The numbers tell a familiar story. In OSHA’s fiscal year 2025 Top 10 Most Cited Standards list, lockout/tagout violations ranked fifth with over 2,100 citations — the same position they have occupied for years [1]. But behind the statistics, 2025 brought a series of preventable fatalities that exposed recurring weaknesses in how organisations manage energy control programmes.
These were not fringe operations cutting corners. They were established companies with documented safety programmes. Understanding what went wrong — and why — is essential for any safety manager serious about preventing similar outcomes at their own facility.
The Incidents That Defined 2025 : Deadliest LOTO Failures
Taylor Farms, New Jersey — May 2025
A worker at Taylor Farms’ fresh-cut vegetable processing facility in Swedesboro, New Jersey was killed while cleaning and sanitising processing equipment. The machinery unexpectedly energised during maintenance. OSHA’s investigation identified 16 violations, primarily centred on systemic failures in the company’s lockout/tagout programme. Investigators found that the employer had failed to implement effective energy-control programmes and had not adequately trained employees on LOTO requirements. The proposed penalty exceeded $1.1 million [2].
It is also worth noting that this was not Taylor Farms’ first brush with OSHA. Since 2015, OSHA has published six investigations into this same Swedesboro facility, including multiple fingertip amputations involving food slicers and unguarded conveyors [3]. That history of repeated incidents at a single site tells us something important: having a LOTO programme on the books is not the same as having one that actually works on the plant floor.
The critical lesson here is the word “systemic.” This was not a case of one employee skipping a step. The entire energy control programme had gaps that allowed the incident to occur.
Cintas Corporation, North Carolina — July 2025
At Cintas Corporation’s facility in Greensboro, North Carolina, 59-year-old Jasbeer Singh — a 25-year company veteran — was fatally crushed when an industrial dryer’s cabinet closed on him during routine lint filter cleaning. The dryer remained energised because lockout/tagout procedures had not been applied. OSHA’s inspection, which ran from July 2025 through January 2026, uncovered multiple violations — $16,550 specifically for the lockout/tagout failure, plus two additional penalties of $14,895 each for confined space violations including failure to test air quality and inadequate hazard identification. Total proposed penalties exceeded $46,000 [4].
What makes this case particularly sobering is the experience level of the worker involved. With 25 years at the company, this was someone who knew the equipment intimately. But that familiarity can work against you. Complacency in routine tasks — particularly on equipment employees interact with daily — is a risk that classroom training alone cannot eliminate. When a task feels routine, the temptation to skip steps grows. And without a system that enforces procedural discipline, even the most experienced technician is vulnerable.
The Common Thread: Programme-Level Failures
When you examine these incidents and the broader pattern of 2025 LOTO citations, the root causes are remarkably consistent. They are not failures of individual workers. They are failures of the systems those workers operate within. If you are a safety manager, these are the gaps worth examining honestly in your own programme.
Procedure accessibility at the point of work. OSHA 1910.147 requires machine-specific energy control procedures. But having a procedure documented somewhere and having it accessible to the right person at the right time are two entirely different things. In facilities running multiple shifts with rotating crews, the gap between “procedure exists” and “procedure is actually used” grows wider with every shift change. Ask yourself: if a technician on the night shift needs the lockout procedure for a specific machine right now, how quickly can they get it? If the answer involves walking to an office, finding a binder, and flipping through pages, that is a gap worth closing.
Verification of correct equipment identification. In complex production environments, technicians may service dozens of similar machines. Misidentifying which machine requires isolation — or which energy sources apply to a specific piece of equipment — accounts for a significant share of LOTO incidents. The more equipment a facility operates, the greater this risk becomes. This is especially true during shift handovers, when one team picks up where another left off without full context of what has and has not been isolated.
Audit trail integrity. OSHA requires periodic inspections of energy control procedures at least annually under 1910.147(c)(6). These inspections must review each authorised employee’s responsibilities and confirm that procedures are being followed correctly. When audit records are incomplete, inconsistent, or difficult to retrieve, the first sign of a problem often comes from an inspector rather than an internal review. And by that point, you are already on the back foot.
Training documentation and currency. The Cintas case highlighted how even experienced employees can be exposed when training programmes do not evolve alongside operational changes. Equipment gets modified, new energy sources are introduced, and procedures are updated — but if the training records do not reflect who has been retrained and when, you have a compliance gap that is invisible until someone gets hurt. Documenting who is authorised for which procedures, and when retraining is due, is a requirement that many facilities struggle to maintain at scale.
What Effective Programmes Do Differently
The organisations that consistently maintain strong LOTO compliance share several practices that go beyond basic regulatory adherence. None of these are revolutionary — but the discipline to implement them consistently is what separates facilities that avoid incidents from those that do not.
They treat procedures as living documents, not static paperwork. When equipment is modified, replaced, or relocated, the associated energy control procedure is updated immediately — not deferred to the next scheduled review cycle. More importantly, they ensure that these updates reach every authorised employee without relying on manual distribution. If you have ever tried to track down and replace every printed copy of an updated procedure across a multi-shift facility, you know how quickly that process breaks down.
They build verification into the execution process itself. Rather than relying solely on training and memory, they use confirmation steps — such as equipment-mounted identifiers that technicians must interact with during the lockout sequence — to ensure the correct machine is being isolated. Digital platforms like Zentri use QR codes on equipment for exactly this purpose: a technician scans the code to confirm they are working on the correct asset before proceeding with the lockout, which eliminates one of the most common sources of human error. It is a simple step that adds seconds to the process but removes an entire category of risk.
They make compliance the path of least resistance. This is perhaps the most underappreciated principle in safety programme design. If following the correct procedure requires more effort than taking a shortcut, shortcuts will eventually happen — no matter how many toolbox talks you run. The best programmes reduce friction by putting the right information in front of the right person at the right time, whether that means digital access on a mobile device at the point of work or clearly posted visual guides at each isolation point.
They use their own operational data to spot weaknesses before an incident or inspection reveals them. Tracking which procedures are accessed most frequently, which machines generate the most near-misses, and which shifts have lower compliance rates turns LOTO management from a reactive programme into a proactive one. You cannot fix what you cannot see, and the organisations that take data seriously tend to catch problems early.
What Safety Managers Should Do Now
If the 2025 enforcement actions highlight one thing, it is that OSHA is not reducing its focus on lockout/tagout. Penalties for willful violations now reach $165,514 per instance, and repeat violators — as Taylor Farms discovered — face penalties well into seven figures [5].
For safety managers reviewing their own programmes in light of these incidents, the most productive steps are practical ones. Walk the plant floor and observe whether employees are actually referencing procedures during lockout — not just whether procedures exist somewhere. Verify that your annual periodic inspections are documented with specific findings, not generic sign-offs that say “all good.” Confirm that your training records can demonstrate exactly who is authorised for which procedures and when they were last reviewed.
And perhaps most importantly, talk to the people doing the work. Ask your technicians where they feel the process is weakest. Ask them where they are tempted to take shortcuts. The answers might be uncomfortable, but they are far less costly than learning the same lessons the hard way.
The facilities that avoided serious incidents in 2025 were not lucky. They were deliberate about building LOTO programmes that work in practice — not just on paper.
References:
[1] OSHA Top 10 Most Cited Standards, Fiscal Year 2025. Presented at the National Safety Council Congress & Expo, September 2025. ohsonline.com
[2] U.S. Department of Labor News Release, November 24, 2025. osha.gov
[3] Work Safety 24/7, “OSHA proposes over $1 million fine on Taylor Fresh Foods,” December 2025. worksafety247.com
[4] WFMY News 2, “Cintas cited for serious safety violations after investigation into fatal incident at Greensboro facility,” February 2026. wfmynews2.com
[5] OSHA Penalty Adjustments, effective January 2025. Maximum penalty for willful or repeat violations: $165,514.
Matthew is Co-Founder of Zentri, a digital lockout/tagout safety compliance platform for manufacturers, and also runs The Lock Box, a European distributor of lockout/tagout equipment and safety devices. He works with energy isolation from both the software and hardware side daily.
