29 CFR 1910.147 governs the control of hazardous energy during servicing and maintenance. LOTO citations are frequently classified as serious because the exposure is amputation or death.
A written energy control program, machine-specific written procedures, annual periodic inspection of those procedures, training for authorized and affected employees, and retraining when machines or procedures change.
No machine-specific procedures, a generic program that does not identify actual energy sources, the annual periodic inspection never performed or never documented, and untrained or undocumented authorized employees.
You have 15 working days from receipt to file a Notice of Contest. Miss it and the citation becomes a final order that cannot be appealed.
1910.147(c)(6) requires a periodic inspection at least annually, certified in writing, identifying the machine, the date, the employees included, and the person performing the inspection. Employers who perform the inspection but never certify it in writing are cited as if they never did it.
If a trained employee violated a known rule, OSHA recognizes an unpreventable employee misconduct defense. It requires four elements: an established work rule designed to prevent the violation, adequate communication of that rule to employees, steps to discover violations, and effective enforcement when violations are found. Employers routinely satisfy elements one, three, and four and fail on element two, because they cannot prove the exposed worker received the briefing.
Generally yes. A single generic procedure is acceptable only in narrow circumstances where machines have a single energy source that is readily identified and isolated, and no potential for stored energy. Most facilities do not qualify.
15 working days from the date you receive the citation. Within that window you can file a Notice of Contest, request an informal conference with the OSHA Area Director, or accept the citation and certify abatement. After 15 working days an uncontested citation becomes a final order of the Occupational Safety and Health Review Commission and is no longer appealable.
Accepting is usually appropriate when the violation clearly occurred and the penalty is proportionate. An informal conference is often the better middle path: it costs nothing, it is scheduled quickly, and Area Directors have authority to reclassify violations, adjust penalties, and extend abatement dates. Contesting makes sense when you dispute the facts, the classification, or you can establish an affirmative defense. Consult an attorney for willful or repeat citations, or where an injury occurred.
See the plain-English summary above. The citation itself lists the specific subsection cited, which narrows what OSHA is alleging you failed to do. Read that subsection before drafting anything, because your response should address that subsection and not the standard in general.
For each violation you accept, you must certify in writing that the hazard was corrected, including the date and a description of the correction. Serious, willful, and repeat violations generally require supporting documentation such as photographs, receipts, or training records. OSHA may also require abatement to be posted where affected employees can see it.
For 2025 the federal maximum is $16,550 per serious violation and $165,514 per willful or repeat violation. Penalties are proposed per violation, so multiple instances multiply quickly. OSHA considers employer size, good faith, and citation history when setting the final amount, and state-plan states may apply different schedules.
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