Energy Control Procedure Template

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Key Takeaways

730 companies received citations for energy control procedure violations in FY2024 — the #1 most-cited LOTO subsection
Generic “one-size-fits-all” procedures fail OSHA audits because they lack machine-specific isolation steps
Every compliant procedure must include 6 mandatory elements plus documented energy magnitude
Stored energy requirements (capacitors, springs, hydraulics) are where most “complete” procedures still fail

OSHA cited 730 companies for energy control procedure violations last year. That’s not a typo. Seven hundred thirty. More than any other lockout/tagout subsection.

The kicker? Most of those companies had procedures. They just had the wrong kind.

An energy control procedure template that passes audits looks nothing like the generic forms you download from safety supply websites. Those templates check a box. They don’t protect workers. And osha knows the difference.

I’ve reviewed hundreds of energy control procedures over 20 years. The ones that fail audits share the same problem: they’re written for “equipment” instead of for that specific hydraulic press on Line 3.

What OSHA Requires for Energy Control Procedures

Split-screen diagram of CNC lathe procedures: detailed blueprint vs generic checklist.

An energy control procedure is a machine-specific written document that details the exact steps for shutting down, isolating, blocking, and verifying zero energy state before servicing. Not a generic checklist. Not a one-page form. A procedure written for that machine.

“Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.”
— 29 CFR 1910.147(c)(4)(i)

Shop Floor Translation: You need a written procedure for EVERY piece of equipment that requires lockout/tagout. “Every piece” means the CNC lathe gets its own procedure. The conveyor system gets its own procedure. The packaging machine gets its own procedure. One generic form covering “all equipment” fails the audit before the inspector finishes reading page one.

The regulation spells out exactly what each procedure must contain. Miss any of these elements and you’ve got a citation waiting to happen.

The “Generic” Trap: Why Energy Control Procedure Templates Fail Audits

Precision instruments vs blank forms, highlighting specific energy control instructions.

The most common energy control procedure template failure isn’t missing paperwork. It’s having paperwork that doesn’t actually describe the machine.

Here’s what I see constantly: A facility downloads a template, fills in the equipment name at the top, and checks boxes for “electrical” and “pneumatic” energy sources. Done. Filed. Forgotten until the audit.

Then the OSHA inspector asks the authorized employee to walk through the procedure on the actual machine. The procedure says “de-energize at main disconnect.” The inspector asks: “Which disconnect? There are three panels within 50 feet of this machine.”

Citation issued.

COMPLIANT PROCEDURE	NON-COMPLIANT PROCEDURE
“De-energize at Panel 3B, Breaker #17 (40A), located on north wall 15 feet from machine”	“Turn off power at disconnect”
“Close and lock ball valve V-103 (2-inch, red handle) on hydraulic supply line”	“Shut off hydraulic pressure”
“Bleed accumulator through port A-7 until gauge reads 0 PSI (±2 PSI)”	“Release stored energy”
“Block ram with 6-inch steel prop (Part #BLK-2234) at full up position”	“Support any raised components”

The left column passes audits. The right column generates citations. The difference isn’t length — it’s specificity.

AUDIT TRAP: “Generic procedures are acceptable for identical machines” is a myth. OSHA Letter of Interpretation (March 24, 1995) clarifies that even machines of the same make and model may have different energy sources due to modifications, location, or auxiliary equipment. Each machine needs verification that the procedure actually matches its current configuration.

The 6 Mandatory Steps Every Energy Control Procedure Must Include

Diagram of 6 mandatory energy control steps with icons and industrial machinery.

OSHA regulation 1910.147(c)(4)(ii) lists the required elements. Your energy control procedure template must address all six — not as checkbox items, but as machine-specific instructions.

Step 1: Intended Use Statement

The procedure must state its specific purpose. This isn’t bureaucratic filler. It defines scope — what servicing activities this procedure covers.

What to include:

Machine name and unique identifier (asset number, location code)
Specific servicing tasks this procedure covers
Tasks that require different procedures or are excluded

Example language:
“This energy control procedure covers blade replacement, belt adjustment, and bearing lubrication on Bandsaw #BS-107 (Asset 2234-A), Building 3, Cell 7. Annual motor replacement requires Procedure ECP-2234-B.”

Step 2: Procedural Steps for Shutdown

Not “turn off the machine.” The actual sequence.

What to include:

Normal operating shutdown sequence (what buttons, what order)
What the machine should do during proper shutdown
Warning signs that shutdown isn’t proceeding normally
Who to contact if shutdown sequence fails

The authorized employee performing lockout needs enough detail to shut down equipment they may not operate daily.

Step 3: Procedural Steps for Machine Isolation

This is where generic templates fall apart. “Isolate all energy sources” tells the worker nothing.

What to include for each energy source:

Exact location (panel number, valve tag, specific breaker)
Physical description (color, size, position indicators)
Required position (open/closed, on/off, up/down)
Verification method (indicator lights, gauge readings, physical position)

A maintenance technician should be able to walk to every isolation point using only this procedure. If they have to ask someone “which valve?”, the procedure fails.

Step 4: Procedural Steps for Lockout Device Application

Your procedure must specify what lockout hardware goes where.

“Lockout devices… shall be affixed to each energy isolating device by authorized employees.”
— 29 CFR 1910.147(d)(4)(i)

Shop Floor Translation: Each energy isolating device gets a lock. If the machine has four isolation points — a breaker, two valves, and a pneumatic disconnect — the procedure specifies four lock placements. Not “lock out all energy sources.” Four specific instructions for four specific locations.

What to include:

Lock type required for each isolation point (padlock, valve lockout, breaker lockout)
Device specifications if non-standard hardware needed
Group lockout requirements if multiple workers involved
Hasp requirements if multiple locks needed at single point

Step 5: Procedural Steps for Stored/Residual Energy

This section separates procedures that protect workers from procedures that just satisfy paperwork requirements. More on this in the stored energy section below.

What to include:

Each source of stored energy present after isolation
Specific method for dissipating or restraining each source
Measurable verification criteria (gauge readings, physical position, temperature)
Time requirements for energy dissipation if applicable

Step 6: Procedural Steps for Equipment Verification

The “try start” requirement. Non-negotiable.

“Prior to starting work on machines or equipment that have been locked out or tagged out, the authorized employee shall verify that isolation and deenergization of the machine or equipment have been accomplished.”
— 29 CFR 1910.147(d)(6)

Shop Floor Translation: After lockout, attempt to start the machine using normal operating controls. Confirm nothing happens. This verification step must be documented in the procedure — not assumed.

What to include:

Specific verification test method (push start button, actuate switch)
Expected result (no response, no movement, no pressure)
Secondary verification methods (voltage testing, pressure gauge check)
Documentation requirements for verification completion

Documenting Energy Magnitude in Your Energy Control Procedure Template

Isometric diagram of energy magnitude documentation highlighting voltage and pressure.

Here’s what separates adequate procedures from audit-proof procedures: energy magnitude documentation.

OSHA requires authorized employees to understand “the type and magnitude of the energy” for machines they lock out. Most templates check the “type” box with generic labels: electrical, hydraulic, pneumatic. They ignore magnitude entirely.

Energy Type	Magnitude Documentation Required
Electrical	Voltage (480V 3-phase), amperage (60A), circuit designation
Hydraulic	Operating pressure (3000 PSI), accumulator pre-charge pressure
Pneumatic	Line pressure (120 PSI), receiver tank capacity (80 gallons)
Thermal	Operating temperature (450°F), cooldown time required
Gravitational	Component weight (2,400 lbs), drop height if blocking fails
Mechanical (springs)	Stored force (500 lb-ft), travel distance if released

Why does this matter? Because magnitude determines hazard severity and influences lockout device selection. A worker locking out 480V needs different respect for the hazard than someone locking out 24V control circuits. Both need lockout. The consequences of failure differ dramatically.

Include magnitude in your energy control procedure template for:

Each identified energy source
Both operating levels and maximum possible levels
Units of measurement (not just “high pressure”)

Handling Stored Energy: Capacitors, Springs, and Hydraulics

Illustration of stored energy management: capacitors, accumulators, springs, and safety measures.

Stored energy violations hide inside “complete” procedures. The machine is locked out. Power is isolated. The authorized employee is cited anyway. Why?

Because residual energy remained in the system, the procedure didn’t address it, and someone got hurt — or an inspector noticed the gap.

“Following the application of lockout or tagout devices to energy isolating devices, all potentially hazardous stored or residual energy shall be relieved, disconnected, restrained, or otherwise rendered safe.”
— 29 CFR 1910.147(d)(5)(i)

Shop Floor Translation: Flipping the breaker off doesn’t eliminate the charge in capacitors. Closing the valve doesn’t eliminate pressure in the accumulator. Stored energy must be specifically addressed for each machine.

Capacitors and Electrical Storage

Capacitors retain charge after power isolation. Your energy control procedure template must include:

Capacitor locations on the machine
Discharge method (built-in bleed resistors, manual discharge procedure)
Verification method (voltage measurement points, indicator lights)
Wait time if passive discharge required (specify duration)

Failure pattern: “Allow capacitors to discharge” without specifying duration or verification. OSHA wants measured confirmation, not assumptions about dissipation time.

Springs and Mechanical Storage

Compressed or extended springs store mechanical energy. If released unexpectedly, that energy goes somewhere — often into the worker.

What to include:

Spring locations and function
Normal operating state (compressed, extended, tensioned)
Safe release procedure or blocking method
Blocking device specifications and placement points

Hydraulic and Pneumatic Accumulators

These are the most frequently missed stored energy sources. The hydraulic pump is off. Pressure remains in the accumulator.

What to include:

Accumulator location and type
Bleed procedure (specific valve, port location)
Zero-pressure verification (gauge location, acceptable reading)
Caution for pressure rebuilding if isolation incomplete

AUDIT TRAP: Your procedure says “bleed hydraulic pressure.” The inspector asks: “To what pressure level? How does the worker verify it?” If your answer is “until it stops” instead of “until gauge reads 0 PSI ±2 PSI,” prepare for the citation.

The 8-Element Exception: When You Don’t Need a Written Procedure

Diagram of 8-element exception: narrow exception path vs open procedural path.

OSHA includes an exception at 1910.147(c)(4)(i) that allows skipping the written procedure. It’s narrow. It’s specific. And it disappears the moment you have an incident.

The exception applies ONLY when ALL eight conditions exist:

No stored or residual energy after shutdown
Single energy source that is readily identified and isolated
Isolation completely de-energizes the machine
Machine is locked out during servicing
Single lockout device achieves locked-out condition
Lockout device under exclusive control of authorized employee
Servicing does not create hazards for other employees
Employer has NO accidents involving unexpected energization on that machine

Miss one element, written procedure required. Have one near-miss incident, written procedure required permanently.

My recommendation: Write the procedure anyway. The exception requires you to verify eight conditions for every machine. That verification takes longer than writing the procedure. And when you have that first incident — and you will eventually — you’ll need the procedure regardless.

Download: Free Energy Control Procedure Template

Illustration of template customization: blank canvas to detailed technical diagram with custom fields.

I’ve put together an energy control procedure template that includes all six OSHA-required sections plus the stored energy and magnitude documentation that separates citations from compliance.

This template includes:

Machine identification section with asset tracking
Energy source inventory table with magnitude fields
Step-by-step isolation instructions with location fields
Stored energy checklist (electrical, mechanical, hydraulic, pneumatic, gravitational)
Verification testing documentation
Group lockout provisions
Procedure review and update log

The template is formatted for direct use. Fill in your machine-specific information. The structure ensures you don’t miss the sections that trigger citations.

[Download the Energy Control Procedure Template (Word .docx)]

Note: This template provides structure and required elements. You must customize it with machine-specific information for each piece of equipment requiring lockout/tagout.

Maintaining Your Energy Control Procedures

Diagram of evolving energy procedures: growing tree with inspection elements and update triggers.

Documentation isn’t one-and-done. The regulation requires periodic inspection.

“The employer shall conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”
— 29 CFR 1910.147(c)(6)(i)

Shop Floor Translation: Every energy control procedure needs annual inspection. Not annual training. Inspection means watching an authorized employee actually perform the procedure on the machine and verifying the documented steps match reality.

When machines are modified — new controls, relocated disconnects, additional energy sources — the procedure updates immediately. Annual inspection catches drift. Modification triggers immediate revision.

FAQ

Q: Can I use one energy control procedure for multiple identical machines?

A: Only if they are truly identical in current configuration. Same make, model, and options don’t guarantee identical lockout requirements. Modifications, different panel locations, auxiliary equipment connections, and facility-specific installation differences require verification. Many facilities find separate procedures for “identical” machines easier to maintain than proving ongoing equivalence.

Q: What if my machine has more energy sources than the template allows?

A: Add rows. The template structure accommodates any number of energy sources. Complex machines with 8-10 isolation points need 8-10 documented lockout steps. Don’t compress multiple energy sources into single line items to fit a form — expand the form to match the machine.

Q: How specific does the location information need to be?

A: Specific enough that a qualified worker unfamiliar with the machine can locate every isolation point without asking for help. “Panel 3B, Breaker 17, north wall of Building 2, 15 feet east of Column J-7” beats “main electrical panel.” If someone has to hunt for it, the procedure isn’t specific enough.

Q: Does every piece of equipment need an energy control procedure?

A: Every piece requiring LOTO for servicing needs either a machine-specific written procedure or documented verification that it qualifies for the 8-element exception. Cord-and-plug equipment under exclusive control during servicing has a separate exception. When in doubt, write the procedure.

Q: Who should write the energy control procedure?

A: Someone who knows the machine. Typically maintenance supervision working with operators who run the equipment daily. The authorized employees who will use the procedure should review it before implementation. Outside consultants can provide templates and structure, but machine-specific knowledge comes from your people.