OSHA Targets November Proposal to Revisit Computer-Based LOTO Controls
OSHA is targeting November 2026 for a proposed lockout/tagout rule that could reconsider whether computer-based controls qualify for hazardous energy isolation, ISHN reports. Nothing is proposed yet, and 29 CFR 1910.147 still governs.
Where the Rulemaking Stands
Project stage: Pre-proposal. As of October 2026, the Lock-Out/Tag-Out Update (RIN 1218-AD00) sits in the proposed rule stage on the federal regulatory agenda. The agenda lists November 2026 as the anticipated date for a notice of proposed rulemaking. ISHN stresses that this is a target, not a guarantee. OSHA has not published regulatory language, so no comment window is open.
The sticking point is the control-circuit exclusion. Section 1910.147(b) defines an energy-isolating device as a mechanical device that physically prevents the transmission or release of energy, and it specifically excludes push buttons, selector switches and other control-circuit-type devices. A stop button can halt a motor while power stays connected. Under today’s rule, control-circuit devices generally cannot serve as the sole energy-isolating device during servicing. The standard dates to 1989, and OSHA issued a request for information in May 2019 on the safety benefits and limits of these devices. ISHN says the agency could set conditions for qualifying systems, add safeguards or limit their use to specific applications.
What It Means for Subcontractors
- Keep isolating physically. An electronic stop command or interlock is not authorization to start maintenance. Safety managers at industrial maintenance, electrical and mechanical subs should confirm crews still lock out and verify isolation at the disconnect, valve or breaker on every job.
- Audit automated-equipment procedures before year-end. Pull LOTO procedures for equipment with remote operation, photo-eyes, motion locks or integrated safety circuits, such as powered doors and production lines. Confirm each procedure names every energy source and isolation point, and document how the control circuit can fail.
- Recheck stored hydraulic and pneumatic energy. A system can block a pump restart while pressure stays trapped in a line, and a raised component can still descend. Hydraulic and pneumatic service techs should verify that procedures cover bleeding pressure, restraining elevated loads and re-accumulation during the job.
- Assign someone to watch the Federal Register from November 2026. Name one owner, whether the safety director or a compliance contact, to check for a notice of proposed rulemaking under RIN 1218-AD00. If it publishes, flag the comment deadline internally and decide whether to comment. Subs that service automated lines have field experience on where control circuits fail.
- Don’t rewrite procedures yet. Any change depends on language OSHA hasn’t released. Hold training updates until a proposal shows which systems qualify and under what conditions, and keep current authorized-employee training on schedule.
