OSHA Standard Citation Report: Control of Hazardous Energy (2025)

Period: October 2024 – September 2025

Executive Summary

Between October 2024 and September 2025, OSHA issued 2,550 citations for Lockout/Tagout (LOTO) violations across all industries. These citations resulted from 1,427 inspections and carried a total penalty weight of $16,446,984.

The data indicates that the manufacturing sector remains the primary focus of LOTO enforcement, accounting for the vast majority of both citations and high-dollar penalties.

Top 5 High-Risk Industry Groups

Based on the number of citations issued, the following NAICS subsectors are the most frequently cited for failing to control hazardous energy:

NAICSIndustry DescriptionCitationsInspectionsTotal Penalties
332Fabricated Metal Product Manufacturing378239$1,306,412
311Food Manufacturing369198$2,731,011
326Plastics and Rubber Products Manufacturing269136$2,140,913
321Wood Product Manufacturing16987$1,004,786
333Machinery Manufacturing13470$481,348

Key Findings & Industry Trends

1. High Severity in Food and Plastics

While Fabricated Metal (332) had the highest number of total citations, Food Manufacturing (311) and Plastics/Rubber (326) faced significantly higher financial impacts.

  • Food Manufacturing averaged approximately $7,401 per citation.
  • Plastics and Rubber averaged approximately $7,958 per citation. This suggests that violations in these sectors are often classified as “Serious” or “Willful,” or involve repeat offenses.

2. Manufacturing Dominance

The top 10 list comprises only the manufacturing and wholesale sectors. This aligns with the heavy use of industrial machinery, conveyors, and automated systems in these environments which require frequent maintenance and, consequently, strict adherence to LOTO procedures.

3. Warehousing and Logistics

Beyond traditional manufacturing, Warehousing and Storage (493) and Merchant Wholesalers (423/424) showed notable activity, with over 150 combined citations. This highlights that LOTO is a critical safety factor in logistics hubs, likely involving automated sorting equipment and forklifts.

4. Emerging Compliance Areas

Significant penalties were also noted in:

  • Chemical Manufacturing (325): $594,114
  • Transportation Equipment (336): $529,818
  • Administrative and Support Services (561): $710,629 (High penalty relative to citation count)

Conclusion

Standard 1910.147 continues to be one of OSHA’s most frequently cited standards. For employers in the 300-level NAICS codes (Manufacturing), the data suggests an urgent need for robust energy control programs, annual inspections of procedures, and comprehensive employee training to mitigate both physical risk to workers and significant financial liability.

Note: Penalty amounts reflect current totals as of the report date and may include adjustments from original assessed amounts through informal settlements or court decisions.

Source: Gemini Plus was used to analyze the OSHA data to generate this summary

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