Lockout/tagout (LOTO) procedures exist for one reason: to keep workers safe when they service or maintain equipment that could unexpectedly start up or release stored energy. When LOTO programs are designed or followed correctly, they work. When they're not, the consequences can be devastating — amputations, crush injuries, electrocutions, and fatalities. For Ohio employers, understanding where LOTO programs commonly break down is the first step toward making sure your workplace isn't next in an OSHA investigation.
No Written Program — or a Program That Sits in a Drawer
OSHA's Control of Hazardous Energy standard requires employers to have a written energy control program along with equipment-specific procedures for machinery that has more than one energy source or where the steps aren't immediately obvious. Many employers either skip the written program entirely or create one and never revisit it. A program that doesn't reflect your actual equipment, your actual facility layout, or your current workforce is almost as dangerous as having nothing at all.
Missing machine-specific procedures: A generic LOTO checklist is not enough when different pieces of equipment have different lockout points, stored hydraulic pressure, or multiple electrical disconnects.
Outdated documentation: If you've added, replaced, or modified equipment since your program was last reviewed, your written procedures need to catch up.
Inadequate Training — and No Retraining
LOTO training isn't a one-time event. OSHA requires authorized employees (those who perform lockout) and affected employees (those who work in areas where LOTO is used) to be trained differently. Both groups need to understand their specific roles. Common training failures include:
Training conducted only at hire with no periodic refreshers
No retraining after a near-miss, an incident, or a procedure change
Workers who transfer to new roles but never receive updated LOTO instruction
Training delivered only in English in a multilingual workforce
If an employee can't demonstrate they understand the procedure for a specific piece of equipment, they shouldn't be working on it unsupervised.
Shortcuts That Become Habits
Some of the most dangerous LOTO failures aren't about paperwork — they're about culture. When supervisors tolerate shortcuts or even model them, workers learn quickly that the written procedure is optional. Watch for these patterns on your floor:
Relying on blocking or wedging instead of locking out: Physically restraining a machine part is not a substitute for de-energizing and locking out the energy source.
Using one lock for group work: Each authorized employee working on equipment must apply their own personal lock. One lock for a crew of three leaves two workers exposed.
Skipping verification: After locking out, employees must verify that the energy has actually been isolated — by attempting to start the equipment or testing for residual energy — before beginning work.
Removing another worker's lock: This should never happen outside of a documented procedure for a lost or abandoned lock. No exceptions.
Overlooking Non-Electrical Energy Sources
Electricity gets the most attention, but LOTO applies to all forms of hazardous energy — hydraulic, pneumatic, thermal, chemical, gravitational, and mechanical stored energy. A press with a suspended ram, a pneumatic line that hasn't been bled, or a pipe that hasn't been fully depressurized can injure or kill just as quickly as a live electrical circuit. Make sure your procedures account for every energy source on every piece of equipment, not just the ones with an obvious on/off switch.
If you're not confident your LOTO program would hold up to an OSHA inspection — or more importantly, to a real incident — the team at Surety HR can help you review your procedures, close the gaps, and build a training approach that actually sticks. Reach out to us to get started.
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