Evolving workplace safety: The future of OSHA's lockout/tagout standard

I'll be the first to admit: I'm that guy. The one who meticulously checks scuba gear while friends roll their eyes. The safety nerd who insists on watching every safety video before an excursion. My friends joke that safety is “just a job” for me, but we both know that's far from the truth.

Safety isn't a switch you can turn off. It's a calling.

Throughout my consulting career, I've seen firsthand how a moment of overlooked risk can change lives forever. I've heard stories that haunt me—of serious injuries, of near-misses that could have been catastrophic. Lockout/tagout isn't just a procedure to me. It's a mission to protect every worker who steps onto a job site.

And now, we're at a critical moment. Technology is racing forward, and our safety standards are struggling to keep pace.

As a seasoned safety professional, I've watched technology transform our workplaces faster than our regulations can keep up. The pending updates to the Occupational Safety and Health Administration’s (OSHA) Control of Hazardous Energy standard (29 Code of Federal Regulations 1910.147) are a near-perfect example of this ongoing challenge.

Consider this: the current lockout/tagout standard has remained essentially unchanged since 1989. That's 35 years of technological revolution that our safety protocols haven't fully addressed.

What's driving the change?

OSHA is fundamentally rethinking how we approach hazardous energy control, driven by three areas:

• Energy isolating devices: Recognizing that modern control technologies differ dramatically from traditional methods, OSHA is reassessing what constitutes a safe energy isolation mechanism.
• Industrial robotics: Today's robots aren't static machines behind protective cages. They're collaborative, mobile, and often controlled remotely, requiring entirely new safety paradigms.
• Risk assessment approaches: moving from rigid procedural checklists toward more flexible, context-sensitive risk evaluation methodologies.

Out with the old

Candidly, I'm torn. Part of me loves the traditional approach of physically isolating energy sources. Another part recognizes that clinging exclusively to “the old ways” could leave us vulnerable.

This isn't just a regulatory update. It's about embracing technological evolution while maintaining worker protection.

So, what’s really at stake here? The critical challenges surrounding lockout/tagout that make it one of OSHA's most frequently cited regulations include:

• Human error: At its core, human error represents the most dangerous element, where a single momentary lapse in attention can transform a routine maintenance task into a potential catastrophe. Workers might accidentally bypass critical safety procedures, misunderstand energy isolation protocols, or fail to properly verify equipment's complete de-energization, creating scenarios where unexpected machine startup could result in severe injury or fatality.
• Outdated documentation: Compounding these human factors are systemic documentation challenges. Many organizations struggle with maintaining accurate, up-to-date procedural documentation that reflects current equipment configurations. Outdated manuals, incomplete energy control maps, and procedures that haven't been revised to match technological upgrades create significant compliance gaps.
• Complex compliance maintenance: Documentation deficiencies not only increase safety risks but also exponentially complicate the compliance maintenance process. Decoding the administrative requirements puzzle, including detailed tracking of authorized employees, comprehensive energy control procedures for each unique machine or process, and maintaining meticulous records that demonstrate ongoing safety readiness, is enough to make any safety professional want to swap safety manuals for a beach vacation.
• Challenging annual review processes: Annual review processes can become particularly challenging, demanding extensive time and resources to verify employee qualifications, document equipment changes, and ensure comprehensive training records remain current.

Looking ahead

While a definitive timeline remains uncertain, OSHA is tentatively targeting a proposed rulemaking in December 2024. The goal? Create standards that are:

• Technologically adaptive.
• Practicality-focused.
• Genuinely protective of worker safety.

By acknowledging the limitations of decades-old regulations and embracing a more “up-to-date” approach, OSHA aims to develop standards that are as innovative and adaptable as the workplaces they seek to protect.

My perspective

As someone who's been in safety for years, I see this as an opportunity, not a burden. We're not just updating a standard; we're re-imagining how technology and human safety can coexist more intelligently.

The future of workplace safety isn't about rigid rules. It's about smart, flexible systems that protect people while enabling technological progress.

Stay curious. Stay adaptable. Stay safe.

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About the author

Randal Hines, Senior Consultant

Randy Hines, a Senior Consultant with more than 25 years of EHS experience, has worked across diverse industries, including automotive, defense, biopharma, healthcare, foundries, and general manufacturing.