1910.147 is one of OSHA's Top 5 citations year after year. It governs the control of hazardous energy — electrical, mechanical, hydraulic, pneumatic, chemical, thermal — during service and maintenance. ARKVOS documents authorized-employee training and per-shift briefings.
Employers must (1) have written energy-control procedures for each machine, (2) train authorized, affected, and other employees, (3) conduct periodic (annual) inspections of each procedure, and (4) provide locks, tags, and devices.
Missing machine-specific procedures (1910.147(c)(4)), no periodic inspection records, inadequate training documentation for authorized employees, and group lockout failures.
ARKVOS-1 generates per-machine LOTO briefings tied to your energy-source inventory. Workers acknowledge with selfie + GPS at each authorized maintenance event. Annual periodic-inspection records are stored with cryptographic hashes.
$16,550 per serious. Common citation pattern: one citation per missing machine procedure plus one per untrained authorized employee — six-figure exposure is routine.
Multi-worker maintenance operations require group lockout protocols. ARKVOS tracks the primary authorized employee and each affected worker's acknowledgement.
Almost always. The narrow exception in 1910.147(c)(4)(i) — single-energy-source, fully de-energized by unplugging — covers very few real machines. ARKVOS-1 helps you draft per-machine procedures.
Authorized: actually performs the LOTO. Affected: operates the machine being serviced. Other: works in the area. Each tier has different training requirements — ARKVOS tracks the worker's tier and applies the right briefing.
Annually, an authorized employee (other than the one being inspected) must observe a representative LOTO procedure and certify the worker is performing it correctly. ARKVOS records the inspection event with selfie + GPS + SHA-256.
Not 1910.147 — construction uses 1926 Subpart K and S for electrical and equipment-specific lockout. The principles overlap but the standard is different.
Arkvos offers a free OSHA citation response generator. Upload the citation and get a formal response letter, a corrective action plan with dates, and a checklist of evidence to attach. Employers have 15 working days from receipt of a citation to contest it. Open the free citation responder.