If your people service or maintain equipment that could unexpectedly energize or release stored energy — electrical, hydraulic, pneumatic, mechanical, thermal — OSHA's Control of Hazardous Energy standard requires documented energy-control procedures. This is where a lot of programs fall short: they have a general LOTO policy but not the specific procedures the standard actually calls for.
A compliant LOTO program generally requires:
Written energy-control procedures — and critically, these are expected to be specific to the equipment. A single generic procedure covering everything usually doesn't satisfy the standard; the procedures need to reflect the actual energy sources and steps for the machines being serviced.
Periodic inspections — documented periodic reviews of the procedures to confirm they're being followed and still accurate.
Training and retraining — for authorized and affected employees, documented.
The machine-specific point
The most common LOTO gap isn't the absence of a policy — it's the absence of machine-specific procedures. The written program is the framework; the equipment-specific procedures are what make it real and what an inspector or reviewer looks for.