Under OSHA’s general-industry rule, each lockout or tagout device is normally removed by the employee who applied it. If that authorized employee is unavailable, your business may direct removal only under a specific, documented and trained procedure that provides equivalent safety. Before energy is restored, you must check the work area and equipment, make sure employees are safely positioned, and notify affected employees after the device is removed and before startup.
If you manage a plant floor, supervise a maintenance crew, or write energy-control procedures for your facility, this question comes up constantly: can someone other than the person who locked out the equipment take that lock off? The short answer is “only in narrow, pre-planned circumstances” — and getting this wrong is one of the more common OSHA citation triggers in general industry. This guide walks you through the OSHA LOTO removal procedure step by step, so your team knows exactly who can act, when, and what has to be documented along the way.
This article addresses OSHA 29 CFR 1910.147, the Control of Hazardous Energy standard that applies to general industry workplaces in the United States. If you operate outside general industry — construction, maritime, or outside the U.S. — different standards or local regulations may govern your lockout/tagout program. Regardless of which rule technically applies, you should always follow your site-specific energy-control procedure first, since that document is what your employees are trained on and what an inspector will ask to see.
Whether “a coworker can remove your lock” is not a general authorization question that a supervisor can decide on the spot. Under OSHA’s standard, this is an exception that your business has to build into a documented, trained procedure ahead of time — it isn’t something improvised in the moment, no matter how reasonable it seems at the time.
Before anyone touches a lock or tag, your team should confirm several things. Skipping this step is where a lot of near-misses start, so it’s worth treating as a hard gate rather than a formality.
These checks apply whether you’re following the normal removal sequence or the exception process for an absent employee, so it’s worth building them into your team’s muscle memory rather than treating them as a one-off checklist item.
In the majority of cases, the removal step is straightforward because it follows the same person who did the lockout. Here’s the standard sequence your team should be following:
If you want a broader walkthrough of the full cycle — not just removal — our guide to the 5 steps of LOTO covers preparation, shutdown, isolation, lockout application, and verification in more detail.
This is the part of the LOTO process that trips up the most businesses. If the employee who applied the lock has left the site, is unreachable, or is otherwise unavailable, someone else may remove the device — but only under a specific, documented, and trained procedure that your business has already put in place. This is not a general supervisory power, and it isn’t a judgment call made in the moment. OSHA expects your energy-control procedure to spell out, in advance, exactly what qualifies as “unavailable” and who is authorized to act.
At minimum, this exception process should require your team to:
Because this process carries real risk if it’s handled loosely, your business should document each exception-based removal — who authorized it, what contact attempts were made, and when the returning employee was notified. That documentation is exactly what an OSHA inspector or an internal audit will want to see if this scenario ever gets questioned.
Group lockout situations add another layer, since multiple employees may be working under a single energy-control procedure using a group lockbox or a lockout hasp that holds several individual locks at once. In these setups, each employee working on the equipment should still apply and remove their own personal lock from the group device — the group mechanism doesn’t change the individual responsibility for personal lock removal.
Shift changes require particular attention too. Your procedure should specify how continuity of protection is maintained when one shift’s crew leaves and another arrives — typically through a controlled handoff where outgoing employees don’t remove their locks until incoming employees have applied their own, so the equipment is never left without active lockout protection. A well-organized lockout hasp setup makes this kind of multi-employee, multi-shift coordination easier to manage and easier to audit.
Sometimes a key is lost, a lock is damaged, or an emergency requires equipment access faster than the normal process allows. These situations feel urgent, but they’re exactly the moments where your business should stop and follow the documented exception process rather than reaching for bolt cutters because it seems faster. Improvised removal — cutting a lock without following your procedure, or letting a supervisor authorize removal informally — is one of the more common ways a LOTO program drifts out of compliance, even with good intentions behind it.
If your team runs into missing keys or damaged locks often enough that it’s becoming a recurring problem, it may be worth reviewing your padlock and key management setup rather than treating each incident as a one-off.
Use this checklist as a quick reference for your team, or adapt it into your own written energy-control procedure.
| Step | Responsible Role | Action | Evidence / Sign-Off |
|---|---|---|---|
| 1 | Authorized employee | Inspect work area and confirm equipment is operationally intact | Visual check logged |
| 2 | Authorized employee | Confirm all employees are clear of hazardous areas | Area check confirmed |
| 3 | Authorized employee | Remove personal lockout/tagout device | Device removal logged |
| 4 | Supervisor / designated employee | Notify affected employees before startup | Notification recorded |
| 5 (exception only) | Authorized supervisor per written procedure | Verify absence, document contact attempts, notify employee before return | Exception form signed |
| Factor | Normal Removal | Exception-Based Removal |
|---|---|---|
| Who removes the device | The authorized employee who applied it | A designated person acting under your written exception procedure |
| Trigger condition | Work is complete and the employee is present | The authorized employee is genuinely unavailable |
| Verification required | Area and equipment checks | Area and equipment checks, plus verified absence and contact attempts |
| Notification | Affected employees notified before startup | Affected employees notified before startup, and the returning employee notified before resuming work |
| Documentation | Standard log entry | Exception form or equivalent written record |
Prolockey is the lockout/tagout brand of Lockey Safety Products Co., Ltd., founded in 2015 in Yueqing, Zhejiang, China. The company operates an 8,000 m² facility, has 100+ employees and serves customers in 140+ countries.
A LOTO removal procedure only works as well as your business’s ability to identify who owns each device on the equipment. If your team is relying on generic locks that all look the same, it becomes harder to confirm at a glance whose device is still in place — and that’s exactly the kind of ambiguity that slows down a safe removal sequence. Prolockey offers a range of options to support clearer device ownership:
Ready to standardize your LOTO hardware? Send Prolockey your current padlock identification method, group-lockout setup and required quantities. We can recommend matching safety padlocks, tags and hasps and prepare a B2B quotation.
Who is allowed to remove a personal LOTO lock?
Normally, only the authorized employee who applied the lock removes it. This keeps responsibility for verifying the work is complete and the area is safe with the person who has the most direct knowledge of the job.
Can a supervisor remove an absent employee’s lock?
Only if your business has a documented, trained exception procedure covering that scenario. A supervisor cannot decide on the spot to remove someone else’s lock without following the written process, which typically requires verifying the employee’s absence and making reasonable contact attempts first.
What must be checked before equipment is restarted?
The work area must be confirmed free of nonessential tools and materials, machine components must be operationally intact, and employees must be safely positioned or clear of the equipment before energy is restored.
What is the correct procedure for removing a lockout tagout device?
The authorized employee inspects the work area, checks that employees are clear, removes their own device, and affected employees are notified before the equipment is started. If the authorized employee is unavailable, the documented exception process applies instead.
How does device removal work in group lockout?
Each employee working under a group lockout procedure applies and removes their own personal lock from the group lockbox or hasp. The group device coordinates multiple locks, but individual removal responsibility stays with each employee.
What records should be kept for exceptional lock removal?
Your business should document who authorized the removal, what steps were taken to verify the employee’s absence and contact them, and confirmation that the employee was notified before resuming work.
What does “locked out, do not remove” mean?
It’s a warning on a tag or lock indicating that equipment is in a locked-out state for safety reasons and the device should not be removed except by the authorized employee who applied it, or through your business’s documented exception process.
What should you do if a lock is damaged or the key is lost?
Stop and follow your business’s documented process for damaged locks or lost keys rather than cutting the lock informally. This situation should be treated the same as an unavailable-employee exception, with the same verification and documentation steps.
Prolockey provides lockout tagout devices; employers are responsible for establishing and implementing site-specific energy control procedures.
