Procedure specificity
The hard work is usually developing or refreshing machine-specific procedures that match the actual energy sources and shutdown sequence.
1910.147 requires employers to control hazardous energy during servicing and maintenance with written procedures, locks or tags, training, and annual inspections. In practice, citations here usually turn into a machine-by-machine abatement project with procedure cleanup, audits, and maintenance follow-up.
Facilities with multiple machines often rely on generic procedures or informal practices. OSHA then finds missing procedure detail, skipped annual audits, and training records that do not match the equipment actually serviced.
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1910.147 · what usually follows
Contest timing can matter, but most employers still need to fix hazards, gather proof, line up Owner Handoff, and prepare written closeout support.
The hard work is usually developing or refreshing machine-specific procedures that match the actual energy sources and shutdown sequence.
Closeout often depends on written procedures, annual inspection records, authorized-employee lists, and training logs tied to the right equipment.
Maintenance, EHS, and the training lead usually each own part of Lockout/Tagout abatement, so the handoff has to be explicit.
Matched cases include energy-control procedures, equipment inventory, annual inspection, and training-log files, with machine-guarding support when needed.
Typical items
If you were cited under 1910.147, your Form OSHA-2 likely references one or more of these. The packet breaks each one down with abatement steps, proof needs, and an assigned owner.
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.
Abatement responsibility should never land on a single role. Here's how a typical citation usually 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
Written closeout support usually requires documentation like this. Your packet generates the exact list for every cited item.
Template Packs
When those issue types appear in the packet, the full product includes downloadable files you can hand off internally, fill in, and add to your closeout package.
Included when matched
Energy-control procedures, equipment inventory, inspections, and training logs.
Included when matched
Machine inventory, guarding inspection checklist, photo log, and signoff sheet.
The exact template set depends on the actual sub-items on your citation, not just the top-line standard code.
How it compares
OSHA Action Packet isn't a replacement for an attorney on serious cases. It's the organized starting point most employers never build.
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
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.
Guarding issues are visible, and OSHA can document multiple machines in one visit. The follow-up work usually includes hardware correction, before-and-after proof, and lockout coordination.
See abatement guide
Forklift programs break when operators change, evaluations are not documented, or pre-shift checks are handled informally. OSHA can usually see those gaps quickly from interviews, records, and truck condition.
See abatement guide
1910.147 · FAQ
Yes, if the receipt date still keeps the federal 15-working-day window open. But even when the contest window is gone or unclear, the main work usually remains abatement, proof collection, Owner Handoff, and written closeout support.
For citations involving a fatality, willful violation, or significant penalty exposure, yes, hire an OSHA defense attorney. For many citations under this standard, the immediate gap is operational: abatement work, proof, Owner Handoff, and written closeout documentation. That is the work OSHA Action Packet helps organize.
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.
Typical ownership is split across Maintenance Lead, EHS Manager, HR / Training Lead. Each packet assigns every cited item to a role and produces Owner Handoff ready to share directly.
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.
Yes. Common matched packs for this standard include Lockout/Tagout Pack, Machine Guarding Pack. The exact template set depends on the actual cited sub-items in your packet.
Packet PDF, per-item Abatement Plan, Proof & Docs, Owner Handoff, Calendar (.ics), CSVs, included template packs when applicable, and the Full Packet ZIP. Preview is free. You only pay if you want the full packet and downloads.
Upload your federal OSHA citation PDF and see the free preview in under a minute. Most cases are $349 after preview, and some simple cases qualify for a lower price. The same packet handles deadlines, abatement, proof, Owner Handoff, and downloads.
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