Lockout/Tagout (LOTO) Tag Requirements: A Complete Guide to OSHA 1910.147 Compliance

Understanding safety tag requirements and implementing an effective LOTO program

Important Disclaimer

This article is provided for general informational purposes only and does not constitute legal, safety, or professional compliance advice. Regulations, standards, and codes are subject to change and may be interpreted differently by authorities having jurisdiction (AHJ). Always consult with qualified safety professionals, licensed engineers, or legal counsel to determine the specific requirements applicable to your facility. TagBuilder is not responsible for any actions taken based on this information.

Lockout/tagout procedures prevent an estimated 120 fatalities and 50,000 injuries every year, according to OSHA estimates. At the heart of every LOTO program are the tags themselves—the physical warning devices that communicate to every worker that equipment is locked out and must not be energized.

Understanding OSHA 1910.147: The Control of Hazardous Energy

OSHA Standard 29 CFR 1910.147 applies to the control of hazardous energy during servicing and maintenance of machines and equipment. The standard establishes minimum performance requirements for the control of energy sources that could cause injury to employees.

The Distinction Between Locks and Tags

OSHA 1910.147 establishes a clear hierarchy: lockout devices are preferred over tagout devices. The standard permits tagout-only programs under specific circumstances, but imposes additional requirements when tags are used without locks.

When Lockout Is Required: If energy-isolating devices are capable of being locked out, the employer must use lockout devices. This is the default requirement.

When Tagout May Be Used Alone: Tagout devices may be used without locks only when the energy-isolating device cannot accept a lock, and when the employer can demonstrate that the tagout program provides equivalent protection to a lockout program.

Specific Requirements for LOTO Tags Under 1910.147

OSHA 1910.147(c)(5) establishes the requirements for lockout and tagout devices. Tags must meet all of the following criteria:

Durability Requirements

Environmental Resistance: Tags must be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected. Tagout devices must not deteriorate or become illegible, particularly when used in corrosive or wet environments.

Standardization Requirements

Consistent Format: All tagout devices used within a facility must be standardized by at least one of the following criteria: color, shape, or size. Additionally, the print and format must be standardized.

Identification Requirements

Warning Statement: Tags must include a legend that indicates the prohibition against operating or energizing the equipment. Acceptable legends include "Do Not Start," "Do Not Open," "Do Not Close," "Do Not Energize," and "Do Not Operate."

Employee Identification: Tags must identify the authorized employee who applied them.

Attachment Requirements

Non-Reusable Attachment: The attachment means must be non-reusable—typically a single-use nylon cable tie or similar device.

Self-Locking: The attachment must lock without requiring tools or additional securing mechanisms.

Strength Requirement: The attachment must require a minimum force of 50 pounds to release.

Hand-Attachable: Workers must be able to attach the tag by hand, without requiring tools.

What Information Must Appear on LOTO Tags

Based on OSHA requirements and industry best practices, compliant LOTO tags typically include:

Warning Statement/Legend - A clear prohibition against operating the equipment
Employee Identification - The name of the authorized employee who applied the tag
Date and Time of Application - Essential for tracking duration of lockout
Equipment Identification - The specific equipment or energy-isolating device being tagged
Reason for Lockout - Brief description of the maintenance or service activity

Tag Design Specifications

Color Requirements

OSHA doesn't mandate specific colors for LOTO tags, but establishes that tags must have a standardized color scheme within the facility. Industry convention typically uses:

Red Tags: Primary lockout/tagout tags indicating danger and prohibition of equipment operation.

Yellow Tags: Sometimes used for caution situations or temporary status indicators.

Material Selection

Cardstock Tags: Acceptable only in clean, dry, indoor environments with short lockout durations.

Plastic Tags: Suitable for most indoor industrial environments. Resistant to moisture and moderate chemical exposure.

Engraved Rigid Tags: Maximum durability for harsh environments, repeated use of the tag body (with new attachments each time), and permanent equipment identification portions.

Common Compliance Failures

Based on OSHA inspection findings, these are frequent tag-related violations:

Generic or unclear warning statements
Missing employee identification
Inadequate attachment strength
Reusable attachments
Environmental durability failure
Non-standardized tags across the facility
Running out of tags

Conclusion: Tags as Life-Safety Devices

LOTO tags are not mere administrative paperwork—they're life-safety devices that communicate critical information to every worker who encounters locked-out equipment. A tag that's illegible, incomplete, or easily removed defeats the purpose of the entire lockout/tagout program.

Investing in properly designed, durable tags that meet all OSHA requirements is essential. But equally important is the training, procedures, and culture that ensure tags are used correctly every time.

Need OSHA-Compliant LOTO Tags?

Your lockout/tagout program is only as good as the tags that support it. TagBuilder produces durable, OSHA-compliant tags that meet all 1910.147 requirements—including the 50-pound attachment strength specification.

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