15 working days
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LOTO is a frequent source of serious and repeat citations. Missing the contest window locks each item at face value.
29 CFR 1910FY top-10 cited · rank #61910.147
Cited under 1910.147 Lockout/Tagout? Here's your 15-day response plan.
1910.147 requires employers to control hazardous energy during servicing and maintenance with written energy-control procedures, locks/tags, and annual inspections.
Every facility with powered equipment needs LOTO procedures. Missing machine-specific procedures, untrained authorized employees, and skipped annual audits are the top findings.
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1910.147 · what's at stake
Why a Lockout/Tagout citation moves faster than you think.
Four deadlines and exposures every cited employer should have on a whiteboard by end of day one.
Per machine
Procedure specificity
Generic energy-control procedures don't satisfy 1910.147(c)(4). You need a written procedure for each machine type.
Annual
Periodic inspection
OSHA expects a documented annual audit of each energy-control procedure. Missing audits extend the violation.
Severity
Willful exposure
Amputation and fatality incidents often convert LOTO citations from serious to willful, with dramatically higher penalties.
Typical items
Sub-codes we see most under 1910.147.
If you were cited under 1910.147, your Form OSHA-2 likely references one or more of these. Your packet breaks each one down with deadlines, evidence needs, and an assigned owner.
- 1910.147(c)(1)No written energy-control program covering lockout/tagout procedures, training, and inspections.serious
- 1910.147(c)(4)(i)Machine-specific energy-control procedures not developed, documented, and used.serious
- 1910.147(c)(7)(i)Authorized, affected, and other employees not trained on LOTO procedures at initial assignment.serious
- 1910.147(c)(6)(i)No annual periodic inspection of each energy-control procedure.serious
Your actual citation will match one of these sub-codes exactly. The packet parses the CFR reference on your Form OSHA-2 and builds the correct item-level response.
Who on your team handles Lockout/Tagout abatement?
Abatement responsibility should never land on a single role. Here's how a typical citation splits:
Maintenance Lead
Machine-specific procedures, lock/tag hardware, lockbox management
EHS Manager
Written program, annual periodic inspection, program audit
HR / Training Lead
Authorized/affected employee training and refresher scheduling
Evidence OSHA typically wants to see
Written abatement certification usually requires documentation like this. Your packet generates the exact list for every cited item.
- Written energy-control program (dated)
- Machine-specific energy-control procedures (one per machine)
- Authorized employee training records
- Affected employee awareness-training records
- Annual periodic inspection documentation (per procedure)
- Photos of lockout hardware deployment on abated equipment
How it compares
Your options after a citation.
OSHA Action Packet isn't a replacement for an attorney on serious cases. It's the organized starting point most employers never build.
OSHA defense attorney
- Typical cost
- $5k–$15k retainer
- Turnaround
- Days to weeks
- What you get
- Legal strategy, contest filing, formal response
Compliance consultant
- Typical cost
- $3k–$8k
- Turnaround
- 1–2 weeks
- What you get
- Site walk, abatement plan, written report
Do it yourself
- Typical cost
- Your time
- Turnaround
- Unpredictable
- What you get
- Full control, high risk of missed deadlines
OSHA Action Packet
Best fit- Typical cost
- $349 flat
- Turnaround
- 2–5 minutes
- What you get
- Deadlines, evidence list, ownership map, exports
If your citation involves a fatality, willful violations, or significant penalty exposure, talk to an OSHA attorney. For most other citations, the gap isn't legal strategy. It's organization and speed.
Related standards
Often cited alongside this one.
Federal OSHA inspections rarely yield a single-standard citation. If you were cited under one of these, you were probably cited under the others too.
1910.212Top 10
Machine Guarding
Machine guarding is the classic source of amputation citations. Missing, modified, or bypassed guards are the most common findings.
See response guide
1910.178Top 7
Powered Industrial Trucks
Most forklift citations stem from operators who are uncertified, trained in-house without evaluations, or allowed to operate after a near-miss without re-evaluation.
See response guide
1910.147 · FAQ
Lockout/Tagout citation questions
How long do I have to contest a Lockout/Tagout citation?
Fifteen working days from the date you received the Citation and Notification of Penalty. The deadline is the same for every federal OSHA citation, regardless of standard. Miss it and the citation becomes a final order of the Occupational Safety and Health Review Commission. Penalties locked, abatement dates locked, right to negotiate gone.
Do I need a lawyer for a 1910.147 citation?
For citations involving a fatality, willful violation, or significant penalty exposure, yes, hire an OSHA defense attorney. For most citations under this standard, the gap isn't legal strategy. It's getting organized before deadlines pass: contest window, abatement dates per item, written certification for each abated condition. That's the work OSHA Action Packet automates.
What evidence does OSHA expect for abating 1910.147?
For Lockout/Tagout citations, OSHA typically wants: Written energy-control program (dated); Machine-specific energy-control procedures (one per machine); Authorized employee training records. The full list is generated per-item inside your packet based on what was actually cited on your inspection.
Who on my team handles Lockout/Tagout abatement?
Typical ownership is split across Maintenance Lead, EHS Manager, HR / Training Lead. Each packet assigns every cited item to a role and produces a per-owner worksheet you can hand off directly.
What if my citation bundles multiple standards?
That is the norm. Most federal OSHA inspections yield 3 to 12 items across several standards. Your packet covers every item. This page is just the standard-specific guide for one of them.
What does the packet actually include?
Executive PDF summary, per-item action table with deadlines and evidence, assigned-owner worksheets, calendar export (.ics), CSVs, and the full ZIP bundle. Preview is free. You only pay if you want the full packet.
Cited under 1910.147? Start your packet.
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