Avoiding OSHA’s Top LOTO Pitfalls: A 2025 Roadmap to Safer Maintenance & Compliance
Lockout/Tagout (LOTO) remains one of OSHA’s most frequently cited violations year after year. In the fiscal year 2024, LOTO ranked #6 with 2,443 total violations (down slightly from 2,539 in 2023). Of these, five key LOTO sections led the list of most-cited deficiencies:
- 1910.147(c)(4): Energy control procedure
- 1910.147(c)(7): Training and communication
- 1910.147(c)(6): Periodic inspection
- 1910.147(c)(1): Establishing an energy control program
- 1910.147(d): Application of control
At Grace, we have always focused on innovative technologies and training solutions to help employers maintain compliance and keep their teams safe. Below, we look at five essential tools—both physical products and programmatic strategies—to help you avoid the top five LOTO pitfalls in 2025.
1. Establish Clear & Accessible Energy Control Procedures
(Addressing 1910.147(c)(4)) – 738 violations
- Violation Recap: This OSHA section requires employers to develop, document, and utilize procedures for the control of potentially hazardous energy.
- Why It’s Cited: Inadequate or poorly documented procedures can lead to confusion about the correct methods for isolating energy sources, increasing the risk of accidental energization.
Countermeasure:
- Standardize Written Procedures: Develop step-by-step LOTO instructions for each piece of equipment. Make sure they are accessible and easy to follow.
- Use Permanent Electrical Safety Devices (PESDs): Voltage indicators provide a visual representation of voltage presence before any panel is opened. Test points allow qualified personnel to test for absence of voltage with their multimeters. This helps workers verify the effectiveness of their LOTO procedures quickly and safely.
- Proxxi Band: This wearable device can serve as a secondary, proactive alert system. It is designed to detect electrical fields and notify the wearer, reinforcing safe work practices and verifying that energy has truly been isolated before proceeding.
2. Provide Comprehensive Training & Communication
(Addressing 1910.147(c)(7)) – 477 violations
- Violation Recap: Employers must train employees to understand energy control procedures, the purpose of each step, and the importance of compliance.
- Why It’s Cited: Incomplete or inconsistent training leads to employees who are either unaware of the correct LOTO protocols or do not fully understand how to execute them properly.
Countermeasure:
- Tailored Training Programs: Offer both general and equipment-specific LOTO training. New employees should be trained on the fundamentals, and all employees must receive refresher trainings regularly.
- Interactive & Multimedia Approaches: Consider using real-life simulations, video-based training modules, or e-learning platforms to maintain engagement.
- PESDs as a Training Aid: Demonstrate how to use voltage indicators and test point PESDs during training sessions so employees learn to check for presence or absence of voltage effectively. Hands-on training helps employees become more competent and confident in LOTO processes.
3. Conduct Regular & Thorough Periodic Inspections
(Addressing 1910.147(c)(6)) – 377 violations
- Violation Recap: OSHA requires employers to inspect their energy control procedures at least annually to ensure they are being followed and remain effective.
- Why It’s Cited: Employers sometimes fail to conduct regular inspections or don’t document inspections thoroughly, resulting in persistent and unnoticed deficiencies.
Countermeasure:
- Scheduled Audits: Integrate inspections into your maintenance calendar so they are never overlooked. Assign clear responsibilities—who will inspect what, and when.
- Document All Findings: Keep a written record (or digital log) of any issues found during inspections, as well as corrective actions taken. A well-documented inspection process helps you track improvements and maintain compliance.
4. Establish & Maintain a Robust Energy Control Program
(Addressing 1910.147(c)(1)) – 210 violations
- Violation Recap: Employers must develop a program that includes energy control procedures, employee training, and periodic inspections.
- Why It’s Cited: Many companies have ad-hoc LOTO measures but fail to create a comprehensive, written program that ties procedures, training, and inspections together.
Countermeasure:
- Create a Holistic LOTO Policy: Your policy should clearly outline roles and responsibilities, types of energy sources, specific lockout/tagout devices, verification methods, and steps to follow in an emergency.
- Incorporate GracePESDs:
- Voltage Indicators: Enable employees to visually confirm zero energy.
- Safe-Test Point: Provides a touch-safe test point to use a meter without direct exposure to live parts.
- ChekVolt: Combines the benefits of a voltage indicator and test points into one device, simplifying your overall LOTO process.
- Leverage Proxxi Band: Add an extra layer of personal safety with a wearable device that alerts users if they approach energized equipment, promoting consistent compliance with your program’s procedures.
5. Ensure Proper Application of Control
(Addressing 1910.147(d)) – 203 violations
- Violation Recap: This section outlines the sequence and actions needed to isolate hazardous energy, attach lockout/tagout devices, release any stored energy, and verify isolation.
- Why It’s Cited: Even with procedures in place, employees sometimes skip or rush steps—especially the verification step, which is crucial for worker safety.
Countermeasure:
- Follow a Step-by-Step Checklist: Standardize the LOTO process to remove guesswork. Emphasize the “verify isolation” step before anyone starts work.
- GracePESDs for Verification:
- Voltage Indicators: Quickly confirm no voltage is present inside the panel.
- ChekVolt: Allows for both indication and measurement in one tool, making the verification process faster and safer.
- Proxxi Band as a Last Line of Defense: If an employee accidentally enters a potentially energized zone or the system is re-energized unexpectedly, the band can give an immediate alert.
Staying ahead of OSHA’s Top 10 Violations list is about more than just avoiding fines—it’s about protecting your greatest asset: your workforce. By implementing a well-rounded approach that includes comprehensive procedures, ongoing training, routine inspections, robust energy control programs, and verified application of control, you can dramatically reduce the risk of LOTO-related incidents.
We’re dedicated to helping you build a safer, smarter, and more productive workplace. From our GracePESDs product lines that simplify LOTO voltage verification to cutting-edge wearable technology like the Proxxi Band, our solutions empower you to meet and exceed OSHA standards.
As we look toward 2025, now is the time to invest in these essential tools and practices—ensuring your organization’s safety culture remains second to none!
Ready to take your LOTO and electrical safety strategies to the next level? Download our eBook, Electrical Safety by Design: Save Lives. Improve Productivity, and discover how to incorporate PESDs into your program.
You’ll gain expert insights on hazard mitigation, compliance with OSHA and NFPA 70E, and innovative ways to streamline maintenance tasks. Don’t miss out on this essential guide to elevating safety and productivity in your facility!