The word "specific" appears four times in 29 CFR 1910.147(c)(4)(ii). That single drafting choice is why a downloaded lockout/tagout template does not satisfy the standard: OSHA does not ask for a procedure about lockout, it asks for the procedure for shutting down, isolating and verifying this machine. 1910.147 was the fourth most frequently cited OSHA standard in fiscal year 2025.
What 1910.147(c)(4) actually requires
Paragraph (c)(4)(i) is one sentence: "Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section." Three verbs, all mandatory - written but not used is as much a violation as used but not written.
Paragraph (c)(4)(ii) then says the procedures "shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following":
| Paragraph | Required element | What a generic template usually shows instead |
|---|---|---|
| (A) | A specific statement of the intended use of the procedure | "This procedure applies to all equipment at the facility" |
| (B) | Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment | "Shut down the machine. Isolate all energy sources." |
| (C) | Specific procedural steps for the placement, removal and transfer of lockout or tagout devices, and the responsibility for them | "Apply your lock and tag." |
| (D) | Specific requirements for testing a machine or equipment to determine and verify the effectiveness of the devices and other energy control measures | "Verify zero energy state." |
Every line in the right-hand column is true, useless, and unverifiable. None of them tells the millwright at 2 a.m. which of the four disconnects in the panel room feeds the conveyor, or that the hydraulic accumulator holds pressure for twenty minutes after the pump stops.
The documentation exception, and why it almost never applies
There is one way out of the paperwork, and it is narrow. The note to (c)(4)(i) says the employer "need not document the required procedure for a particular machine or equipment, when all of the following elements exist" - eight of them, joined by "and":
- No potential for stored or residual energy, or reaccumulation of stored energy, after shutdown that could endanger employees.
- A single energy source that can be readily identified and isolated.
- Isolating and locking out that source completely deenergizes and deactivates the machine.
- The machine is isolated from that source and locked out during the servicing.
- A single lockout device achieves the locked-out condition.
- That device is under the exclusive control of the authorized employee doing the work.
- The servicing creates no hazards for other employees.
- The employer, in using this exception, has had no accidents involving unexpected activation or reenergization of the machine during servicing or maintenance.
Run a real bench grinder through the list and it passes. Run almost anything with a hydraulic cylinder, a pneumatic line, a capacitor bank, a gravity-loaded ram, a second control panel or a shared header through it and it fails on condition 1, 2 or 5. That is by design: OSHA wrote the exception for the simple single-cord machine, not for production equipment.
When one procedure may cover several machines
"Machine-specific" does not mean one document per serial number. OSHA addressed this directly in a letter of interpretation dated January 14, 2003:
"Similar machines and/or equipment (those using the same type and magnitude of energy), which have the same or similar type of controls, can be covered with a single procedure."
OSHA standard interpretation, 01/14/2003
The same letter sets the boundary in the next breath - "over-generalization can result in a document that has little or no utility for employees who must follow the procedure" - and supplies the practical test to apply to your own paperwork:
"The procedure must be written in sufficient detail and provide enough direction so that the employees can follow the procedure and determine how to safely perform servicing or maintenance work."
OSHA standard interpretation, 01/14/2003
So a bank of six identical extruders on the same bus, with identically numbered disconnects and identical stored energy, is one procedure. Six presses of three different makes are not, no matter how similar the shutdown reads on paper.
Five things a downloaded template cannot know
This is the fastest self-audit we know: take your current procedure to the machine and see whether the document answers these five questions without anyone filling in a blank.
- Every energy source, with its magnitude. 480 V three-phase, 120 V control circuit, 90 psi shop air, 2,000 psi hydraulic, steam, a spring, a suspended part. (d)(1) requires the authorized employee to know the type and magnitude of the energy before turning anything off - and the procedure is where that knowledge comes from.
- Where each one is isolated, by label. "Disconnect DS-114, north wall of MCC room 2," not "the electrical disconnect." (d)(3) requires isolating devices to be "physically located and operated"; a procedure that cannot tell you where they are cannot be followed.
- What holds energy after shutdown, and how it is released. (d)(5)(i) requires stored or residual energy to be "relieved, disconnected, restrained, and otherwise rendered safe" - bleed valve, blocking pin, gravity block, capacitor discharge time. (d)(5)(ii) adds that where energy can reaccumulate, verification of isolation must continue until the work is done.
- How verification is performed on this machine. Element (D) says specific requirements for testing. "Try the start button" is not a test of an isolated 480 V feeder; a meter reading at a named point, or a specific attempted-start plus pressure gauge check, is.
- The order things come back on. Restoring some equipment in the wrong order is itself the hazard. (e)(1) and (e)(2) require the area to be inspected, components confirmed operationally intact, employees safely positioned or removed, and affected employees notified before start-up.
If the answers live only in a technician's head, they are not in a procedure, and neither an inspector nor the next hire can use them. The machine-specific LOTO procedure generator walks these five questions in order and prints the result with the (d) and (e) sequences already in place.
The sequence the procedure has to carry
Paragraph (d) is not a suggested order. It opens: the procedures "shall cover the following elements and actions and shall be done in the following sequence." A procedure that omits a step, or reverses two, is out of compliance even if the words are all present somewhere.
| Step | Paragraph | What it demands |
|---|---|---|
| 1 | (d)(1) Preparation for shutdown | Authorized employee knows type and magnitude of the energy, its hazards, and the means to control it |
| 2 | (d)(2) Shutdown | Orderly shutdown using the established procedure, avoiding added hazards from the stoppage |
| 3 | (d)(3) Isolation | All needed isolating devices located and operated to isolate the machine |
| 4 | (d)(4) Device application | Devices affixed by authorized employees, locks holding devices in the safe or off position |
| 5 | (d)(5) Stored energy | Residual energy relieved, disconnected, restrained; continued verification where it can reaccumulate |
| 6 | (d)(6) Verification of isolation | Isolation and deenergization verified before work starts |
| 7 | (e)(1)-(e)(3) Release | Area inspected, employees positioned and notified, each device removed by the employee who applied it |
OSHA's own Appendix A to 1910.147 prints a "typical minimal lockout procedure" in this order. Appendix A is non-mandatory and generic on purpose - it shows the skeleton, and expects you to fill in the machine.
The parts a template quietly leaves you exposed on
- Lock unless you can prove a tag is equal. (c)(2)(ii) requires lockout whenever the isolating device can accept a lock, unless the employer demonstrates that tagout provides full employee protection. (c)(3) defines what that demonstration takes: the tag goes where the lock would have gone, plus additional measures such as removing an isolating circuit element, blocking a controlling switch, opening an extra disconnect, or removing a valve handle.
- Annual periodic inspection, certified. (c)(6)(i) requires an inspection at least annually by an authorized employee other than those using the procedure, correcting any deviations. (c)(6)(ii) requires certification identifying the machine, the date, the employees included and the person who performed it. A generic procedure gives an inspector nothing specific to inspect against.
- One lock, one owner. (e)(3) allows removal only by the employee who applied the device, with a narrow documented exception requiring verification that they are off site, all reasonable efforts to contact them, and confirmation they know before resuming work at the facility.
- Crews, contractors and shift change. Group lockout and shift-change continuity are their own requirements under (f). A one-page template that stops at "apply lock" has not addressed them.
Pair the procedure with a task-level hazard analysis for the work itself - the JHA builder covers the steps around the lockout, which the energy control procedure does not.
On a construction site, 1910.147 is not the rule
Worth knowing before you copy a general-industry template onto a jobsite: 1910.147(a)(1)(ii)(A) states the standard "does not cover" construction and agriculture employment. Construction circuits are governed by 1926.417, which is three short paragraphs - controls to be deactivated shall be tagged, deenergized equipment or circuits shall be rendered inoperative with tags attached at all points where they can be energized, and tags shall plainly identify the equipment or circuits being worked on.
Bottom line
- (c)(4)(ii) uses the word "specific" four times. Anything that could be printed for a different machine without changing a word fails it.
- The documentation exception needs all eight conditions at once. Stored energy or a second energy source ends the conversation.
- One procedure per family of genuinely similar machines is allowed; the test is whether an employee can follow it and determine how to work safely.
- Name the sources and their magnitudes, the labeled isolation points, the stored energy and how it is released, the verification method, and the restart order.
- Then walk it at the machine with a knowledgeable authorized employee before anyone relies on it. A procedure validated only at a desk is a guess with a signature block.