Guide

Cited by OSHA for lockout/tagout (1910.147)? What to do next

Lockout/tagout is one of the standards OSHA cites most often every year, and the section cited most is the one about written energy control procedures. If your citation mentions 1910.147, this is what usually needs to happen.

1. Read exactly what was cited

Each item on the citation names a paragraph of 1910.147 and an abatement date. The common ones:

• (c)(4) — no written, machine-specific energy control procedures.
• (c)(7) — employees not trained, or training not documented.
• (c)(6) — no periodic inspection of the procedures, at least annually.
• (c)(5) — no lockout devices provided, or devices not durable and identifiable.

2. Mind the deadlines

You have 15 working days from receiving the citation to notify the Area Director in writing if you want to contest it. You can ask for an informal conference with the area office, but it does not stop that 15-day clock, so ask early (OSHA Field Operations Manual, chapter 7). Each item also has an abatement date: the day by which it must be corrected. If you have legal questions about contesting or penalties, talk to a lawyer: this guide is about fixing the problem.

3. Fix the procedures machine by machine

1. List every machine that people service, clean or clear jams on.
2. For each one, identify every energy source and the device that isolates it, with its location.
3. Write the procedure: intended use, shutdown, isolation, lock and tag placement, stored energy, verification, and return to service.
4. Have a qualified person verify it on the machine and approve it.

Machines of the same type, with the same energy sources and the same controls, can share one procedure. Different models usually need their own.

4. Train and document

Authorized employees need training on recognizing energy sources and on the procedure; affected employees need to know what lockout is and that they must not touch locked-out equipment. Keep a record with names and dates.

5. Prove abatement

For every item you do not contest, OSHA's abatement verification rule (29 CFR 1903.19) requires you to certify that it was corrected, within 10 calendar days after the abatement date, and for some items to send documents such as the procedures or training records. Keep copies of everything you send.

General information, not legal advice.