Beyond The Tags

How to Strengthen Your Lockout/Tagout (LOTO) Program Through Process, Training, and Technology

Lockout/Tagout (LOTO) violations have consistently ranked among OSHA’s top 10 most cited violations year after year. And yet, the tragedy is not in the fines—it’s in the real-world injuries and fatalities that occur when energy isn’t properly controlled. Behind every citation is a life forever altered.

For many organizations, LOTO exists as a laminated policy in a binder. But safe work doesn’t come from paperwork. It comes from understanding, from repetition, from systems that make safety real at every step: planning, training, doing, and tracking.

This article explores how companies can build a more robust LOTO program by focusing on four foundational pillars:

1. Evaluating and updating your written procedures

2. Delivering timely, relevant, and practical training

3. Tracking compliance and competency through technology

4. Embedding LOTO into your broader safety culture and everyday workflow

Because when it comes to energy control, assumptions aren’t just risky—they’re deadly.

Evaluating and Updating Lockout/Tagout Procedures

Before you train or track anything, your written procedures must reflect reality—not wishful thinking. That starts with a comprehensive equipment review:

  • Has anything changed since your last LOTO review? New machines, maintenance protocols, or control panels?
  • Are specific steps clearly outlined for each piece of equipment—especially for complex systems?
  • Are procedures written in plain language with diagrams or photos for clarity?

OSHA requires that employers develop and maintain equipment-specific LOTO procedures that identify all energy sources—electrical, mechanical, hydraulic, pneumatic, chemical, and thermal—and the steps needed to isolate and lock out those energies.

Too often, organizations rely on generic procedures or “tribal knowledge.” That works—until it doesn’t. A review every 12 months is not just smart—it’s required under OSHA 1910.147(c)(6)(i).

A strong evaluation process includes frontline involvement. Bring in operators and maintenance technicians to walk through real shutdowns. Capture steps, barriers, and potential shortcuts.

Example in Action: In one automotive parts facility, a procedural walkthrough revealed that contractors were routinely bypassing LOTO because procedures were overly complex and not easily accessible. A revised version, co-authored with maintenance techs, reduced confusion and increased compliance rates.

Real-World Consequence: In another case, a technician was seriously injured while servicing a machine because the LOTO instructions were outdated and failed to mention a secondary pneumatic energy source. No one on the shift had updated the procedure or verified whether the line had changed. The investigation concluded that generic documentation and infrequent reviews were to blame.

LOTO procedures should be treated as living documents, evolving with your operations. Set a recurring schedule—not just for annual reviews but for post-incident or near-miss updates. Each incident can be an insight.

Training That Goes Beyond Check-the-Box

Training is where many LOTO programs break down—not because it’s not delivered, but because it’s not retained.

OSHA mandates LOTO training for three groups:

  • Authorized employees (those who perform lockout)
  • Affected employees (those who work around locked-out equipment)
  • Other employees (everyone else who may encounter a lockout situation)

But too often, this training is:

  • Delivered once and forgotten
  • Generic and not site-specific
  • Not accompanied by practical demos
  • Presented with minimal assessment or feedback

To be effective, LOTO training must include:

  • Visual walkthroughs of actual equipment shutdowns
  • Hands-on demonstrations of locking out energy sources
  • Quizzes or check-ins to validate comprehension
  • Regular refresher training, especially after near misses or updates to procedures

Practical Example: A food packaging plant introduced a “LOTO rodeo” as a competitive, hands-on quarterly refresher. Teams earned points for speed, accuracy, and completion of procedural steps. Engagement soared, and incident rates fell by 25% in one year.

Training in Action: Another manufacturer of aerospace components developed a mobile cart outfitted with sample valves, switches, and lockout points to simulate common machinery. Trainers used the cart in break rooms and tool cribs to facilitate short, rotating sessions throughout the workday. The result? Increased retention and a 40% jump in worker confidence scores during quarterly safety surveys.

Training must reflect the environments workers actually encounter. Use video tutorials, photo-based quizzes, and real-world examples. Teach to understanding—not just completion.

Tracking Competency and Compliance

Even with the best procedures and training, if you’re not tracking compliance—you’re flying blind.

This means more than logging completion dates. It means capturing:

  • Who has completed training and when
  • Who has demonstrated practical competency
  • Where gaps exist in refresher cycles
  • Which equipment has had LOTO audits or observations
  • Which procedures have been recently reviewed and by whom

Too often, audits only happen post-incident. But a strong LOTO program includes random spot checks, peer-to-peer reviews, and behavioral observations.

Common Pitfall: A manufacturing site relied solely on paper training logs. During an OSHA inspection, the site couldn’t produce evidence that temporary contractors had received proper LOTO instruction. The result? A $92,000 fine and reputational damage.

Best Practice: Digitally track and flag when employees are overdue for refresher training or have not demonstrated hands-on proficiency. Integrate training milestones into onboarding and advancement.

Embedding LOTO into Safety Culture and Workflow

LOTO isn’t just a compliance item—it’s a mindset. That mindset needs to be visible in the culture:

  • Supervisory Modeling: Leaders must visibly participate in safety walks, question procedural shortcuts, and reward proper LOTO behavior.
  • Peer Accountability: Encourage workers to challenge each other respectfully. Normalize correction as a safety commitment—not a call-out.
  • Storytelling: Share examples of “LOTO saves” or near misses during meetings. Create a culture where reporting is a source of pride.

Cultural Insight: At a distribution hub, safety teams started asking employees to share one thing they learned during 22 updates availabletheir last LOTO use. It opened honest conversations, uncovered gaps, and built collective ownership.

Build LOTO into your visual management. Use signage, floor markings, and QR codes linking to digital procedures at equipment sites. Make safety visible and accessible.

How sam® by secova Supports a Smarter LOTO Program

sam® isn’t just a place to store procedures or training logs. It’s a platform that helps you embed LOTO into your daily safety culture.

Here’s how:

  • Procedure Management: Upload and assign equipment-specific LOTO procedures. Ensure only the latest version is visible. Add diagrams, videos, or SOP attachments.
  • Role-Based Training: Assign training based on employee classification (authorized, affected, other) and automate reminders for annual refresher requirements.
  • Competency Tracking: Track completion of hands-on assessments—not just eLearning modules. Log who’s been observed successfully locking out.
  • Audit-Ready Logs: Maintain documentation that’s ready for inspection at any moment—timestamped, verified, and accessible by leadership.

For distributed teams, sam® standardizes expectations across sites. It brings visibility, accountability, and empowerment into every step of the LOTO process.

Lockout/Tagout Isn’t Optional—It’s Foundational

Energy control is one of the most critical, complex, and consequential aspects of workplace safety. It’s also one of the easiest to take for granted.

LOTO isn’t about tags or paperwork. It’s about lives. It’s about giving every technician, every operator, every temp worker the tools, knowledge, and confidence to prevent the unthinkable.

Reinforce your procedures. Reinvent your training. Reimagine your tracking.

At sam® by secova, we make it easier to manage—and harder to overlook.

Because safety doesn’t start with a citation. It starts with accountability.

And it begins right here.

Your LOTO Program Self-Check

If you’re looking to strengthen your Lockout/Tagout efforts, use this checklist to assess your current state:

  • Are all equipment-specific LOTO procedures reviewed at least annually?
  • Do your procedures reflect the most current equipment and energy sources?
  • Are LOTO steps written in plain, visual language?
  • Do authorized employees receive hands-on, role-specific training?
  • Are affected and other employees trained on recognition and response?
  • Are refresher trainings triggered by near misses, equipment changes, or annually?
  • Is training tracked digitally with practical competency records?
  • Do supervisors model proper LOTO practices consistently?
  • Are LOTO audits or peer reviews conducted regularly?
  • Is your team empowered to question and report safety gaps?

The more boxes you check, the stronger your foundation.

If there are gaps, now’s the time to close them. We’re here to help.

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The Hidden Danger of Safety Metrics

Are You Measuring the Wrong Things?

If your safety report shows zero injuries, does that mean your workplace is safe?

That question should make your stomach tighten. Because the real answer—the honest answer—is: Not necessarily.

For decades, safety leaders have worked tirelessly to reduce injury rates and improve compliance. But in the race to lower numbers like TRIR (Total Recordable Incident Rate), DART (Days Away, Restricted or Transferred), and LTIR (Lost Time Injury Rate), many organizations have created a dangerous illusion:

A clean safety record that hides systemic risk.

This article is about what happens when safety becomes a scoreboard. When the numbers we report become more important than the stories behind them. When fear of failure overshadows opportunities to learn. When the appearance of safety masks a culture of silence.

It’s a warning. And it’s also a blueprint—for what we should be tracking instead, and how we can shift safety from performance theater back to a real commitment to protecting people.

The Problem with Lagging Indicators

Let’s start with what we typically measure in safety. Metrics like TRIR, which calculates OSHA-recordable injuries per 100 full-time employees; DART, which includes incidents resulting in job transfer or restricted duty; and LTIR, which counts injuries that lead to lost workdays. These are known as lagging indicators. They track what’s already happened. They measure outcomes, not the causes.

And while they’re useful for establishing long-term trends, they don’t tell you what’s coming. Worse, in many organizations, these metrics become distorted. In environments where safety numbers are tied to leadership incentives, contract eligibility, or corporate reputation, data is often manipulated. Injuries go unreported. First aid incidents are brushed off. Entire categories of risk become invisible—not because they don’t exist, but because they’re inconvenient.

Consider the 2005 BP Texas City Refinery explosion. That site had excellent TRIR numbers leading up to the incident. But the facility was teetering under the weight of deferred maintenance, poor communication, and systemic risk. Fifteen people died. More than 180 were injured. The numbers told one story. Reality told another.

What Happens When Safety Becomes a Scoreboard

Picture this. A worker sustains a minor injury but doesn’t want to be the one to end the “record streak.” A supervisor encourages a band-aid solution—literally and figuratively—so it doesn’t escalate into a reportable event. A near miss occurs, but no one logs it. People whisper about it on break but never put it into the system. Everyone knows what happened, but no one wants to be blamed.

Now multiply that across a company with 2,000 employees.

When safety becomes a performance metric instead of a value system, the wrong incentives are created. Safety becomes something to “get through,” not something to live. And eventually, something critical gets missed.

The consequence isn’t just bad data. It’s broken trust. When workers stop believing that their voice matters, or that safety reporting is welcomed, the silence becomes dangerous.

Why the Pressure to Look Good Is a Hidden Hazard

Too many companies directly tie safety performance to bonuses, contract renewals, or audit scores. That creates immense pressure to maintain a spotless record—on paper.

EHS leaders feel it. Supervisors feel it. Workers feel it most of all. They know that raising a red flag can mean more paperwork, a slower shift, or even being labeled a troublemaker. In one logistics firm, a site manager altered the classification of 12 injuries after the fact, just to avoid reaching a regulatory threshold. When the truth came out, the damage to the company’s reputation far exceeded the cost of the citations.

When organizations prioritize looking safe over being safe, everyone loses.

What You Should Be Measuring Instead

If lagging indicators tell us what happened, leading indicators tell us what might happen next. They shine a light on behaviors, system health, and cultural engagement.

Start with near-miss reporting. The frequency of near-miss reports is one of the best predictors of future risk. The act of reporting signals trust, not because the events are dangerous. When near misses are routinely submitted, reviewed, and discussed, it means workers feel safe telling the truth.

Next, examine how many corrective actions are implemented and followed through. If your team identifies risks during audits or investigations, but those risks remain unresolved, you’re not improving—you’re documenting failure.

Take a look at training. Not just whether it’s completed, but whether it’s retained. Are workers competent and confident in what they’ve been taught? Are they applying it on the floor or just clicking through modules?

Then explore inspection trends. Are your safety inspections identifying meaningful issues? Are they leading to change? Or are they just compliance exercises with boxes ticked?

Finally, pay attention to the quality of safety conversations. Are supervisors and team leads talking about safety daily? Or is safety only mentioned when something goes wrong?

These aren’t abstract ideas. They’re measurable, actionable insights that reveal the strength—or weakness—of your culture.

Near Misses: The Canary in the Coal Mine

The aviation industry has mastered the use of near-miss data. Pilots and air traffic controllers regularly submit anonymous, non-punitive reports of close calls. These systems have helped reduce mid-air collisions and drive continual improvement—even as air traffic increases.

Other industries are slowly catching up. In manufacturing and construction, for example, forward-thinking companies are now incentivizing near-miss reporting and celebrating “almosts” that didn’t become accidents.

When near miss reports are considered wins—not red flags—something powerful happens. People start participating. Problems emerge earlier. Corrections are made faster. And real safety emerges—not just on paper, but in behavior.

From Compliance to Culture

True safety leadership means creating an environment where people care enough to speak up—and are supported when they do.

If your safety metrics solely indicate the lack of injuries, you are managing in the past. You’re solving problems after they hurt someone.

Instead, ask yourself, do our numbers reflect engagement or just absence of failure? Are we measuring learning? Are we capturing early warning signs? Are we seeing trust in action?

If the answer is no, it’s time to rethink what success looks like.

How sam® by secova Helps You See What Others Miss

sam® is built not just for compliance—but for clarity.

The platform encourages quick, easy reporting from any device. That means more near misses logged, more hazards identified, and more insights gained—without slowing down the work.

CAPAs are tracked through to resolution, ensuring issues aren’t just flagged—they’re fixed. Training data integrates with incident history, giving a full view of where your gaps actually are. And with transparent dashboards, everyone from the front line to the C-suite can see not just what happened—but what’s changing.

The result isn’t just fewer injuries. It’s more truth. More learning. And more lives protected.

The Final Word: What Safety Metrics Should Really Mean

Zero injuries should never mean zero conversation.

When the numbers are perfect, ask harder questions. When the reports are blank, look closer. When people are quiet, listen louder.

Real safety isn’t quiet. It’s collaborative. It’s ongoing. And it’s never just about checking the box.

If your dashboard fails to reflect your culture’s pulse, it’s time to revamp it.

Let sam® by secova help you measure what truly matters—before the silence becomes the signal.