OSHA Training Requirements Under 1910.147(c)(7)

OSHA requires employers to provide lockout/tagout training to ensure that employees understand the purpose of the energy control program and can safely apply, use, and remove energy controls. Training must be role-specific, meaning different categories of employees receive different content.

The training requirements have not changed for 2026, but enforcement has intensified. OSHA inspectors increasingly request training certifications during audits, and missing or incomplete records are among the most common citation triggers.

Authorized Employee Training

Authorized employees (those who perform lockout/tagout) receive the most comprehensive training. Per 1910.147(c)(7)(i)(A), they must be trained in:

  • Recognition of applicable hazardous energy sources: Identifying electrical, mechanical, hydraulic, pneumatic, chemical, thermal, and gravitational energy in the equipment they service
  • Type and magnitude of energy: Understanding the voltage, pressure, temperature, or force involved
  • Methods and means for energy isolation and control: Knowing how to operate isolation devices, apply locks and tags, relieve stored energy, and verify deenergization

This training must be specific to the equipment and energy sources in the worker's facility, not generic safety awareness content.

Affected Employee Training

Affected employees (those who operate or work near locked-out equipment) must be instructed in the purpose and use of the energy control procedure. They need to understand:

  • Why lockout/tagout is being performed
  • That they must not attempt to restart or reenergize equipment that is locked or tagged out
  • How they will be notified before and after LOTO is applied to equipment they use

Other Employee Training

Employees who work in areas where energy control procedures are in effect must be instructed about the procedure and the prohibition against attempting to restart or reenergize equipment. This is a basic awareness requirement, not the technical training that authorized employees receive.

Tagout-Specific Training

When tagout devices are used (with or without locks), employees must receive additional training on the limitations of tags. OSHA 1910.147(c)(7)(ii) specifies six points that must be covered:

  1. Tags are warning devices only and do not provide the physical restraint of a lock
  2. Tags must not be removed, bypassed, ignored, or defeated without authorization
  3. Tags must be legible and understandable by all employees in the area
  4. Tags and their attachment means must withstand workplace environmental conditions
  5. Tags may evoke a false sense of security, and workers must understand their limitations
  6. Tags must be securely attached so they cannot be accidentally detached during use

When Retraining Is Required

Initial training is not a one-time event. OSHA requires retraining in three situations:

  • Job assignment changes: When an employee takes on new duties involving different equipment or energy sources
  • Equipment or procedure changes: When machines, equipment, or processes are modified in ways that present new hazards, or when energy control procedures are revised
  • Knowledge deficiencies: When periodic inspections reveal (or the employer has reason to believe) that employees lack the knowledge or skills to properly apply energy controls

Retraining must reestablish proficiency and introduce any new or revised methods and procedures.

Documentation Requirements

OSHA 1910.147(c)(7)(iv) requires employers to certify that training has been accomplished. Each certification must contain:

  • The employee's name
  • The date(s) of training

While OSHA requires only name and date, best practice includes the training content covered, the trainer's name, and the employee's signature. This documentation must be available for OSHA inspection at any time.

Common Training Audit Failures

  • No role differentiation: Giving all employees the same generic training instead of role-specific content
  • No retraining records: Conducting initial training but failing to retrain when equipment or procedures change
  • Missing certifications: Conducting training sessions without documenting attendee names and dates
  • No tagout content: Omitting the six required tagout limitation topics when tags are used in the facility

A LOTO management platform with built-in training tracking ensures certifications are always documented and retraining triggers are not missed. See how LOTOBuilder handles training records.