Every year OSHA publishes its list of most-cited standards. In the final FY2025 data, lockout/tagout (29 CFR 1910.147) ranked No. 4 with 2,177 federal violations — up from No. 5 the year before — and within manufacturing it routinely leads the charts. Plastics manufacturers and machine shops topped the industries cited. It is not exotic machinery causing this. The violations are almost embarrassingly ordinary: procedures that do not exist, procedures that do not name isolation points, annual inspections that never happened.
That ordinariness is the useful part. If thousands of facilities get cited for the same handful of failures, then the same handful of fixes moves you off the list. This guide walks through what inspectors actually write up, what citations cost in approximate dollar terms, and what a defensible program looks like before an inspector ever asks.
Why LOTO keeps topping the citation list
Three forces keep 1910.147 at the top of the charts. First, the standard applies to nearly every industrial employer — any servicing of machines with hazardous energy is in scope, so the exposure base is enormous. Second, compliance is document-heavy: procedures, training, certifications, and annual inspections all must exist and be retrievable, and paper systems decay quietly. Third, OSHA frequently arrives after an amputation, unexpected start-up, or worker complaint — and a post-incident inspection surfaces every gap in the file, not just the one that caused the injury.
The result: most LOTO citations are failures of administration, not of effort. Plants are not being cited for inventing new ways to skip lockout — they are being cited for missing paperwork, missing specificity, and missing follow-through.
The violations inspectors write most
Citation patterns repeat across industries. These are the most common 1910.147 failures, roughly in order of frequency:
- No machine-specific procedures — or generic procedures that say "isolate all energy" without naming a single isolation point
- Machines with multiple energy sources serviced under a single-isolation assumption
- No periodic (annual) inspection of energy control procedures, or inspections without the required certification
- Training failures: employees performing servicing without authorized-employee training, affected employees never briefed on what locks mean
- Failure to isolate every energy source in the field — the stored pneumatic line, the gravity-fed conveyor section, the capacitor bank
- Locks and tags skipped during minor servicing, or shared locks instead of personal locks
- No procedures for contractor or group lockout situations
- Machine-specific procedures that exist in an office but are not available where the work happens
What violations cost (approximate penalties)
Current federal maximums — unchanged for 2026, when OSHA published no inflation adjustment — are $16,550 per serious, other-than-serious, or posting violation; $165,514 per willful or repeated violation (with a $11,823 minimum for willful); and up to $16,550 per day for failure to abate past the deadline. Confirm the current schedule at osha.gov before quoting figures.
Two mechanics matter more than the headline numbers. First, citations can be per-machine: a facility with ten machines and no procedures can generate ten serious violations in a single inspection. Second, proposed maximums are not what most employers pay — gravity, employer size, good faith, and history all reduce the figure, and settlements cut further (the average federal serious-violation penalty actually paid runs under $5,000). Budget the maximum; expect negotiation — but expect a follow-up inspection and an OSHA history either way.
| Violation type | Maximum (federal, 2026) |
|---|---|
| Serious / other-than-serious / posting | $16,550 per violation |
| Willful or repeated | $165,514 per violation (min $11,823 willful) |
| Failure to abate | $16,550 per day past the deadline |
$16,550 per serious violation, per machine. Follow Tegis on Google so the next penalty update finds you first.
The costs that never show up in the citation
The fine is the smallest line item. An unexpected start-up injury brings medical costs, OSHA inspections, possible legal action, increased workers’ compensation premiums, equipment damage, and downtime while the machine and the program are both reviewed. Insurers increasingly ask for LOTO program evidence at renewal; a thin file is now a pricing event, not just a compliance event.
There is also the human arithmetic OSHA itself publishes: compliance with the LOTO standard prevents an estimated 120 fatalities and roughly 50,000 injuries every year in the United States. The citation list is a lagging indicator — every entry is a facility where something already went wrong or almost did.
How inspections actually find LOTO violations
Inspectors rarely open with the procedure binder. They walk the floor, look for machines under service, and ask the tech doing the work to explain the isolation. The questions that generate citations: Which procedure are you following? Can I see it? Show me the isolation points. What about this pneumatic line? Who verified zero energy, and how?
Then come the employee interviews — authorized employees asked to walk through their training, affected employees asked what the locks mean. Finally, the paper: training records, the annual inspection certifications, the written program. A plant that passes the floor test but fails the file test still gets cited. Both halves have to be real.
A prevention sequence that maps to the citations
Work the list from the top, because the citations do. Machine-specific procedures for every multi-energy machine first — with named isolation points, magnitudes, and verification steps. Then periodic inspections with complete certifications. Then role-based training with records. Then field discipline: personal locks, full isolation, stored-energy release, and procedures available at the machine.
None of this requires heroics — it requires a system that makes the correct action the easy action. That is the actual gap behind most LOTO citations: the correct behavior was harder than the shortcut. Programs that put the current procedure one scan away at the asset close that gap more reliably than any poster campaign ever has.
Key takeaways
- LOTO ranked No. 4 in OSHA’s FY2025 most-cited list (2,177 violations) — and routinely leads within manufacturing.
- The dominant violations are administrative: missing machine-specific procedures, no annual inspections, training gaps.
- Penalties scale per violation and per machine; willful or repeated findings approach six figures each (amounts adjust annually).
- Inspectors test the floor first (can the tech show the procedure?) and the file second (records and certifications).
- The cheapest citation is the one your own audit writes up first — inspect yourself before OSHA does.
Frequently asked questions
What is the OSHA penalty for a lockout/tagout violation?
Current federal maximums (unchanged for 2026): $16,550 per serious violation, $165,514 per willful or repeated violation, and up to $16,550 per day for failure to abate. Citations can be issued per machine, and gravity, size, good faith, and history reduce the proposed figure — most settled penalties land well below the maximum. Check osha.gov for the current schedule.
Can OSHA cite us per machine for missing procedures?
Yes. Where several machines lack required machine-specific procedures, OSHA may propose a separate violation for each. A ten-machine gap is potentially ten citations, which is why the multiplication effect — not the per-violation maximum — is what makes LOTO fines escalate quickly.
Do LOTO incidents have to be reported to OSHA?
Employers must report fatalities within 8 hours, and in-patient hospitalizations, amputations, and loss of an eye within 24 hours. Unexpected start-up injuries frequently fall into the amputation or hospitalization categories — which trigger the post-incident inspections where LOTO files get fully examined.
How often are OSHA penalty amounts updated?
Usually each January under the federal inflation-adjustment law — but not guaranteed. 2026 held flat at 2025 levels when no adjustment was published, so never assume this year’s number equals last year’s. Because the amounts move in most years, budget conservatively using the willful/repeated maximum rather than the serious-violation figure when you build the internal business case for program investment.
Which industries get cited most for LOTO?
In the FY2025 federal data, plastics products manufacturers and machine shops led the industries cited under 1910.147. The broader lesson: any sector with frequent servicing of multi-energy equipment — manufacturing, food processing, and metals especially — sits high on the list, because exposure volume drives citation volume.