Almost every lockout/tagout training program and OSHA citation leans on two job titles that people routinely mix up: the authorized employee and the affected employee. Getting the distinction right matters because OSHA 1910.147 assigns each role different protections, different training, and different legal duties — and inspectors ask employees directly which they are.
In plain terms: authorized employees lock equipment out and service it. Affected employees operate the equipment — or work nearby — and need to understand what a lockout means and why they must never touch it. This guide defines each role, spells out the training OSHA requires, and untangles the gray areas that trip up real plants: contractors, group lockouts, and the operator who is also the maintenance tech.
The three roles OSHA defines
OSHA 1910.147 divides everyone at a facility into three categories, and every person on the floor falls into exactly one of them for any given servicing activity:
- Authorized employee — a person who locks out or tags out machines in order to perform servicing or maintenance. This is the person who applies the locks, follows the machine-specific procedure, and verifies zero energy. The equipment operator whose duties include servicing is an authorized employee.
- Affected employee — a person whose job requires them to operate or use a machine on which servicing is performed under lockout, or whose job requires them to work in the area where the servicing happens. They do not lock anything out; they must understand what lockout means and obey its prohibitions.
- Other employee — everyone else in the vicinity. Their entire duty is simple: locked-out equipment is off limits, and they must be instructed never to attempt to restart or re-energize it.
| Role | Who they are | What they must know |
|---|---|---|
| Authorized employee | Performs servicing and applies the locks | Recognize energy sources, isolate and verify zero energy, follow the machine-specific procedure |
| Affected employee | Operates the equipment or works in the area | What lockout means; never restart or remove a lock |
| Other employee | Works elsewhere in the facility | Locked-out equipment is off limits — never touch it |
Authorized employees: who qualifies and what they must be trained on
Authorized status is earned through training and demonstrated knowledge — not simply assigned. An authorized employee must be trained to recognize hazardous energy sources, understand the type and magnitude of energy on the machines they service, and know the methods of isolating and controlling that energy.
That means an authorized employee needs to be able to read the machine-specific procedure and execute it: notify affected employees, shut down, isolate, apply personal locks, release stored energy, and verify zero energy before work begins. When their duties change, or when equipment or procedures change, OSHA requires retraining — and the employer must certify that the training happened.
Affected employees: what they must understand
Affected employees need a different (and shorter) education: they must be instructed in the purpose and use of the energy control procedure, and in the prohibition against attempting to restart or re-energize machines that are locked out. They do not need to know how to isolate the equipment — only that a lock and tag mean hands off, always.
When tagout is used instead of lockout — rarer, but legal in specific cases — affected employees must also be taught that a tag is only a warning, that they must never remove or bypass it, and that tags can evoke a false sense of security. When lockout procedures are modified or a new hazard is introduced, affected employees get a refresher.
The gray areas that cause real problems
Real plants do not always fit the clean definitions. These are the situations inspectors probe most often — and how to handle them:
- The dual-role operator. An equipment operator who also performs servicing is an authorized employee when servicing and an affected employee when running the machine. Train for both roles and document both.
- Outside contractors. Under 1910.147(f)(2), the on-site employer and the outside employer must inform each other of their respective lockout procedures — before work starts. Your program needs a contractor LOTO briefing step, and your contractor needs to see the machine-specific procedure they will work under.
- Group lockout. When several workers service one machine, one authorized employee is designated to control the isolation, and every worker in the group applies a personal lock to the group lockbox or has the protection ensured by the group coordinator. Each person remains protected as if they applied their own lock.
- Shift changes. Procedures must specify how locks and tags transfer between shifts so equipment is never left with unclear protection. A documented shift-handover protocol is what inspectors look for.
- Working near, not on. A machine operator walking past a locked-out press is affected; a forklift driver delivering parts into the same cell is affected too. Area awareness training covers them both.
Contractors and dual-role gray areas trip up good plants. Follow Tegis on Google for more role-clarity guides.
Why inspectors care about the distinction
OSHA citations frequently combine two failures: an employee who performed servicing without authorized-employee training, and affected employees who were never told what the locks mean. When an inspector interviews workers, one of the first questions is "what does that lock mean to you?" — and the wrong answer becomes a citation.
The fix is procedural, not heroic: keep a training matrix that maps every employee to their role, deliver role-appropriate training on a schedule, and re-run it when equipment or assignments change. Record who was trained, when, on what, and who certified it — because the certification is the first document an inspector requests.
Key takeaways
- Authorized employees lock out and service; affected employees operate or work nearby and must obey the lock.
- Authorized training covers recognition, isolation, and verification — with retraining when equipment or duties change.
- Affected employees must know the prohibition: never restart or remove a lock. Tags are warnings only.
- Contractors require a two-way LOTO briefing before work begins — plan it into the job.
- Dual-role workers (operator/maintainer) must be trained and documented for both roles.
Frequently asked questions
Can someone be both an authorized and an affected employee?
Yes — and it is common. A maintenance tech who runs a machine between repairs is authorized when servicing it and affected when operating it. OSHA defines the roles per activity, not per person. Train and document both roles for dual-role employees.
Do contractors need to follow our lockout procedure?
Contractors must be informed of your lockout procedures and requirements, and you must be informed of theirs — this exchange is required by OSHA 1910.147(f)(2) before outside servicing begins. The host employer remains responsible for the site program and for confirming the contractor’s employees are protected.
Who trains affected employees, and how long does it take?
The employer is responsible for affected-employee training, typically delivered by EHS staff or supervisors. It is a focused briefing — the meaning of lockout devices, the prohibition on restarting, and tagout specifics if used — usually under an hour, refreshed when procedures or equipment change.
Is annual retraining required for authorized employees?
OSHA requires annual periodic inspection of each energy control procedure, and retraining for authorized employees whenever there is a change in machines, energy control procedures, or job assignments — plus whenever an inspection reveals deviations. Some employers fold an annual refresher into the audit cycle to keep both requirements on one calendar.
Can an affected employee remove a lock or tag?
No. Affected employees must never remove a lock or tag or attempt to restart locked-out equipment — that prohibition is the core of their training. Only the authorized employee who applied a lock removes it, other than through the documented emergency-removal procedure.