The US Occupational Safety and Health Administration (OSHA) is working on an update to the lockout/tagout rules for controlling hazardous energy during maintenance. Under regulatory identifier RIN 1218-AD00, the federal regulatory agenda lists November 2026 as the target date for a proposed rule. Such a date is a planning goal, not a guarantee, trade publication ISHN reports.
Physical isolation versus electronic control
The current standard, 29 CFR 1910.147, requires employers to use documented procedures, training, periodic inspections and physical isolation of energy sources before maintenance begins. Electronic controls such as stop buttons and interlocks generally do not count as a substitute for that physical isolation under the existing rules. According to ISHN, OSHA is now examining whether certain computer-based safety systems could, under specific conditions, be recognized as a form of energy control after all. No concrete rule text has been published yet.
Stored energy remains a hazard
Even if an update opens the door to more electronic control methods, that does nothing to change a core problem of maintenance work: stored energy. Hydraulic pressure, compressed air and raised components remain a concern, according to ISHN: a stop command issued from a control panel does not mean those hazards have disappeared. Halting a process is therefore not the same as actually isolating energy.
Context
The current reconsideration effort is not happening in isolation. Back in 2019, OSHA used a Request for Information to ask the public whether control circuit devices such as push-buttons and selector switches could, in certain situations, safely serve as energy control, and about the risks and benefits of mobile and collaborative robots; that request followed a permanent variance the agency granted in 2016 to a steel plant in Connecticut, United States, for a specific “trapped key” system used in roll grinding. OSHA assessed that system as a whole and found it to be as safe as full lockout for that particular task. In the RFI, the agency also asked whether technological progress since 1989, the year the original standard was issued, now makes such solutions more broadly viable. The timeline since then has been erratic: in the spring 2023 regulatory agenda, the revision of 1910.147 was shifted to the long-term action category, after August 2024 had previously served as the target date for a proposal, according to Safety+Health Magazine.
What employers can do now
Until a final rule is issued, the existing obligations under 1910.147 remain fully in force. As practical steps, ISHN recommends: reviewing existing lockout/tagout procedures, assessing automated equipment, checking stored energy, keeping training up to date, and tracking the proposal’s progress through the Federal Register.
For HSE professionals worldwide, this US debate is relevant because many companies with automated or robot-driven production lines face the same question: when can an electronic stop function count as energy control, and when does physical isolation remain necessary? As long as OSHA has not published a definitive rule text, organizations would do well to base their own risk assessments on the presence of energy, not on the presence of software.
Source: OSHA Plans a Lockout/Tagout Update: What Computer-Based Controls Could Change, 21 October 2026
Additional research: Safety+Health Magazine – Lockout/tagout update now “long-term” action in latest regulatory agenda, OSHA Federal Register – Request for Information, 20 May 2019
