Lockout/Tagout

Why Lockout/Tagout Violations Persist Despite Clear OSHA Standards

LOTO failures are often blamed on individual mistakes, but modern industrial systems introduce complexity and production pressure that safety rules alone can’t solve. A stronger culture and shared responsibility may be the real key to preventing predictable harm.

• By Herbert Post
• Feb 27, 2026

While the incidence of workplace injuries has declined modestly since 2021, the total number of nonfatal injuries has remained consistently above 2.5 million per year. Likewise, the annual workplace death toll has remained stubbornly above 5,000, according to the Bureau of Labor Statistics. The numbers fluctuate, but the outcome does not fundamentally change.

The account of accidents year after year suggests a familiar response:

• Additional training programs
• Intensified oversight and supervision
• More sophisticated monitoring and control systems
• Renewed commitments from leadership

We assume that safety failures persist because both the institutional and personal effort have been insufficient, and that improvement lies primarily in doing more of the same.

This allows us to see recurring patterns in accidents and citations that seem to be foreseeable. That is how we get “predictable harm”, and Lockout/Tagout offers a textbook example of that. OSHA clearly outlines what employers must do:

• Establish and maintain an energy control program
• Train workers
• Ensure that hazardous energy is effectively isolated and verified during servicing and maintenance.

The standard itself is clear, comprehensive, and applicable. Yet violations persist. From fiscal year 2023 to 2024, Lockout/Tagout was the only top 10 standard to increase both in citation count and ranking.

If the problem is framed as a compliance issue, responsibility is quickly placed on the individual: somebody made a mistake. From there, attention may shift to those responsible for training and communicating requirements, stating that there must be a training or awareness gap.

In many workplaces, Lockout/Tagout is treated as a paperwork requirement rather than a life-critical routine. When it becomes a compliance checkbox instead of an operational discipline, violations occur despite having the “right” rules and equipment on paper.

Or we place responsibility on those expected to apply the rules. It must be complacency and routine risk. In environments where the same machines have been serviced for years without incident, familiarity creates a false sense of control. “We’ve done this a thousand times.”

He had done the machine oiling this way many times before, and “nothing bad happened,” Telfeyan said, until the custodian lost a finger (“No excuses”).That overconfidence erodes vigilance and makes skipped steps feel justified during routine or short-duration tasks.

Accidents are then an unexpected event combined with individual error. Responsibility narrows to the person closest to the incident, and solutions follow a familiar formula. More training. Stricter enforcement. Higher penalties. The expectation is straightforward: change behavior, and accidents will decline.

This line of thinking is measurable and administratively convenient. It assigns clear roles, clear failures, and clear corrective actions. But it also reinforces a narrow view of how harm occurs, one that treats accidents as deviations from otherwise sound systems.

But what happens if, instead of following that reasoning inward, we turn our attention outward, to the conditions that surround the action?

We may look first at the historical context in which Lockout/Tagout was conceived. LOTO was developed in the late 20th century, when industrial work was more linear, contained, and predictable. Machines typically relied on one or two energy sources, most often a single electric motor, making it relatively straightforward to achieve a true zero-energy state. Work was more linear and contained:

• Clearer task boundaries
• Fewer energy sources per machine
• More stable workforces
• Slower production cycles

Modern industrial systems operate under very different conditions. Today’s equipment integrates multiple overlapping energy sources—electrical, hydraulic, pneumatic, thermal, and stored energy—often within a single production line. Work is no longer linear or fully contained. Instead, it unfolds within systems that are interconnected, automated, and continuously in motion:

• Multiple overlapping energy sources per system
• Higher levels of automation and safety interlocks
• Accelerated production cycles and reduced downtime
• Work performed during partial operation or transition states

Under these conditions, energy states change dynamically rather than sequentially. Maintenance and servicing frequently occur during troubleshooting, brief pauses, or partial shutdowns, not during full system outages. Automation and interlocks can allow certain tasks to proceed under limited energy, blurring the line between safe operation and full lockout. At the same time, lean and just-in-time production models compress available time for intervention, increasing pressure to keep equipment running and making full lockout feel incompatible with everyday operational demands.

Incentives that reward speed, informal norms that normalize bypasses, and repeated exposure that dulls risk perception all shape how work is actually performed. The execution of Lockout/Tagout shows that even the most mature safety standards can fail when they are applied to work conditions they were never designed to govern.

Surrounding every rule and action lies systemic pressure, an uncontrolled form of hazardous energy that pushes organizations to move faster and accept predictable harm as the cost of production.

The limits of procedural safety are exposed when rules are applied in environments defined by fragmentation, acceleration, and constant transition.

LOTO effectiveness hinges not only on knowing the procedure, but on whether people are given the time, authority, and support to apply it every single time maintenance is performed. This kind of process safety ultimately depends on a strong safety culture. One capable of resisting systemic pressure.

From Individual Mistakes to Collective Responsibility

Sustained enforcement efforts have exposed a growing disparity between increased control and persistent patterns of injury, fatalities, and most-cited standards. This disparity forces us to examine how risk is organized and rendered acceptable within everyday production practices.

One cannot place an inspector behind every worker, nor can surveillance technologies indefinitely accompany each gesture and decision. At a certain point, the limits of control become visible: not as a failure of will, but as a structural condition.

Regulation operates by establishing agreements about what levels of exposure, injury, or loss are considered reasonable. In this sense, it does not prohibit danger; it organizes it. Vulnerability is administered, and risk is rendered calculable. Regulation, therefore, functions less as a moral boundary—something that must never occur—and more as a system of thresholds beyond which harm becomes officially intolerable.

Accidents are the visible outcome of a sequence of decisions that were made, justified, and normalized long before the event itself occurred. They mark the point at which accepted thresholds are crossed: which risks were deemed tolerable, which safeguards were postponed, and how regulation defined compliance in terms of minimum acceptability rather than the elimination of harm.

This is why patterns of injury often persist even under conditions of compliance. When standards designed to address known hazards coincide with recurring incidents, the issue is not ignorance, intent, or enforcement alone, but the role regulation plays within modern production systems.

Safety improves not when responsibility is narrowed, but when conditions are designed so people can do the right thing without absorbing the cost alone. Safety is not a single role or function, but a system of unevenly distributed responsibilities. It is the outcome of coordinated decisions made across roles. The uncomfortable tasks lie not in identifying new tools or rewriting procedures, but reflecting on things like why we still accept harm as a reasonable cost of doing business.

Breaking the cycle requires moving beyond heroic expectations of workers, of safety professionals, or of rules and toward collective responsibility. Safety outcomes do not improve when responsibility is framed as individual performance, but when work is understood as a shared, relational system in which people depend on one another to manage risk.

Instead of asking whether a rule was followed, we should ask whether the conditions made safe action possible. Modern Lockout/Tagout reminds us that safety is not achieved through compliance alone, but through consistent, shared decisions that prioritize people long before an accident forces attention.

This article originally appeared in the February/March 2026 issue of Occupational Health & Safety.