If your facility runs a lockout/tagout program built around federal OSHA, you may have a gap you can’t see. Compliance with the federal standard does not mean compliance in California.
California enforces its own lockout/tagout standard: Cal/OSHA Title 8, Section 3314. It covers the control of hazardous energy during cleaning, repairing, servicing, setting-up, and adjusting of machines and equipment. Federal OSHA’s 29 CFR 1910.147 is the baseline. Cal/OSHA §3314 meets that baseline and adds requirements that go further. A program written to the federal standard alone can still fall short when a Cal/OSHA inspector walks your floor.
This piece covers what §3314 requires beyond the federal rule. For a complete overview of how a California facility builds and maintains its program, see our lockout/tagout program development guide.
Why “We Follow Federal OSHA” Is Not Enough in California
This is the most common issue we see. When we walk a facility and ask for the written LOTO program, the document often cites only 29 CFR 1910.147. The first thing we check is whether it references Cal/OSHA Title 8 at all. Many do not.
That happens for understandable reasons. Programs get adapted from a corporate template, downloaded from a federal source, or carried over from a prior facility in another state. None of those account for the California-specific provisions in §3314. The program looks complete on paper. The gap only becomes visible when California’s standard is applied to it.
Cal/OSHA is the Division of Occupational Safety and Health, often shortened to DOSH. It conducts its own inspections, applies §3314, and issues its own citations. A federal-only program is not a defense.
What Cal/OSHA §3314 Requires Beyond the Federal Standard
The differences are specific and documentable. These are the provisions California facilities most often miss.
| Requirement | Federal OSHA (29 CFR 1910.147) | Cal/OSHA (Title 8, §3314) |
|---|---|---|
| Unjamming machines | Not named explicitly in the standard’s scope | §3314(a) explicitly includes unjamming prime movers, machinery, and equipment in covered activities |
| Equipment with lockable controls | Tagout permitted where the employer shows it gives full protection | §3314(d) requires equipment with lockable controls be locked out or positively sealed; a tag alone is not sufficient |
| Written energy control procedures | Required | §3314(g) requires the procedures be documented in writing |
| Periodic inspection | At least annually, by an authorized employee other than the one using the procedure | §3314(j) requires the same inspection, at least annually |
| Foundational safety program | No federal equivalent | Title 8, §3203 requires a written Injury and Illness Prevention Program; §3314(l)(4) requires LOTO training documentation to align with IIPP recordkeeping |
A few of these are worth expanding.
Unjamming Is in Scope
Federal programs frequently treat clearing a jam as a quick production task, not a servicing activity. Cal/OSHA §3314(a) names it directly: unjamming prime movers, machinery, and equipment is covered. If a worker reaches into a machine to clear a jam without controlling the energy, that is a §3314 activity, and your program needs to address it.
Lockout, Not Just a Tag, for Lockable Equipment
Under §3314(d), equipment with lockable controls (or controls readily adaptable to lockable controls) must be locked out or positively sealed in the off position. Tagout alone is not compliant for that equipment. Federal OSHA allows tagout-only in some cases where the employer can demonstrate it provides full protection. California is more direct: if the control can take a lock, it gets a lock.
Written, Documented Procedures
Section 3314(g) requires hazardous energy control procedures to be documented in writing. In practice, California enforcement expects machine-specific procedures, not a single generic policy that names no equipment. A new maintenance worker should be able to pick up the procedure for a given machine and follow it. A text-only line like “lock out breaker panel F3” rarely meets that bar. (We cover what a usable, machine-specific procedure contains in a separate piece on equipment-specific LOTO procedures.)
Annual Periodic Inspection
Section 3314(j) requires a periodic inspection of the energy control procedure at least annually, performed by an authorized employee other than the one using the procedure being inspected. This is not a paperwork review. It means confirming the procedure still works on the actual machine. Skipping it is a common finding. We cover this in depth in our guide to annual procedure verification.
Not sure whether your LOTO program meets Cal/OSHA Title 8, or only federal OSHA? Call (925) 551-7300 or request a consultation. We’ll review your existing program against §3314 and show you exactly where it falls short.
How Lockout/Tagout Connects to Your IIPP
California requires every employer to maintain a written Injury and Illness Prevention Program (IIPP) under Title 8, §3203. There is no federal equivalent. The IIPP is the foundational safety document in California, and your lockout/tagout program functions as a component under it.
A complete LOTO program ties back to the IIPP: hazard identification, employee training, and procedures all connect. When we develop a program, we make sure the LOTO documentation aligns with the facility’s IIPP rather than sitting in isolation. If you want to understand the broader California requirement, see our Injury and Illness Prevention Program page.
What Happens When the Requirements Aren’t Met
When a Cal/OSHA inspector reviews lockout/tagout, common findings include no written program, no machine-specific procedures, no documented annual inspection, and tagout used where lockout was feasible. Each can carry a citation. We break down what inspectors look for, and what the consequences are, in our guide to common LOTO violations in California.
The point is not to alarm. It is to show that a federal-only program leaves predictable gaps, and those gaps are fixable before an inspection ever happens.
Frequently Asked Questions
Which government entity establishes the requirements for lockout/tagout?
For California facilities, Cal/OSHA (the Division of Occupational Safety and Health) enforces the lockout/tagout standard under Title 8, §3314. Federal OSHA sets the national baseline under 29 CFR 1910.147, but California operates its own state plan with standards that meet or exceed the federal rule. If you operate in California, §3314 is the standard that applies to you.
Does a federal OSHA lockout/tagout program meet California requirements?
Not necessarily. A program built only to 29 CFR 1910.147 can miss the California-specific provisions in §3314, including the explicit coverage of unjamming, the requirement to lock out (not just tag) equipment with lockable controls, and the requirement under §3314(l)(4) that LOTO training documentation align with §3203 IIPP recordkeeping. If your program does not reference Cal/OSHA Title 8, it likely needs review.
How often does Cal/OSHA require lockout/tagout procedures to be inspected?
At least annually. Under §3314(j), the periodic inspection must be performed by an authorized employee other than the one using the procedure being inspected, and it must confirm the procedure still works as written.
Talk to CDMS About Your Lockout/Tagout Program
Ready to bring your lockout/tagout program in line with Cal/OSHA §3314? Call (925) 551-7300 or request a consultation. We come to your facility, review your existing program and procedures against the California standard, and lay out what it takes to close the gaps.
