The inspector who walks your bulk plant still asks for the same three lockout proofs. Documented energy control procedures for the equipment you service. Training certification with each worker's name and dates. A periodic inspection record that shows the last annual review.
Under 29 CFR 1910.147, those three proofs are what the walk-through tests.
The standard covers servicing and maintenance where stored energy or an unexpected start could injure employees. At a propane retailer, that usually means compressors, pumps, motors, fill equipment, and shop tools that get opened or rebuilt. Normal production use is outside the rule. Cord-and-plug gear under exclusive control of the person doing the work can also fall outside when unplugging removes the hazard.
The energy control program auditors ask for
Paragraph (c)(1) requires employers to establish a program of procedures, training, and periodic inspections. Before anyone services covered equipment, isolate the machine from its energy source and render it inoperative.
A May 10, 2005 OSHA interpretation letter restates those three parts. It notes that the standard does not require one standalone written energy control program document. It does require documentation and certification in three places.
Document procedures under (c)(4). Certify inspections under (c)(6) and training under (c)(7).
Dealer guidance: Keep the LOTO procedures in the same audit drawer as your other plant books. A Policies and Procedures manual should name the same shop roles and equipment the lockout sheets cover.
Documented procedures for plant equipment
Cornell LII’s text of 1910.147(c)(4)(i) states the documentation duty. "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." Say who may use the sheet, the steps they follow, and how you enforce them.
Dealer guidance: The safety manager loses the walk-through when a sheet names a disconnect that is gone. Write the sheet for the gear still on the floor.
At minimum the sheet needs:
- "A specific statement of the intended use of the procedure"
- Shut-down and isolation steps that block and secure the machine
- Who places, removes, or transfers each lock or tag, and how
- How the crew tests that isolation really worked
The May 2005 letter stresses the word specific. Over-general sheets do not give an authorized employee enough detail to isolate energy.
There is a narrow documentation exception. You need not document the procedure for a particular machine when all eight elements in the (c)(4)(i) note exist. Those elements cover one readily identified energy source and no stored energy that could endanger people after shutdown. They also require exclusive control of one lock and no unexpected-activation accidents under that exception.
The letter adds that the exception drops only the documentation duty. You still must develop and use energy control procedures. If a device can accept a lock, use lockout unless tagout gives full protection under (c)(3). After January 2, 1990, new or replaced machines must accept a lockout device.
Dealer guidance for propane plants: write a procedure for each machine techs open. Name the disconnect, valve, or block that isolates it.
Authorized employees, affected employees, and training
The standard splits the crew. An authorized employee locks out or tags out equipment to do the servicing. An affected employee operates that equipment, or works in the area while lockout is in place. That person becomes authorized when the job includes covered servicing.
Dealer guidance: A missing name-and-date training line turns the new hire into a finding. Certify the session before that person opens plant equipment.
Training under (c)(7) must make "the purpose and function of the energy control program" understood. Authorized employees need the energy sources on site, how strong that energy is, and how to isolate it. Affected employees get the purpose and use of the procedure. Other employees in those areas get the procedure and the restart ban.
Retrain when job assignments change, when machines present a new hazard, or when procedures change. Retrain also when a periodic inspection, or the employer, finds knowledge gaps. Certify training with "each employee's name and dates of training."
Cornell LII’s text of 1910.147(c)(8) states who may lock or tag. "Lockout or tagout shall be performed only by the authorized employees who are performing the servicing or maintenance." Notify affected employees before devices go on and after they come off.
Periodic inspection at least annually
Paragraph (c)(6) requires employers to inspect each energy control procedure at least once a year. An authorized employee other than the ones using that procedure must perform it. Fix gaps the inspection finds.
Dealer guidance: The plant manager cannot show an annual cert for the fill motor the tech just opened. Put that review on the plant calendar before the gap becomes a finding.
For lockout, the inspector walks each authorized employee through their duties under that sheet. For tagout, the walk covers authorized and affected employees plus the tag limits in (c)(7)(ii).
Certify that those inspections happened. Record which machine, the date, which employees were in the review, and who inspected. That annual cert is often the first gap an auditor finds when the procedures look fine on paper.
A written DOT security plan often sits in that same stack the safety manager opened for energy control. Keep it ready for the next security pull.
What your safety manager does this week
Your safety manager pulls the documented energy control procedures this week (week of September 29, 2026). Cover the plant compressor, transfer pump, and fill-equipment motors. Walk each sheet against the disconnects and valves still on the floor. Name who fixes each missing or stale procedure before the next inspector or insurer visit.
Then open the last periodic inspection certification and confirm it is current for the machines still in service. Schedule any overdue annual reviews before the next inspector or insurer pull, or before that new hire opens plant equipment.
Pull the training certification list next. Add every new hire who opens plant equipment and every tech whose assignment or gear changed since the last session.
Common questions
Who pulls the lockout file when an OSHA inspector or insurer asks?
Have your safety manager or plant manager pull the lockout binder. Keep the front desk from handing the whole shelf alone. Put a one-page cover sheet on top that names which sections to hand over. Train the CSR on that sheet so a surprise visit does not stall at the counter.
Where should energy control procedures live at a propane plant?
Ask your plant manager to file the lockout sheets where plant and shop people can reach them during a work shift. Put a copy of the hardware list (locks, tags, hasps) with that section. Tell the night filler and the shop lead where it sits before the next overtime call.
What proves we did the annual lockout inspection?
Your plant manager should hand the periodic inspection certification over without hunting through a general safety binder. Print that sheet with the procedure it covers, and check the date before the next inspector or insurer pull.
Sources
- Cornell Law School Legal Information Institute, 29 CFR § 1910.147 - The control of hazardous energy (lockout/tagout), as of September 29, 2026 (current text; FR history through 76 FR 44265, July 25, 2011) — www.law.cornell.edu
- National Archives / GovInfo, CFR-2025-title29-vol5-sec1910-147.xml (29 CFR 1910.147), CFR Title 29 Vol. 5 (2025 annual edition; read September 29, 2026; WebFetch timeout this edit run; curl HTTP 200; text also verified via local job dump matching Cornell LII) — www.govinfo.gov
- National Archives / eCFR, 29 CFR 1910.147 The control of hazardous energy (lockout/tagout), as of September 29, 2026 (automated curl CAPTCHA-blocked; regulatory text verified via Cornell LII and GovInfo CFR-2025 annual XML above) — www.ecfr.gov
- Occupational Safety and Health Administration, Control of Hazardous Energy (Lockout/Tagout) - Overview, read September 29, 2026 — www.osha.gov
- Occupational Safety and Health Administration, Hazardous energy control lockout/tagout (LOTO) program documentation and certification requirements (interpretation letter), May 10, 2005 (archive notice on page; read September 29, 2026) — www.osha.gov
This page is general information for propane marketers in the United States. It is not legal advice and it does not certify compliance. Confirm the current rule text, your state's adopted code, and your insurer's requirements before you rely on any example here.
Propane Safety Pro writes the written programs linked above, built to how your company actually runs. Call 610-228-0887 and ask for the written program. We sell to propane companies, not homeowners.