Every LOTO program starts the same way: a plant realizes the binder is thin, or a near-miss happens, or the insurer asks for the file. What follows is the hard part — not the theory of 1910.147, but the sequence of actually building the thing from nothing, in an order that protects people while it comes together.
This guide is that sequence, in seven steps, with a 90-day starter plan at the end. It assumes no existing program — only a commitment and a person with authority to close gaps.
Step 1: Scope it — decide what is in and what is out
Start with a defensible inventory, not a vague ambition. List every machine where servicing could cause unexpected energization or stored-energy release — then decide what the program covers. Use the scope and exemption guide to draw the line honestly: cleaning inside guards and jam clearing usually count; narrow exceptions like true cord-and-plug under exclusive control usually do not.
For each machine record: asset ID, name and model, location, the servicing tasks performed, and the energy families present. Include contractors and temporary workers in scope from day one — they are not an add-on, they are a requirement.
Step 2: Assess the energy on each machine
Before you can write a procedure, you have to know what is on the machine. Run a proper energy assessment on each inventoried asset: trace every energy source, name every isolation point with its exact label, and identify stored energy that survives isolation — capacitors, accumulators, springs, gravity, heat.
Record the results as an energy table per machine: energy type, magnitude, isolation point, lockout device needed, stored-energy release and verification. That table is the skeleton of every procedure you are about to write.
Step 3: Write procedures — start with the highest risk
Do not write 200 procedures before anything is usable. Prioritize by hazard and servicing frequency and write the top machines first, using the OSHA-aligned template and the how-to guide. Every procedure needs named isolation points, magnitudes, stored-energy steps, and a verification step — the details that survive an audit.
Review each draft at the machine with the authorized employees who will use it. The floor will find the wrong breaker number and the missing pneumatic drop that the office never will.
Step 4: Select and procure the devices
The procedures name the isolation points; the hardware makes them lockable. Use the device guide to size the kit to your actual breakers, valves, plugs, and disconnects — not a generic catalog bundle.
Budget the non-negotiables: a personal keyed-different lock per authorized employee, device-specific lockouts for every isolation point in the procedures, hasps and a group lockbox for crew jobs, standardized tags, and department lock stations so nothing lives in a toolbox.
Step 5: Train by role and certify it
Training is where programs go from written to real. Deliver role-based training: full isolation skill for authorized employees, purpose-and-prohibition for affected employees, hands-off awareness for everyone else — plus the tag-limitation topics wherever tags are used.
Certify every session with names and dates. Use the toolbox talk outline for the refreshers, and schedule retraining on the legal triggers: change, new machines, procedure revisions, and deviations found in inspections.
Step 6: Run the annual loop
A program is not a project that finishes; it is a loop. Each procedure needs a periodic inspection at least annually by an authorized employee who does not use it, with the certification naming the machine, date, employees, and inspector. Deviations get corrected and retraining happens where needed.
Between annuals, run the compliance checklist quarterly and review the four program metrics monthly — coverage, inspection timeliness, deviations closed, and near-misses. The loop is what keeps the program from decaying.
The loop keeps the program from decaying. Follow Tegis on Google for program-building checklists.
Step 7: A 90-day starter plan
Here is the whole sequence on a calendar. Adjust owners to your plant, but keep the order — scope before assessment, assessment before procedures, procedures before training:
| Timeline | Work | Owner |
|---|---|---|
| Days 1–14 | Equipment inventory; scope decision; program owner appointed | EHS / maintenance manager |
| Days 15–45 | Energy assessment on top-risk machines; first procedures drafted and walked at the machine | Authorized employees + safety |
| Days 46–60 | Devices procured and kitted; role-based training delivered and certified | Maintenance + HR/EHS |
| Days 61–90 | Procedures published at the point of work; first inspection cycle kicked off | Program owner |
| Ongoing | Monthly metrics; quarterly checklist; annual inspections on schedule | Program owner |
Key takeaways
- Scope first: a real equipment inventory decides what the program must cover — and what it may not.
- Assess energy before writing anything; the energy table is the skeleton of every procedure.
- Write high-risk machines first and review every draft at the machine with the people who use it.
- Size the hardware to your actual isolation points and train by role with named, dated certifications.
- A program is a loop — monthly metrics, quarterly checklist, annual inspections — not a one-time project.
Frequently asked questions
Does a small business need a full written LOTO program?
Yes. 1910.147 applies to any servicing of equipment with hazardous energy, regardless of size — the program can be short, but it must exist, match the floor, and cover procedures, training, and inspections. A small team with a handful of machines can hold the whole thing in a well-built folder.
How many procedures do we need?
One per machine that needs one. Equipment with multiple energy sources, stored energy, or isolation that does not fully de-energize it needs a machine-specific procedure; identical single-source machines may share one that names them all. See the template guide for the grouping rules.
Who should run the program?
One program owner with real authority — typically EHS or maintenance leadership — who can stop work, budget for devices, and drive the annual loop. Ownership without authority is why programs stall after the first push.
How much does a LOTO program cost to build?
The bulk is labor: assessments, procedure writing, and training. Hardware is the visible line — personal locks, device-specific lockouts, hasps, and stations, usually modest per machine. Track the cost against a single serious violation (over $16,000) and the program pays for itself defensively on day one.