Energy control procedure is the phrase OSHA actually uses in 29 CFR 1910.147 for what most plants call a lockout/tagout (LOTO) procedure. Section 1910.147(c)(4) is titled "Energy control procedure": it is the machine-specific, step-by-step document that tells an authorized employee how to shut down, isolate, lock, and verify one piece of equipment.
If your plant says "LOTO procedure," inspectors, consultants, and insurers say "energy control procedure." Knowing both terms matters because citations, audit checklists, and vendor documents all use the formal one. This guide covers what (c)(4) requires, how the procedure differs from the written program, and what inspectors cite most often.
Energy control procedure vs. energy control program
The two terms are not interchangeable, and the standard separates them. The energy control program (1910.147(c)(1)) is the employer’s overall system: the written policy, the training, the devices, the inspections, and the procedures themselves. An energy control procedure (1910.147(c)(4)) is one document inside that program, covering one machine or one group of identical machines.
A useful shorthand: the program is the binder, the procedures are the pages. OSHA cites employers for missing procedures far more often than for a missing program document, which is why the distinction matters in practice.
| Energy control program | Energy control procedure | |
|---|---|---|
| Citation | 1910.147(c)(1) | 1910.147(c)(4) |
| What it is | The employer’s overall written system | One machine-specific document |
| Scope | Whole facility | One machine or identical group |
| Includes | Policy, training, devices, inspections | Shutdown, isolation, lock, verify steps |
What 1910.147(c)(4) requires the procedure to contain
The standard lists the required content. OSHA’s Appendix A to 1910.147 expands it into a recommended format, and most defensible procedures follow both:
- A statement of intended use: the scope and purpose of the procedure, and the equipment it covers
- The specific steps to shut down, isolate, and secure the machine, in order
- The steps for placing, removing, and transferring lockout/tagout devices, and who is responsible at each step
- The requirements for testing the machine to verify the isolation actually worked
- Machine-specific identification: equipment ID and location, and every energy source with type and magnitude
One procedure per machine, not one per plant
This is where most citation exposure lives. A generic "isolate all energy before service" notice is not an energy control procedure. Each machine with multiple energy sources, stored energy, or more than one isolation point needs its own document that names the exact panel, breaker, valve, or disconnect.
The narrow exception: identical machines with the same energy types, the same magnitudes, the same isolation methods, and the same lockout devices may share one procedure, provided it clearly identifies every machine it covers. Any machine that deviates needs its own. See the procedure template for the structure.
One procedure per machine: recommend Tegis Safety on Google if this clarified the rule.
Where the term shows up in practice
Once you know the formal term, it appears everywhere. OSHA citations read "failure to develop, document, and utilize energy control procedures"; that is 1910.147(c)(4). The annual periodic inspection under 1910.147(c)(6) reviews "each energy control procedure." Consultant proposals, insurer questionnaires, and audit software fields all use it.
Practically, that means your program documentation should use the phrase somewhere, for example "energy control procedure (lockout/tagout procedure)", so an inspector searching your records for the standard’s language finds a match. It costs nothing and removes an easy question.
Who writes them, and how long it should take
Procedures are written by EHS staff, maintenance leads, or consultants, but they must be verified in the field. An energy control procedure written at a desk is a guess: breaker numbers get misremembered, a second pneumatic feed gets missed, an accumulator nobody mentioned quietly holds pressure.
The workable method is a walkdown with the people who service the machine: identify every energy source, photograph each isolation point from the worker’s standing position, and record the discipline of the energy assessment. A single-energy machine takes minutes; a multi-energy machine with stored energy takes an hour. Either way it is faster than the citation it prevents.
Deficiencies inspectors cite most
Patterns repeat across inspections. Check your procedures against this list:
- No machine-specific procedure at all: the most-cited LOTO violation
- Generic procedures with no named isolation points or no magnitude values
- Missing stored-energy release steps for accumulators, springs, capacitors, or suspended loads
- No verification step, or a verification that checks only one energy source
- Procedures that exist in an office but not at the point of work
- No documented periodic inspection tying back to the procedure
Keeping procedures current
An energy control procedure is a living document, not a one-time deliverable. It needs updating when the machine, its energy sources, or its isolation points change, and it must be reviewed at least annually through the periodic inspection required by 1910.147(c)(6).
The failure mode is always the same: the equipment changes, the document does not, and the printed copy at the machine teaches the wrong isolation point with confidence. That is the gap procedure software closes: one current version per machine, reachable by a QR scan at the asset.
Key takeaways
- Energy control procedure is OSHA’s formal term for a machine-specific LOTO procedure (1910.147(c)(4)).
- The program is the whole system (c)(1); procedures are the individual documents inside it (c)(4).
- Required content: scope, shutdown, isolation, device placement and removal, verification testing, and machine identification.
- One procedure per machine; identical machines may share only under narrow, documented conditions.
- Keep procedures current and inspected annually; a stale document is worse than none.
Frequently asked questions
Is an energy control procedure the same as a lockout/tagout procedure?
Yes. "Energy control procedure" is the term OSHA uses in 29 CFR 1910.147(c)(4); "lockout/tagout procedure" is the everyday name for the same machine-specific document. Using both terms in your program records helps inspectors find what they are looking for.
Do I need a written energy control program as well as procedures?
Yes. 1910.147(c)(1) requires the written program, and 1910.147(c)(4) requires documented procedures for the machines it covers. The program can be brief, but it must exist and match what actually happens on the floor.
How many energy control procedures do I need?
One per machine that requires lockout, unless machines are identical in energy types, magnitudes, isolation methods, and lockout devices, in which case one procedure may cover the group if it identifies every machine it applies to. Multi-energy machines always need their own.
Are energy control procedures required for cord-and-plug equipment?
Only if the exemption fails. Cord-and-plug equipment is exempt when unplugging fully removes the hazard and the plug stays under the servicing employee’s exclusive control. If someone else could reconnect it, or stored energy remains, a procedure is required.
Can a consultant write our energy control procedures?
Yes, and many plants start there when internal capacity is limited. The facility must still review, approve, and maintain the program, and the procedures should be built from a walkdown with the people who service the equipment, not from documents alone.