Three paragraphs.
Three-quarters of every citation.
Lockout/tagout is in OSHA's top five most-cited standards every year — 2,443 citations in FY2024, 2,177 in FY2025. When OSHA publishes the breakdown by paragraph, the same three lead, in the same order, year after year. None of them is about a lock.
Citations by paragraph
Source: OSHA subsection breakdown for FY2023, as presented by OSHA and reported by Safety+Health and EHS.com. The top-five order — (c)(4), (c)(7), (c)(6), (c)(1), then (d) — held for FY2023 through FY2025. Totals for FY2024 and FY2025 from OSHA's annual Top 10.
The top three are the three that require a record
Read the standard and the pattern is obvious once you see it. (c)(4) requires a documented procedure for each machine. (c)(7) requires that training be given — and, in practice, that you can show who was trained for what and when. (c)(6) requires an inspection of each procedure at least annually, by someone independent of it, and that the employer certify that it happened.
Together those three were 1,583 of 2,139 citations — 74%. Not "the locks were missing." Not "nobody isolated the machine." The procedure was not written down for that machine; the training could not be shown; the annual inspection did not happen or could not be proven. The controls may well have been in place. The record was not.
That is a different problem from the one most lockout products solve, and it is a cheaper one to fix — if the record is the kind of thing that exists as a consequence of doing the work, rather than a thing someone has to remember to assemble before the inspector arrives.
One report per paragraph
Each of the three is a specific document with a specific shape. These are real samples, generated by Setyr from a synthetic site, free to download. Nothing here is a mock-up.
A documented procedure for each machine, with the steps, the points and the verification.
The worked examples show the shape; your own are the record.
See the shapeA record, per employee, that they were trained for their role — and retrained when the procedure or the job changed.
Training & qualification matrix (c)(7)
Sample reportAt least annually, per procedure, by someone other than its user, with the deviations and who inspected.
Periodic review attestation (c)(6)
Sample reportThe samples include the cases that matter: a procedure never inspected, an inspector who was not independent and the override reason recorded, an authorized employee who was never trained. A report that shows only the compliant rows is not an attestation. More on what makes a report proof →
Citation counts are OSHA's and are reproduced with their fiscal year and source. A citation under a paragraph does not mean the record was the only deficiency, and a complete record does not make a programme compliant — compliance is a property of how the programme is run. The reports above are records of data held in Setyr; they are not audits or certifications.