The Two Standards in Plain Language

In California, two Cal/OSHA Title 8 standards govern this overlap:

• §5157, Permit-Required Confined Spaces. Requires a written program, hazard evaluation, atmospheric testing, an entry permit, an attendant, a rescue plan, and trained roles (authorized entrant, attendant, entry supervisor). Applies whenever employees enter a space large enough for bodily entry, with limited or restricted entry or exit, not designed for continuous occupancy, that contains a recognized hazard.
• §3314, Control of Hazardous Energy (LOTO). Requires a written energy control program, machine-specific energy control procedures, training, periodic inspection of procedures, and physical isolation devices. Applies whenever employees service or maintain equipment where the unexpected release of energy could cause injury.

The confined space standard says hazards must be isolated before entry. The LOTO standard says how isolation is actually done. When a confined space contains equipment with stored energy, the LOTO procedure becomes the mechanism that satisfies the confined space program’s isolation requirement. The two standards are not duplicative. They are sequential.

For a complete overview of the written program requirement, see our confined space program guide.

Decision Tree: Which Standard Applies to This Activity?

Use this to decide what your facility needs in place before the work begins:

If the activity falls in the right-hand column, the entry permit cannot be issued until the LOTO procedure has been executed and verified.

What the Entry Permit Actually Shows

The CDMS entry permit form has a specific section for isolation methods, with a checkbox for “Lockout/Tag Out.” That box is not decorative. When it is checked, the entry supervisor is attesting that:

The most common deficiency we see on this point: the LOTO procedure on file is a generic one-pager that does not address the energy sources connected to the specific confined space being entered. A mixing tank with three feed lines, one steam jacket, and a top-mounted agitator needs four isolation points, not one. If the LOTO procedure does not name them, the entry permit cannot honestly check the isolation box.

Common Failures We See in the Field

When we walk a facility that has both programs on paper, here is where they break down:

The LOTO procedure exists but the confined space program does not reference it. The entry permit asks whether isolation is complete, but provides no mechanism to point to the actual procedure used. The entry supervisor checks the box without verifying.

The confined space program names “lockout” as a hazard control but the facility has no equipment-specific procedures. §3314 requires machine-specific procedures for each piece of equipment being serviced. A generic policy that says “lock out energy sources before entry” is not a procedure.

Periodic inspection of the LOTO procedure has lapsed. Cal/OSHA §3314 requires that energy control procedures be inspected at least annually, by someone other than the person who normally uses the procedure. When this lapses, the LOTO step in the entry permit is supported by an unverified procedure.

Contractor entries skip the host-employer integration. A contractor performing maintenance in a host facility’s confined space must follow the host’s program (§5157) and must coordinate energy isolation (§3314). When the contractor brings their own locks but the host’s procedure does not document the isolation points, the entry happens with an incomplete picture.

Training is split, not integrated. Authorized entrants are trained on confined space hazards. Authorized employees are trained on LOTO. The person doing both jobs in the same shift may have never received training on how the two programs interact in practice.

How to Integrate the Two Programs

Integration does not mean merging the documents. It means making sure each one references the other where the overlap occurs.

In the confined space program: The hazard evaluation for each permit-required space should list the energy sources connected to that space, the LOTO procedure that controls each one, and the verification step required before entry. The entry permit should require the LOTO procedure number on its face, not just a checkbox.

In the LOTO program: Equipment-specific procedures for any machine inside or connected to a confined space should include a note that confined space entry triggers the §5157 program in addition to the standard isolation steps. Training for authorized employees should cover the difference between routine equipment service and service that requires entry.

In the training plan: Anyone who may serve as an authorized entrant in a space that contains energized equipment needs LOTO training, not just confined space training. Anyone who may serve as an entry supervisor needs to know enough about the LOTO procedure to verify it before signing the permit.

For a deeper look at the entry permit itself and what goes on each line, see our piece on what goes on a confined space entry permit. For the broader LOTO program requirements, see our lockout/tagout program services overview.