Last Updated: April 7, 2026
OSHA 29 CFR 1910.147 requires a lockout or tagout device at every energy isolation point during equipment servicing. Tagout tags must show the authorized employee's name, application date, and a warning legend such as "Do Not Energize." OSHA cited 1910.147 violations 2,443 times in FY2024, ranking it 7th on the agency's Top 10 most-cited standards list.
Your maintenance crew is servicing a panel. Someone else comes in and energizes it. That's exactly the scenario OSHA 29 CFR 1910.147 — the Control of Hazardous Energy standard — was written to prevent. Proper lockout/tagout labels are the frontline defense against accidental re-energization. When they're missing, illegible, or non-compliant, your crew is exposed — and OSHA will find it.
This guide covers what the 1910.147 standard requires for lockout/tagout labels, what information must appear on every tag, when lockout versus tagout applies, and the most common labeling violations inspectors catch. Get these details right and you protect your crew and stay off OSHA's citation list.
What Does OSHA 1910.147 Actually Require for Lockout/Tagout?
OSHA 29 CFR 1910.147 requires employers to establish an energy control program before anyone performs maintenance or servicing on equipment capable of unexpected energization. The standard covers all energy sources: electrical, hydraulic, pneumatic, chemical, thermal, mechanical, and gravitational.
Three elements make up a compliant program:
- Energy control procedures — written, equipment-specific procedures documenting how to isolate each energy source
- Lockout/tagout devices — physical locks or warning tags applied at every energy isolation point during work
- Training and periodic inspections — annual revalidation that procedures work and employees understand them
When your crew services a circuit panel, compressor, or conveyor, every energy source must be isolated and labeled before work begins. Missing a single isolation point is a 1910.147(c)(4) violation — the most-cited subsection under the standard with 738 violations in FY2024 alone.
Takeaway: Every piece of serviced equipment needs a written procedure AND properly labeled lockout devices or tagout tags applied before work starts. Documentation and labeling are both required — one without the other is a violation.
Lockout vs. Tagout: When Does Each Method Apply?
Lockout is required when the energy-isolating device is capable of being locked. A lockout device is a physical mechanism — a padlock, hasp, or lockout hardware — that prevents the energy-isolating switch from moving to the "on" or "energized" position. Only the authorized employee with the key can remove it.
Tagout is permitted only when lockout is not feasible — when the equipment's energy-isolating device cannot physically accommodate a lock. A tagout tag is a prominent warning device that communicates "this equipment is isolated for maintenance." It does not physically prevent operation.
Per OSHA 1910.147(c)(3), if an energy-isolating device cannot be locked out, the employer must use a tagout system. However, OSHA explicitly treats lockout as the safer and preferred method.
Key Rule: If the equipment CAN accommodate a lock, a lock is required. Applying only a tagout tag to a lockable device is a violation of 1910.147.
AHJs (Authorities Having Jurisdiction) and state-plan OSHA agencies may impose stricter requirements — always confirm locally.
What Information Must Appear on a LOTO Tag?
Per OSHA 1910.147(c)(5)(ii), every tagout device must include:
- Warning legend — one of these five phrases: "Do Not Start," "Do Not Open," "Do Not Close," "Do Not Energize," or "Do Not Operate"
- Name of the authorized employee who applied the tag
- Date of application
Beyond the minimum requirements, best practice — and most compliant facility programs — also include:
- Employee department and contact number
- Reason for lockout (e.g., "Replacing motor bearings — Panel 4B")
- Estimated duration of work
Durability is a compliance requirement, not a preference. Under 1910.147(c)(5)(ii)(C), tags must withstand environmental conditions at the point of application — moisture, UV exposure, corrosives, temperature extremes. A tag that fades, tears, or becomes illegible mid-job is a compliance failure. Attachment hardware must be non-reusable, self-locking, and require a minimum of 50 pounds of force to remove.
Print Pro AZ's electrical safety labels and LOTO tags are printed on durable outdoor-rated materials that hold up in field conditions — not office-grade paper tags that deteriorate by the end of a workday.
Takeaway: Spec your LOTO tags for the actual environment. An indoor-grade tag on an outdoor enclosure will fail inspection and won't survive the job.
Energy Control Procedure Labels: What Goes on the Placard?
Under OSHA 1910.147(c)(4), every employer must develop a written energy control procedure for each piece of equipment. These aren't binder documents locked in the office — they need to be accessible at the point of work.
A compliant energy control procedure placard must cover:
- Steps to shut down, isolate, block, and secure the equipment
- All energy sources and their exact location (panel number, valve ID, hydraulic line)
- Type and magnitude of each energy source (voltage level, PSI, weight)
- Methods for restraining, blocking, or relieving stored energy (capacitor discharge, spring tension, gravity)
- Steps for re-energization after work is complete
Many facilities post a laminated procedure card on or near the equipment. Others use QR codes linking to a digital procedure. Either approach works — what matters is that the procedure is accessible to the authorized employee at the time of lockout.
Per 1910.147(c)(4)(ii), a written procedure may be waived only when the authorized employee's scope is limited to a single machine, the energy is electrical only, has a single energy source, the isolation point is visible from the work location, and the equipment is not capable of storing residual energy. This exemption is narrow and frequently misapplied — when in doubt, document it.
For facilities that need custom-printed energy control procedure labels and equipment placard tags, Print Pro AZ handles custom orders with your exact equipment IDs and isolation point details.
What Types of Labels Does an OSHA-Compliant LOTO Program Include?
A full lockout/tagout program uses several distinct label types — not just the red tag hanging on the lockout point:
| Label Type | Purpose | Required By |
|---|---|---|
| Lockout/tagout tag | Applied at the energy isolation device during work | 1910.147(c)(5) |
| Equipment hazard label | Permanently mounted to identify energy sources | OSHA 1910.145 / ANSI Z535 |
| Energy isolation point label | Marks location of each breaker, valve, or isolation device | ANSI Z244.1 best practice |
| Energy control procedure placard | Documents shutdown/restart steps at point of work | 1910.147(c)(4) |
| Arc flash label | Identifies arc flash hazard level at electrical panels | NFPA 70E 130.5 |
Arc flash labels and LOTO labels work together. When your crew performs lockout on an electrical panel, the arc flash label (required under NFPA 70E Section 130.5) communicates the incident energy level and required PPE before the lockout procedure begins. Missing either creates a compliance gap and leaves your crew uninformed about the hazard.
Print Pro AZ stocks pre-printed arc flash labels and custom electrical warning signs that meet OSHA 1910.145 and ANSI Z535 requirements alongside a full range of LOTO-compliant electrician labels.
For a deeper look at arc flash hazard levels and NFPA 70E labeling requirements, see Arc Flash Labels for Solar Installations: NFPA 70E Requirements.
The Most Common LOTO Labeling Violations OSHA Cites
OSHA cited 2,443 violations of 1910.147 in FY2024. The most frequent failures by subsection:
1910.147(c)(4) — Energy Control Procedure: 738 violations The procedure doesn't exist, isn't equipment-specific, or doesn't document all energy sources present.
1910.147(c)(7) — Training and Communication: 477 violations Employees weren't trained, or training wasn't documented for each authorized and affected employee.
1910.147(d) — Application of energy controls Lockout/tagout wasn't applied before servicing started — or it was removed before work was complete.
Common labeling-specific failures OSHA flags:
- LOTO tags missing the authorized employee's name or application date
- Tags not rated for the environment (paper tags on outdoor enclosures, unlabeled valve positions)
- Energy isolation points not labeled, so workers can't identify what to lock out
- Multiple energy sources (electrical + pneumatic) with only one isolated and labeled
Here's a scenario Print Pro AZ hears regularly: A contractor installs a new compressor, labels the electrical disconnect panel, and overlooks the pneumatic supply valve — no valve tag, no procedure card, no indication of stored pressure. OSHA inspects after an incident. The citation isn't just for the missing tag; it's for an incomplete energy control procedure that never identified the second energy source. Two separate violations, two separate fines, from one unlabeled valve.
Frequently Asked Questions
What does OSHA 1910.147 require on a lockout/tagout tag?
Per OSHA 29 CFR 1910.147(c)(5)(ii), every tagout device must display a warning legend — such as "Do Not Energize" or "Do Not Start" — the name of the authorized employee who applied it, and the date of application. Tags must withstand environmental conditions at the point of use and attach with a non-reusable fastener requiring at least 50 pounds of force to remove.
Can I use a tagout tag instead of a lockout device?
Tagout alone is permitted only when the energy-isolating device cannot physically be locked. Per 1910.147(c)(3), lockout is the required method whenever the equipment can accommodate a lock. Using only a tagout tag on a lockable device is a direct violation of 1910.147. Tagout tags provide warning — they do not physically prevent operation.
What is the difference between a lockout device and a tagout tag?
A lockout device physically prevents an energy-isolating switch from being moved to the "on" position — it uses a lock and key that only the authorized employee controls. A tagout tag is a labeled warning that communicates the equipment should not be energized but does not physically prevent it. Lockout is always preferred; tagout is the backup when lockout is not feasible.
How often does OSHA cite lockout/tagout violations?
OSHA cited 1910.147 violations 2,443 times in FY2024, placing it 7th on the agency's Top 10 most-cited standards list. The most-cited subsection was 1910.147(c)(4) — energy control procedures — with 738 violations. Lockout/tagout has appeared in OSHA's Top 10 every year for over a decade.
Do arc flash labels satisfy OSHA lockout/tagout label requirements?
No. Arc flash labels required under NFPA 70E Section 130.5 identify electrical hazard levels and required PPE — they are separate from LOTO tags. An arc flash label tells your crew what hazard is present and what PPE to wear before lockout begins. The LOTO tag is applied after energy isolation to communicate that the equipment is locked out and must not be energized. Both are required for a compliant electrical maintenance program.
Get Your LOTO Labels Right Before OSHA Does It for You
Lockout/tagout labels are compliance requirements with direct life-safety consequences. OSHA 29 CFR 1910.147 is clear: equipment-specific written procedures, labeled energy isolation points, and tagout devices that meet minimum content and durability standards. A missing name on a tag, an unlabeled valve, or a procedure that doesn't cover stored energy puts your crew at risk and puts you on OSHA's top-10 citation list.
Print Pro AZ carries OSHA-compliant lockout/tagout tags, arc flash labels, and custom energy control labels built for industrial field conditions. Shop electrical safety labels →
Running a commercial facility that needs a full LOTO label program? Send us your equipment list →
Brent Hanke | Print Pro AZ | (602) 649-5305 | b.hanke@printproaz.com Brent Hanke is the founder of Print Pro AZ, supplying NEC-compliant labels to contractors across the country.