How to Write a Lockout/Tagout Program (LOTO) That Passes RAVS

If there's one safety program that RAVS reviewers scrutinize line by line, it's lockout/tagout. LOTO shows up on almost every hiring client's required-program list, and it's one of OSHA's most cited standards year after year. A vague, generic LOTO program is the fastest way to fail a RAVS review — and the fastest way to get your contractor grade dropped in front of every client connected to your ISNetworld account.

This guide walks through exactly what a LOTO program needs to contain to pass RAVS, with citations to 29 CFR 1910.147 (the federal standard) so you can point reviewers to the specific language they're looking for.

What RAVS Reviewers Are Actually Looking For

RAVS doesn't grade whether your workers lock out energy sources in the field. It grades whether your written program meets the requirements of 29 CFR 1910.147 — the OSHA standard titled "The Control of Hazardous Energy (Lockout/Tagout)."

Reviewers are checking for specific elements the standard requires. If your program is missing one, they'll mark the answer deficient and cite the missing element in their feedback. The good news: the standard tells you exactly what needs to be there. The bad news: most templates you find online are either generic boilerplate that doesn't match what reviewers want, or they're missing the equipment-specific procedures that 1910.147(c)(4) requires.

Here's what a passing program looks like.

Section 1: Purpose and Scope

Start with a one-paragraph statement of purpose: your company has established this program to prevent injury from the unexpected startup or release of stored energy during servicing and maintenance of machines and equipment. Cite 29 CFR 1910.147 directly.

Then define scope. Who is covered? This is where most programs get vague. Be specific: the program applies to all employees who service or maintain equipment where the unexpected energization, startup, or release of stored energy could cause injury. Name the job titles if you can — electricians, maintenance techs, mechanics, whoever it applies to.

Also state what's not covered. Cord-and-plug equipment under exclusive control of the user (1910.147(a)(2)(iii)(A)) and minor servicing during normal production operations (1910.147(a)(2)(ii)) are carved out of the standard — but only if specific conditions are met. Reviewers like to see that you understand the distinction.

Section 2: Definitions

Include definitions for the terms the standard uses: affected employee, authorized employee, energy-isolating device, energy source, lockout device, tagout device, servicing and maintenance, setting up, and normal production operations. Pull these straight from 29 CFR 1910.147(b). Reviewers check that the definitions match the regulatory text.

This isn't filler. The rest of your program uses these terms, and if the definitions drift from the standard, reviewers flag it.

Section 3: Responsibilities

Assign responsibilities by role. At minimum:

• Program administrator (usually the safety manager): maintains the written program, conducts periodic inspections, oversees training records, and reviews equipment-specific procedures annually.
• Supervisors: ensure authorized employees follow procedures, verify locks and tags are in place before work begins, and stop work if procedures are not being followed.
• Authorized employees: apply and remove locks/tags, verify isolation, and follow the equipment-specific procedure for the machine they're working on.
• Affected employees: recognize when LOTO is in use and do not attempt to start or operate locked-out equipment.
• Other employees: anyone whose work operations are or may be in an area where energy control procedures are used must understand the purpose of the procedure and the prohibition against attempting to restart or reenergize.

Section 4: Energy Control Procedures (The Part Everyone Skips)

This is where most programs fail. 29 CFR 1910.147(c)(4)(i) requires equipment-specific written procedures for each machine or piece of equipment that will be locked out. A single generic procedure that says "de-energize the equipment and apply a lock" does not satisfy the standard.

1910.147(c)(4)(ii) lists what each equipment-specific procedure must include:

• A specific statement of the intended use of the procedure
• Specific procedural steps for shutting down, isolating, blocking, and securing machines or equipment
• Specific procedural steps for the placement, removal, and transfer of lockout or tagout devices and who has responsibility for them
• Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures

There's a limited exception in 1910.147(c)(4)(i) Note: a single procedure can cover multiple machines only if they share the same type of energy control and the same sequence of steps. In practice, this exception is narrow — reviewers expect separate procedures for meaningfully different equipment.

In your RAVS written program, describe how equipment-specific procedures are developed, where they're stored (near the equipment or in a binder accessible to authorized employees), and how they're reviewed and updated when equipment changes. Attach a sample procedure as an appendix. Reviewers want to see the framework, not every individual procedure — but they want proof the framework produces real procedures.

Section 5: Sequence of Lockout

Spell out the generic sequence that applies to all lockouts, per 1910.147(d):

1. Preparation for shutdown. Identify all energy sources (electrical, hydraulic, pneumatic, mechanical, thermal, chemical, gravitational) and the magnitude and hazards of the energy.
2. Notify affected employees. Tell anyone whose work operations are in the area that a lockout is about to occur.
3. Machine or equipment shutdown. Follow the normal stopping procedure.
4. Machine or equipment isolation. Operate the energy-isolating devices to isolate the equipment from its energy sources.
5. Lockout or tagout device application. Apply locks and tags to each energy-isolating device.
6. Stored energy. Relieve, disconnect, restrain, or otherwise render safe all potentially hazardous stored or residual energy (capacitors, springs, elevated parts, trapped pressure, hot components).
7. Verification of isolation. Verify that isolation and de-energization have been accomplished before work begins. This step is required — it's not optional, and reviewers look for it explicitly.

Then the sequence for restoring equipment to service (1910.147(e)): inspect the work area, ensure employees are clear, remove locks and tags (only by the person who applied them, with narrow exceptions), and notify affected employees.

Section 6: Tagout-Only Systems

If your company uses tagout instead of lockout on equipment that can be locked out, you have a problem. 1910.147(c)(2)(ii) requires that energy-isolating devices capable of being locked out must be locked out. Tagout-only is allowed only when the device cannot accept a lock, and even then the employer must demonstrate the tagout program provides full employee protection equivalent to lockout (1910.147(c)(3)).

Describe in your program when tagout is permitted and the additional measures you use (removing an isolating circuit element, blocking a controlling switch, opening an extra disconnect, removing a valve handle) to provide equivalent protection.

Section 7: Periodic Inspections

29 CFR 1910.147(c)(6) requires a periodic inspection of the energy control procedure at least annually. This is the single most overlooked requirement. Your RAVS answer must describe:

• Who conducts the inspection (an authorized employee other than the one using the procedure being inspected)
• That the inspection reviews each authorized employee's responsibilities under the procedure
• That for tagout systems, affected employees are included in the review
• How the inspection is documented — name of the machine/equipment, date of inspection, employees included, and the person performing the inspection
• The corrective action process when deficiencies are found

Attach a periodic inspection form as an appendix. Reviewers look for this form.

Section 8: Training and Retraining

1910.147(c)(7) breaks training into three buckets:

• Authorized employees receive training on recognition of hazardous energy sources, the type and magnitude of energy in the workplace, and methods for isolating and controlling it.
• Affected employees receive training on the purpose and use of the energy control procedure.
• Other employees working in areas where procedures may be used receive instruction on the procedure and the prohibition against restarting locked-out equipment.

Retraining is required when there's a change in job assignment, equipment, or procedures that introduces a new hazard, or when a periodic inspection reveals deviations or inadequacies. Retraining is also required when the employer has reason to believe the employee's knowledge is inadequate.

Training must be certified — document the name of each employee trained and the dates of training. Keep these records. RAVS reviewers often ask how training is documented, and a clear records-retention answer helps.

Section 9: Group Lockout and Shift Changes

If multiple employees work on the same equipment, describe your group lockout procedure per 1910.147(f)(3): a primary authorized employee takes responsibility for the group, and each member applies a personal lock to a group lockout device (lockbox or hasp). No lock, no work.

For shift or personnel changes (1910.147(f)(4)), describe the orderly transfer of lockout devices between outgoing and incoming employees to ensure continuity of protection.

Section 10: Outside Contractors

1910.147(f)(2) requires that when outside contractors work at your site, the on-site employer and the outside employer inform each other of their respective LOTO procedures, and each ensures their employees understand and comply with the other's restrictions. Include a paragraph describing how this coordination happens.

Common RAVS Rejection Reasons

From what we've seen reviewers flag:

• No equipment-specific procedures referenced or attached
• Missing verification step in the sequence of lockout
• No annual periodic inspection described, or no inspection form
• Training section doesn't distinguish authorized vs. affected vs. other employees
• Tagout described as interchangeable with lockout, without the equivalent-protection language
• No group lockout procedure
• Generic definitions that don't match 29 CFR 1910.147(b)

Fix these and you will clear most RAVS reviews.

PrequalPilot gives you a RAVS-ready LOTO program template that maps section-by-section to 29 CFR 1910.147, including a sample equipment-specific procedure and a periodic inspection form. Start a free trial →