation text on 23 August 2026.
The standard everybody quotes excludes construction
29 CFR 1910.147 is the control of hazardous energy standard. It is the one that requires the written program, the training tiers, the annual inspection and the group lockout procedures. Its scope paragraph, 1910.147(a)(1)(ii)(A), excludes construction and agriculture employment in exactly those words.
What covers construction federally is 29 CFR 1926.417, in Subpart K, the electrical subpart. Here is the entire standard:
- (a) Controls. Controls that are to be deactivated during the course of work on energized or deenergized equipment or circuits shall be tagged.
- (b) Equipment and circuits. Equipment or circuits that are deenergized shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized.
- (c) Tags. Tags shall be placed to identify plainly the equipment or circuits being worked on.
Three sentences. Tags, not locks. Electrical circuits, not machinery generally. No written program, no training requirement, no periodic inspection, no group lockout provision.
Two wrong conclusions get drawn from that. The first is that a construction employer must therefore comply with 1910.147, which is not what the scope paragraph says. The second is that a construction employer owes nothing, which ignores that the General Duty Clause, section 5(a)(1) of the OSH Act, still reaches a recognized hazard likely to cause death or serious physical harm, and that individual equipment standards carry their own energy control language. The correct conclusion is narrower and more useful: find out which standard you are actually under before you write the program, because writing a 1910.147 program for a construction operation produces a document that answers a question nobody asked you.
How federal standards interact with a state running its own program is covered on our federal OSHA and state plans page.
The minor servicing exception, read all the way to the end
29 CFR 1910.147(a)(2)(ii) excludes normal production operations. The Note to that paragraph is where the arguments happen. It permits minor tool changes and adjustments, and other minor servicing activities that take place during normal production, to fall outside the standard, on two conditions read together:
- the work is routine, repetitive and integral to the use of the equipment for production, and
- the work is performed using alternative measures which provide effective protection.
Employers reliably remember the first condition and reliably forget the second. Clearing a jam five times a shift is routine, repetitive and integral. It is still not exempt unless something protects the employee while they do it, and that something has to be an actual measure, such as interlocked guarding or a control reliable circuit, not a habit of being careful.
This is the paragraph that decides most machine guarding fatalities involving energized equipment. If the exception did not apply, the machine needed a full lockout, and the citation follows the body part rather than the paperwork.
The two documents that are usually missing
A lockout program is cited on its documents far more often than on its hardware. Two in particular.
The equipment-specific written procedure
29 CFR 1910.147(c)(4)(i) requires procedures to be developed and documented. There is an exception, and it is narrow: all eight of its conditions have to be true at once, including no potential for stored or residual energy, a single readily identifiable energy source, a single lockout device that achieves the locked out condition, exclusive control by the authorized employee performing the work, no hazard to other employees, and no accident involving unexpected energization during servicing of that machine. One condition false, and the procedure has to be written.
1910.147(c)(4)(ii) then sets out what it has to contain, and the operative word is specific: the intended use of the procedure, the steps for shutting down and isolating the equipment, the steps for placing, removing and transferring the devices and who is responsible for them, and the requirements for testing to verify the isolation actually worked. A one-page policy that names no equipment satisfies none of that.
The certified annual inspection
29 CFR 1910.147(c)(6)(i) requires a periodic inspection of the energy control procedure at least annually, performed by an authorized employee other than the one using the procedure being inspected. 1910.147(c)(6)(ii) requires the employer to certify it, naming the machine or equipment, the date, the employees included, and the inspector.
This is the most common single gap we find in programs that are otherwise in reasonable shape. It is also the standard's own drift detector: 1910.147(c)(7)(iii) makes retraining mandatory when an inspection reveals a deviation or inadequacy. Skip the inspection and you have also disabled the mechanism that was supposed to tell you the program had stopped working.
California, and section 3314
California's lockout rule is 8 CCR 3314, in the General Industry Safety Orders. It covers cleaning, repairing, servicing, setting up, adjusting and unjamming machinery where unexpected energization or start up could injure someone.
The bones are the same as the federal rule, with California-specific edges:
- A hazardous energy control procedure is required and must be documented in writing, with steps for each affected machine. One document may cover a group of machines where the controls are similarly configured and the disconnect points are readily identified.
- The periodic inspection is at least annually, by someone other than the users of the procedure, matching the federal interval.
- Training is documented under 8 CCR 3203, the injury and illness prevention program regulation. In California, lockout training records are IIPP records. Federal OSHA has no IIPP requirement at all, which is one of the sharper practical differences between the two systems.
- 3314 carries hardware requirements federal OSHA does not, including that tagout devices be non-reusable, attachable by hand, self-locking, and non-releasable with a minimum unlocking strength of no less than 50 pounds.
One question this page does not answer, on purpose: whether a particular California construction operation controls hazardous energy under 3314 or under a Construction Safety Order. 3314 sits in the General Industry Safety Orders, and Cal/OSHA's own published lockout guidance does not address construction scope. That is a real question with a real answer for any given operation, and it is worth settling before an inspection rather than during one. Call and we will work it through against what you actually do.
What we do with this
We write hazardous energy control procedures that name the equipment, run the annual periodic inspection and produce the certification that 1910.147(c)(6)(ii) and 3314 require, and train the three tiers separately rather than putting everyone through the authorized employee class.
Consulting covers the written procedures and the machine-by-machine survey. Training is delivered nationwide. Fractional EHS is the option when the annual inspection needs an owner who is not the person running the procedure. Related program work sits on our confined space and heat illness pages.
Lockout/tagout questions, answered
Does OSHA's lockout/tagout standard apply to construction work?
No. 29 CFR 1910.147(a)(1)(ii)(A) excludes construction and agriculture employment in exactly those words. That surprises most people, because 1910.147 is the standard everyone means when they say lockout/tagout. On a construction site the federal rule is 29 CFR 1926.417, which is three sentences long, applies to electrical circuits, and requires tags rather than locks. It does not require a written program, training, or an annual inspection.
So construction work has no real lockout standard?
Federally, close to none. 1926.417 sits in Subpart K, the electrical subpart, and covers tagging deenergized circuits. There is no federal construction equivalent of the full 1910.147 program. That does not mean a contractor has no exposure. The General Duty Clause, OSH Act section 5(a)(1), still reaches a recognized hazard causing death or serious physical harm, and specific equipment standards carry their own energy control language. It does mean a contractor who assumes 1910.147 covers them is reading the wrong standard, and one who assumes nothing covers them is reading the wrong conclusion.
What is the minor servicing exception, and why does it get employers cited?
29 CFR 1910.147(a)(2)(ii) says normal production operations are not covered. The Note attached to it allows minor tool changes and adjustments during normal production without full lockout, but only where the work is routine, repetitive and integral to production, and only where it is performed using alternative measures that provide effective protection. Employers cite the first half of that sentence and skip the second. Routine and repetitive is not the test on its own. If there is no alternative protective measure in place, the exception does not apply and the machine needed to be locked out.
Do we have to have a written energy control procedure?
Almost always yes. 29 CFR 1910.147(c)(4)(i) requires procedures to be developed and documented. There is an exception, but it only applies when all eight listed conditions exist at once, including no potential for stored or residual energy, a single readily identifiable energy source, a single lockout device achieving the locked out condition, exclusive control by the authorized employee doing the work, no hazard created for other employees, and no accident involving unexpected energization during servicing of that machine. Miss one condition and you owe a written procedure.
Does one written procedure cover the whole facility?
Not usually. The procedure has to be specific enough to tell an authorized employee what to do on the machine in front of them, which means the shutdown sequence, the isolating devices, the stored energy, and the verification step for that equipment. One document can cover a group of machines where the energy sources and controls are genuinely alike, and 8 CCR 3314 says so directly for California. A single generic page that names no equipment is the version that does not survive an inspection.
How often does the periodic inspection have to happen?
At least annually, under 29 CFR 1910.147(c)(6)(i), and 8 CCR 3314 uses the same annual interval. Two details get missed. First, the inspection is of the procedure, not of the hardware, so walking the plant looking at padlocks is not it. Second, it has to be performed by an authorized employee other than the one using the procedure being inspected. The person who does the work cannot inspect their own procedure.
Does the inspection have to be documented?
Yes. 29 CFR 1910.147(c)(6)(ii) requires the employer to certify it, and the certification has to identify the machine or equipment, the date, the employees included, and who performed the inspection. This is the single most commonly missing document in an otherwise decent lockout program. The program exists, the locks exist, the training happened, and there is no annual certification anywhere in the building.
Who has to be trained, and in what?
Three tiers, under 29 CFR 1910.147(c)(7). Authorized employees, the ones who apply the locks, are trained on recognizing hazardous energy, the type and magnitude of the energy in the workplace, and the methods for isolating and controlling it. Affected employees, the ones who operate the machine, are trained on the purpose and use of the procedure. Everyone else who works in the area is trained on the procedure and on the prohibition against restarting equipment that is locked or tagged out. If you use tags rather than locks, there is a further block of training on the limitations of tags.
When do we have to retrain?
On a change in job assignment, on a change in machines, equipment or processes that presents a new hazard, or on a change in the energy control procedure itself. Beyond that, retraining is required when a periodic inspection reveals, or the employer has reason to believe, that an employee's knowledge or use of the procedure has slipped. That last trigger is why the annual inspection matters. It is the mechanism the standard uses to catch drift.
Can a supervisor cut off a lock when the employee who applied it has gone home?
Only under a specific documented procedure. 29 CFR 1910.147(e)(3) requires each device to be removed by the authorized employee who applied it. Removal by anyone else is allowed only where the employer can demonstrate that the specific procedure used provides equivalent safety, and that procedure has to be in the written energy control program. Bolt cutters plus a supervisor's judgment is not a procedure.
How does group lockout work when three trades are on the same machine?
29 CFR 1910.147(f)(3) requires group lockout to give each employee protection equivalent to a personal device. In practice that means a group lockout device or box, a primary authorized employee responsible for the group, and each authorized employee affixing a personal lock to the group mechanism when they start work and removing it when they finish. Where more than one crew is involved, one authorized employee coordinates across crews so protection does not lapse in the handoff between them.
What happens at shift change?
29 CFR 1910.147(f)(4) requires specific procedures for the transfer, designed so protection is continuous. The off-going and oncoming authorized employees hand the devices over in an orderly way, and there is no window in which the machine is unlocked because one shift left before the next arrived. Most shift change failures are not procedural gaps, they are timing gaps.
What does California require that federal OSHA does not?
California's rule is 8 CCR 3314, in the General Industry Safety Orders. It requires a written hazardous energy control procedure, an annual periodic inspection by someone other than the user of the procedure, and training documented under 8 CCR 3203, the injury and illness prevention program regulation. Tying lockout training records to the IIPP is a California feature. 3314 also carries hardware language federal OSHA does not, including a minimum unlocking strength for tag attachments. Whether a given California operation is under the General Industry Safety Orders or the Construction Safety Orders is a question worth settling before an inspection rather than during one, and it is one we answer per operation.
Start with the annual inspection
If you want a quick read on whether your program would survive an inspection, the fastest test is to ask for last year's periodic inspection certification. If nobody can produce it, that is the place to start. Call 949-954-6581 or use the contact page.