Why Audit Your LOTO Program?

Lockout tagout violations are consistently among OSHA's top 10 most-cited standards. In 2025, the average serious LOTO violation penalty exceeded $15,000 per instance (see common LOTO violations). A proactive internal audit identifies gaps before an OSHA inspector finds them.

Audit Checklist

1. Written Energy Control Procedures

OSHA 1910.147(c)(4) requires documented procedures for each piece of equipment. Verify that:

  • Every machine with hazardous energy has a written LOTO procedure
  • Each procedure includes a specific statement of intended use
  • Steps for shutdown, isolation, blocking, and securing are documented
  • Device placement, removal, and transfer responsibilities are defined
  • Verification testing requirements are specified

2. Annual Periodic Inspections

Per 1910.147(c)(6), every energy control procedure must be inspected at least annually. Check that:

  • Each procedure has been inspected within the last 12 months
  • Inspections were performed by an authorized employee other than the one(s) using the procedure
  • Inspection certifications include: machine/equipment identified, inspection date, employees included, and inspector name
  • Any deviations or inadequacies were corrected

3. Employee Training

1910.147(c)(7) requires role-specific training:

  • Authorized employees: energy source recognition, type and magnitude, isolation and control methods
  • Affected employees: purpose and use of energy control procedures
  • Other employees: awareness of prohibition on restarting/reenergizing
  • Training certifications exist with employee name and training dates
  • Retraining has occurred when job assignments, equipment, or procedures changed

4. Hardware and Devices

Verify lockout/tagout devices are:

  • Singularly identified and used only for energy control
  • Standardized by color, shape, or size within the facility
  • Substantial enough to prevent unauthorized removal
  • Clearly identifying the employee who applied them

5. Common Citation Triggers

Focus extra attention on these frequently-cited areas:

  • Missing or incomplete procedures for specific equipment
  • Overdue or undocumented periodic inspections
  • No training records or missing retraining documentation
  • Tag-only programs on equipment capable of being locked out without documented justification
  • No procedures for shift changes or group lockout situations

After the Audit

Document findings, prioritize gaps by risk severity, and assign corrective actions with deadlines. Digital LOTO systems make ongoing audit readiness dramatically easier. The audit itself becomes evidence of your organization's good-faith compliance effort.