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About
We Were Tired of Reading Safety Guides Written by People Who’ve Never Held a Padlock
I spent three hours one Tuesday night trying to figure out whether I needed a written lockout procedure for a single-energy-source punch press.
The OSHA regulation? Dense. The “helpful” compliance sites? Either dry government PDFs that read like they were translated from Latin, or sales pages trying to convince me that a $200 “universal lockout kit” would solve all my problems.
It wouldn’t. Half the devices in those kits don’t fit anything in a real machine shop.
That Tuesday night—after my fourth cup of bad coffee—I decided someone needed to translate 29 CFR 1910.147 into language that makes sense to the guys actually doing the work. Someone who’s stood in front of an OSHA inspector and had to explain why the lockout log had a gap from third shift. Someone who knows the difference between what’s legally required and what’s just good practice.
Standard 1910 is that translation.
We’re not here to sell you a “comprehensive safety culture transformation.” We’re here to keep you from getting a $16,131 citation because your lockout procedures say “turn off the machine” instead of specifying which disconnect switch on which panel.
Meet the Field Team
Joel Lee — The Guy Behind the Keyboard
20 years in manufacturing. Survived more OSHA audits than I care to count. Has strong opinions about cheap plastic hasps.
I started as a maintenance tech in a food processing plant where “lockout” meant hanging your personal padlock on whatever looked important. By year three, I’d seen two near-misses that still wake me up sometimes.
Moved into safety management because I got tired of watching good workers get put at risk by bad paperwork. Spent the next fifteen years building energy control programs, training authorized employees, and explaining to plant managers why “we’ve always done it this way” doesn’t hold up when the compliance officer shows up.
I’ve written lockout procedures for hydraulic presses, conveyor systems, industrial ovens, CNC machines, ammonia refrigeration systems, and one very angry packaging line that had six different energy sources and a union steward who didn’t believe in group lockout.
Now I write about it. Because the information shouldn’t be this hard to find.
The Philosophy
A few things I believe:
If it doesn’t fit in a pocket, it doesn’t get used. I’ve seen $500 lockout stations gather dust while guys use whatever padlock was in their toolbox. Hardware has to work in the real world.
Compliance isn’t about the binder on the shelf. It’s about the guy going home with all ten fingers. The paperwork matters because it creates the system. But the system exists to protect people.
OSHA isn’t the enemy. Bad procedures are. I’ve met plenty of reasonable compliance officers. I’ve never met one who accepted “we do annual training” as a substitute for documented annual inspections.
How We Review Products
The No-BS Pledge
Every product recommendation on this site ties back to a specific regulatory requirement. Period.
Here’s what that means:
We don’t recommend “universal” kits unless they actually fit. Those circuit breaker lockouts that claim to fit “most breakers”? Most means about 60%. We tell you which specific breaker types each device actually works with. If it doesn’t fit your Square D QO breakers, you need to know that before you buy.
We cite the specific OSHA paragraph for every compliance claim. When we say a lockout device must be “substantial,” we tell you that’s from 1910.147(c)(5)(ii)(C) and explain that OSHA defines substantial as requiring “bolt cutters or other metal cutting tools” for removal. When we talk about the 50-pound tag attachment rule, we cite the exact regulatory language and the 2000 Letter of Interpretation that clarified it.
We distinguish between legal requirement and best practice. OSHA’s 29 CFR 1910.147 is law. ANSI/ASSE Z244.1 is a consensus standard—useful guidance, but not enforceable by itself. These are different things, and mixing them up creates confusion. We wrote an entire article explaining the difference.
We disclose affiliate relationships. When we link to products on Amazon or other retailers, we may earn a commission. This doesn’t change our recommendations—we recommend what meets the regulatory requirements, not what pays the highest commission. But you should know the relationship exists.
Why We Focus on 1910.147
The Numbers Tell the Story
Lockout/Tagout violations ranked #5 on OSHA’s Top 10 Most Cited Standards in 2024. That’s 2,443 citations in a single year.
Here’s what those citations break down to:
| Violation Type | Citations | What It Means |
|---|---|---|
| Energy Control Procedures | 730 | Missing or generic written procedures |
| Training and Communication | 491 | Inadequate training documentation |
| Periodic Inspection | 362 | Confusing training with inspection |
| Energy Control Program | 289 | No comprehensive written program |
| Application of Control | 231 | Improper lockout sequence execution |
Look at that list. The top four violations are all documentation failures, not hardware failures. Companies get cited because the paperwork doesn’t exist, doesn’t cover the specific machine, or doesn’t get updated.
This is where good managers get fired for bad paperwork.
I’ve seen plant managers with 20 years of experience lose their jobs because someone in corporate decided the facility “wasn’t taking safety seriously enough” after an OSHA citation. The machines were fine. The workers knew what they were doing. But the written procedure said “disconnect power” instead of specifying “open disconnect switch DS-7 on Panel 3, verify zero voltage with multimeter.”
That level of specificity is what OSHA requires. That’s what we teach.
Our LOTO Audit Survival Guide breaks down exactly what inspectors look for and where most companies fail.
Don’t Get Fined. Get Prepared.
The energy control procedure is the foundation of LOTO compliance. It’s also where 730 companies got cited last year.
A compliant procedure isn’t complicated, but it does have to include specific elements that OSHA requires under 1910.147(c)(4)(ii). Most templates you’ll find online miss at least one.
Download our free Energy Control Procedure (ECP) Template to see what a machine-specific procedure actually looks like. It includes:
- All eight required elements from 1910.147(c)(4)(ii)
- Placeholders for machine-specific information
- Verification testing documentation
- The “Shop Floor Translation” for each regulatory requirement
[Get the Free ECP Template →]
No email required. No sales pitch. Just the template.
Questions?
I read every email that comes through the contact form. If you’ve got a specific compliance question about your facility, I’ll do my best to point you toward the right regulation or interpretation.
I can’t provide legal advice—I’m not a lawyer, and your specific situation may have factors I can’t see from an email. But I can usually tell you where to look and what questions to ask.
[Contact Us →]
Standard 1910 is an independent publication focused on OSHA Lockout/Tagout compliance. We are not affiliated with OSHA, the Department of Labor, or any equipment manufacturer. All regulatory citations reference 29 CFR 1910.147 and official OSHA Letters of Interpretation.
