LOT/General/TBT-LOT-015

LOTO Auditing and Compliance

Lock Out Tag OutGeneralLOTO Auditing and Compliance

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LOTO Auditing and Compliance

Toolbox Talk Record

Ref: TBT-LOT-015  |  Issue: 1  |  Date: March 2026
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What?

  • LOTO auditing verifies that lock out tag out procedures are correctly followed across the site.
  • Poor LOTO compliance is a leading cause of fatal and life-changing injuries on construction sites.
  • Audits check that isolation points are correctly identified, locked, and tagged by authorised persons.
  • The Provision and Use of Work Equipment Regulations 1998 (PUWER) require effective isolation procedures.
  • Common audit failures include missing locks, unsigned permits, and unapproved isolation methods.
  • Each isolation should have a unique lock per person working on the equipment (one lock per life).
  • LOTO audits should cover electrical, mechanical, hydraulic, pneumatic, and gravity energy sources.
  • Records of isolation must be maintained and available for inspection at all times during the work.
  • Regular auditing promotes a culture of compliance and identifies training gaps before incidents occur.
  • LOTO procedures must be reviewed and updated whenever equipment or processes change on site.

Why?

Prevent fatalitiesUnexpected energisation of equipment during maintenance kills and seriously injures workers every year.
Legal compliancePUWER 1998 and the Electricity at Work Regulations 1989 require effective isolation verified by competent persons.
Continuous improvementAuditing identifies weaknesses in procedures, training, and equipment before they lead to incidents.
Do Don't
  • Include LOTO compliance checks in regular site safety inspection programmes
  • Verify that every active isolation has the correct number of personal locks applied
  • Check that isolation permits are fully completed, signed, and displayed at the point of work
  • Confirm proving dead has been carried out and recorded after each new isolation
  • Audit that LOTO equipment such as locks, tags, and hasps is in good condition
  • Interview workers during audits to confirm they understand the isolation in place
  • Record all audit findings and track corrective actions through to completion
  • Review LOTO procedures when new equipment is installed or processes change on site
  • Provide refresher training where audits identify gaps in knowledge or compliance
  • Share audit results with the site team to reinforce good practice and lessons learned
  • DON'T treat LOTO audits as a paperwork exercise — physically check every isolation
  • DON'T ignore minor LOTO non-conformances — they indicate systemic weaknesses
  • DON'T allow isolations to remain in place beyond the period authorised on the permit
  • DON'T accept verbal confirmation that isolation is in place without physical verification
  • DON'T skip LOTO checks during time pressure or out-of-hours working
  • DON'T allow personal locks to be substituted with cable ties or unapproved devices
  • DON'T defer corrective actions from LOTO audits — address findings immediately
  • DON'T assume competence — verify that all isolating personnel hold current authorisation
  • DON'T remove another person's lock without following the formal lock removal procedure
  • DON'T audit only electrical isolations — cover all energy sources including stored energy

See also: LOTO Awareness | Verification of Isolation (Proving Dead)

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