Most lockout/tagout violations in California do not come from a careless operation. They come from a program that looks complete on paper but was built to the wrong standard. A facility has a written LOTO program, locks on the wall, and trained workers, and still gets cited because the program was written to federal OSHA and never aligned with Cal/OSHA Title 8, Section 3314.
This piece covers the lockout/tagout violations a Cal/OSHA inspector finds most often, what they check during an audit, and what a citation can cost. For a complete overview of how a California facility builds and maintains its program, see our lockout/tagout program development guide.
Why Federal-Only Programs Get Cited in California
This is the most common gap we see. When we walk a facility and pull the written LOTO program, it often cites only 29 CFR 1910.147, the federal standard. Cal/OSHA enforces Title 8, §3314, which meets the federal baseline and adds requirements that go further. A program that never references the California standard usually misses the same three things: unjamming as a covered activity (§3314(a)), the requirement to lock out equipment with lockable controls rather than tag it (§3314(d)), and the alignment of LOTO training documentation with IIPP recordkeeping under §3203.
We cover those differences in detail in our guide to Cal/OSHA lockout/tagout requirements. The short version: “we follow federal OSHA” is not a defense when a Cal/OSHA inspector walks your floor.
The Most Common §3314 Findings
The violations below account for most of what gets written up. None of them require an injury to trigger a citation. An inspector can find them in a document review and a walk of the floor.
- No written program, or a federal-only program. A program that cites only 29 CFR 1910.147 and never references Title 8, §3314.
- No equipment-specific procedures. A single generic policy that says “lock out all energy sources” instead of separate procedural steps for each machine, which §3314(g)(2)(A) requires.
- Tagout used where lockout is feasible. A tag hung on a control that could accept a lock. Under §3314(d), lockable controls must be locked out or positively sealed.
- Unjamming left out of scope. Workers clearing jams without controlling energy, because the program treated unjamming as a production task rather than a servicing activity.
- No documented annual inspection. Missing the periodic verification §3314(j) requires at least once a year.
- No procedure verification step. Procedures that stop at “apply lock” and never confirm zero energy before work begins.
- Incomplete training records. No documentation of who was trained, when, and on what, for authorized, affected, and other employees.
- Stored energy not addressed. Procedures that isolate the main power source but ignore residual hydraulic, pneumatic, or thermal energy.
- No group lockout or shift-change provisions. Missing steps for jobs that span crews or shifts, where lockout responsibility has to transfer cleanly.
- LOTO training documentation not aligned with the IIPP. Training records that sit in isolation instead of aligning with the facility’s IIPP recordkeeping under §3203, as §3314(l)(4) expects.
The single most common finding is the second one: no equipment-specific procedures, or generic ones that no worker could actually follow. That is the gap that turns a document review into a citation. We explain what a usable, machine-specific procedure contains in our piece on equipment-specific lockout/tagout procedures.
Worried your LOTO program would not hold up to a Cal/OSHA inspection? Call (925) 551-7300 or request a consultation. We come to your facility, review your program and procedures against §3314, and show you exactly which findings an inspector would write up.
What a Cal/OSHA Inspector Actually Checks
Inspectors typically start by asking for the written program and the procedures for specific machines. From there, the audit moves to the floor. They pick a piece of equipment, ask for its procedure, and check whether the procedure matches the machine in front of them. A program that reads well but does not account for a machine’s real energy sources fails that test quickly.
When we walk a facility before an inspection, we check the same things in the same order. Use this as your own pre-inspection checklist:
- A written program that references Cal/OSHA Title 8, §3314, not federal OSHA alone
- A separate, machine-specific procedure for each piece of equipment that needs one
- Lockout (not just a tag) on every control that can accept a lock
- Unjamming addressed as a servicing activity covered by the program
- A shutdown sequence that releases stored energy before work begins
- A verification step that confirms zero energy on the actual machine
- Documented annual inspection of each procedure, performed by an authorized employee other than the one who normally uses it
- Training records for authorized, affected, and other employees
- Group lockout and shift-change procedures where the work calls for them
- LOTO training documentation that aligns with the facility’s IIPP recordkeeping under §3203
If you can produce all ten without scrambling, you are in good shape. If a few of these make you pause, those are the gaps an inspector would likely find first.
What a Citation Costs
Cal/OSHA sets its own penalty amounts. Under California Code of Regulations, Title 8, §336, a serious violation carries a penalty of currently up to $25,000 per violation. A willful or repeat violation can currently reach $162,851 per violation. General and regulatory violations currently run up to $16,285. (Cal/OSHA adjusts these amounts periodically; figures current as of 2025.)
Two points matter more than the dollar figures. First, penalties are assessed per instance. If twelve machines lack a compliant procedure, that can be counted as separate findings rather than one. Second, repeat violations escalate. A finding that goes uncorrected, then surfaces again at a later inspection, moves into the higher penalty range. The cost of fixing the program ahead of time is almost always lower than the cost of a repeat citation.
How to Prepare Before an Inspection
Most of these findings are fixable before an inspector ever arrives. The checklist above is the place to start: work down it, and the gaps that make you pause are the ones to close first.
If that review surfaces more than you can handle on your own, an outside review against §3314 is the most direct path. For facilities that suspect the gaps run beyond lockout/tagout, an EHS gap assessment checks your full program set against the California requirements that actually apply, and lockout/tagout is often where it starts.
For a structured starting point across all your programs, use our EHS compliance audit checklist.
Did a Cal/OSHA inspection turn up lockout/tagout findings you need to close? Call (925) 551-7300 or request a consultation. We come to your facility, identify every §3314 gap, and develop the program and equipment-specific procedures to correct them.
