4.2 Training, retraining and certification

1 What the training is for

1910.147(c)(7)(i) states the objective before it states the content: the employer shall provide training "to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees."

Two words there set the bar. Understood and acquired are outcomes, not activities. A video that was played does not by itself establish that anything was understood, and a signature on a sign-in sheet is evidence of attendance, not of skill. The word skills is what pushes authorized-employee training towards hands-on work at the machine.

2 Three audiences, three contents

Notice how much narrower the second and third rows are than the first. Affected and other employees do not need to know how to isolate a hydraulic accumulator; they need to know what a lock means, that it is not theirs to remove, and that they must never try to start something that carries one. Plants routinely over-train this group and under-train the first — a four-hour general session for everyone, and no machine-specific work for the technicians who actually apply the locks.

And remember the definition from Part 1: an affected employee becomes an authorized employee when their duties include performing covered servicing. An operator who clears jams under a lockout procedure has moved into row one.

3 The six tag limitations

1910.147(c)(7)(ii) adds a whole extra syllabus wherever tagout systems are used: employees shall also be trained in the following limitations of tags.

1. A
   Tags are essentially warning devices affixed to energy isolating devices, and do not provide the physical restraint on those devices that is provided by a lock.
2. B
   When a tag is attached to an energy isolating means, it is not to be removed without authorization of the authorized person responsible for it, and it is never to be bypassed, ignored, or otherwise defeated.
3. C
   Tags must be legible and understandable by all authorized employees, affected employees, and all other employees whose work operations are or may be in the area, in order to be effective.
4. D
   Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace.
5. E
   Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall energy control program.
6. F
   Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use.

Limitation (E) is remarkable for appearing in a federal regulation at all. OSHA is telling employers to teach their workforce that the control they are relying on may make people feel safer than they are. It is worth saying out loud in any tagout training.

Limitation (C) has a practical consequence in many plants: "legible and understandable by all... employees" means the tag has to be readable by the people who will encounter it, which raises real questions on a multilingual site.

4 Retraining: four triggers, no interval

1910.147(c)(7)(iii)(A) requires retraining for all authorized and affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or a change in the energy control procedures. (c)(7)(iii)(B) adds retraining whenever a periodic inspection reveals — or the employer has reason to believe there are — deviations from or inadequacies in the employee's knowledge or use of the procedures. (c)(7)(iii)(C) says the retraining shall reestablish proficiency and introduce new or revised control methods as necessary.

There is no annual refresher requirement in 1910.147. Many employers run one anyway, and it is a reasonable practice — but it is not what the standard asks for, and it is not a substitute for the four triggers. A plant that retrains everybody every January and never retrains the technician who took over a new line in March has complied with its own policy and not with the standard.

5 Certification: two fields, and what it is not

1910.147(c)(7)(iv): "The employer shall certify that employee training has been accomplished and is being kept up to date. The certification shall contain each employee's name and dates of training."

Two required fields, and the certification is an employer record. It is not a card, it is not a wallet credential, and it is not something an outside provider can issue on the employer's behalf — because the employer is the one certifying that its own training was accomplished for its own machines. In practice most plants record more than the minimum: the topics covered, the machines or procedures involved, who delivered the training, and how understanding was checked.

"Being kept up to date" is the part that ties back to the retraining triggers. A certification record that shows one date in 2021 for a technician who has since moved lines and worked through two procedure revisions is evidence that the retraining triggers were not applied.

6 Training that actually produces skill

Nothing in the standard prescribes a method, so what follows is practice rather than requirement — but it is the practice that satisfies the words "knowledge and skills... acquired."

1. 1
   Classroom for the concepts — scope, the six steps, stored energy, who may remove a lock, the tag limitations if you use tags.
2. 2
   At the machine for the skills — walk the actual isolation points with the actual procedure, apply the actual devices, do the actual verification.
3. 3
   Observed performance — the trainee runs the lockout while the trainer watches and says nothing unless safety requires it. This is where "understood" is established.
4. 4
   A written record that names the employee, the date, the procedure and the observer.

If you want a knowledge check before or after that hands-on work, the free lockout/tagout practice test on this site is 25 questions with every answer traced to its paragraph. It is a study aid, not training under 1910.147(c)(7) — that has to come from your employer, on your machines, with your procedures.