OSHA 1910.147 — Lockout/Tagout, Documented

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.

The rule, in plain English

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.

Most-cited violation patterns

Missing machine-specific procedures (1910.147(c)(4)), no periodic inspection records, inadequate training documentation for authorized employees, and group lockout failures.

How ARKVOS documents compliance

Arkvos 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.

Penalty math

$16,550 per serious. Common citation pattern: one citation per missing machine procedure plus one per untrained authorized employee — six-figure exposure is routine.

Group lockout tracking

Multi-worker maintenance operations require group lockout protocols. ARKVOS tracks the primary authorized employee and each affected worker's acknowledgement.

Frequently asked questions

Do we need a written procedure for every machine?

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 helps you draft per-machine procedures.

What's the difference between authorized, affected, and other employees?

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.

What's a periodic inspection?

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 + record-integrity.

Does LOTO apply to construction?

Not 1910.147 — construction uses 1926 Subpart K and S for electrical and equipment-specific lockout. The principles overlap but the standard is different.

Already holding an OSHA citation?

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.

Factual anchors and primary sources

Arkvos separates product capabilities from regulatory requirements. For federal OSHA requirements, the primary authority is OSHA's current regulations and guidance. California construction employers should also review the applicable Cal/OSHA Title 8 requirements.

OSHA 29 CFR 1904.33 requires the OSHA 300 Log, annual summary, OSHA 301 Incident Report forms, and privacy case list if one exists to be retained for five years after the end of the calendar year they cover. Cal/OSHA Title 8 §1509(e) requires construction supervisors to conduct toolbox or tailgate safety meetings, or equivalent, with crews at least every 10 working days. Requirements vary by jurisdiction and work activity, so employers should verify the rule that applies to their facts.

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