Solo lockouts are the training scenario. Real outages are multi-employer, multi-shift affairs: your millwrights, a contractor crew, temp operators, and a night shift inheriting a job none of them started. OSHA 1910.147(f) exists for exactly this situation — and contractor and shift-change gaps are among the most cited and most dangerous LOTO failures.
This guide covers the outside-personnel rule, host and contractor duties, temp-worker joint responsibility, and the shift-change continuity method that keeps protection unbroken across handovers.
The outside-personnel rule: brief both ways
Under 1910.147(f)(2), whenever outside servicing personnel work on site, the on-site employer and the outside employer must inform each other of their respective lockout procedures — before work starts. The host explains site procedures, isolation points, and restrictions; the contractor explains how its crew will comply and any additions its program requires.
The host must also ensure its own employees understand and comply with the contractor restrictions. A common compliant pattern: host employees perform the isolation on familiar equipment, both sides verify, and contractor workers then assume control through personal locks on a group lockbox.
Host vs contractor: who owes what
Responsibilities divide by knowledge and control. The host — who knows the machines, the energy sources, and the site procedures — owns the site program, the machine-specific procedures, and the briefing. The contractor owns its crew competence: trained authorized employees, personal locks, and compliance with the agreed method.
Neither side can contract away its OSHA duty. If contractor workers are exposed in the cell with no locks because "the host has it covered," both employers are exposed at citation time.
Temp and staffing-agency workers
Staffing agencies and host employers are joint employers for LOTO. OSHA expects the host — best positioned, controlling the floor — to deliver site-specific procedures and role-based training: temp maintainers as authorized employees, temp operators near lockouts as affected employees, with the same protections as permanent workers.
The staffing agency must inquire about hazards, confirm the host program exists and covers its people, and act if the host falls short — up to pulling workers or delivering the training jointly. Generic safety videos do not satisfy the site-specific requirement.
Shift and personnel changes: overlap, never trust
Section 1910.147(f)(4) requires specific procedures for shift or personnel changes that keep protection continuous. The compliant pattern is overlap: oncoming authorized employees apply their personal locks to the group lockbox before off-going employees remove theirs. At no point is the equipment without a lock representing every exposed worker.
Document the exchange — who arrived, who left, when — and handle primary-employee rotation for multi-day outages with the same explicit, recorded handover. Leaving personal locks in place until the job completes is an accepted continuity method; pocketing keys "between shifts" is the failure the rule targets.
Multi-employer jobs need overlap, not trust. Follow Tegis on Google for handover templates.
What inspectors ask after an incident
Post-incident interviews go straight to the handover: show me the contractor briefing record, who was the primary authorized employee, whose locks were on the box at the time, how did the shift transfer protection. Missing briefing records, a crew working under one supervisor lock, and unwitnessed "verbal handovers" are the findings that turn an injury investigation into willful citations.
Close the loop with the compliance checklist: contractor briefing filed, group method documented, shift log entries complete, and every participant able to state which procedure they worked under.
Key takeaways
- Brief both ways before outside work starts — host procedures out, contractor compliance back, all documented.
- Temp workers get identical site-specific, role-based protection; joint employment means joint responsibility.
- Shift changes transfer by overlap: incoming locks on before outgoing locks off, every time, on record.
- One lock per exposed person across employers — no crew coverage, no "just holding the light" exceptions.
- Name the primary authorized employee for every multi-employer, multi-shift job in advance.
Frequently asked questions
Do contractors follow our LOTO procedure or theirs?
Both, reconciled in advance. The employers must inform each other of their respective procedures before work starts; in practice the host site procedures govern the equipment while the contractor ensures its crew is trained, locked, and compliant. The agreement — and the briefing — must be documented.
How do shift changes work during a lockout?
By overlap, never by trust: oncoming authorized employees apply their personal locks before off-going employees remove theirs, so protection is continuous. Record who arrived, who left, and when — including rotation of the primary-employee role on multi-day jobs.
Who trains temp workers on lockout/tagout?
Both joint employers share the duty, with the host delivering site-specific, role-based training and the staffing agency verifying hazards are covered and following up on gaps. Temp maintainers are authorized employees; temp operators nearby are affected employees.
Can the host isolation cover the contractor crew?
Host employees may perform the initial isolation on familiar equipment, but every exposed contractor worker must still apply a personal lock — typically to the group lockbox after verifying the isolation. Host locks alone covering a contractor crew is a classic cited failure.