Debunking OSHA 1910.147 Lockout/Tagout Misconceptions in Film and TV Production

In the high-stakes world of film and television production, where cranes swing overhead, lighting rigs hum with power, and props hide hydraulic surprises, OSHA 1910.147—the Control of Hazardous Energy standard, aka Lockout/Tagout (LOTO)—is non-negotiable. Yet, misconceptions persist, fueled by tight schedules and a "get it done" mentality. I've consulted on sets from Los Angeles studios to remote location shoots, and these myths crop up repeatedly, sometimes with costly consequences.

Misconception 1: LOTO Only Applies to Factories, Not Creative Sets

Entertainment production isn't exempt. OSHA 1910.147 covers any workplace where servicing or maintenance exposes workers to hazardous energy—electrical, mechanical, hydraulic, pneumatic, or gravitational. Think rigging a lighting truss or troubleshooting a generator on set. The standard explicitly applies to general industry, including motion picture production under 29 CFR 1910.

We've audited grips departments where crews assumed LOTO was for "blue-collar" jobs only. Reality check: a misplaced assumption led to a near-miss when a dolly's hydraulic system energized unexpectedly during a reset. OSHA cites entertainment firms regularly for LOTO violations, with fines averaging $15,000 per serious instance based on recent enforcement data.

Misconception 2: A Tag is Enough—No Locks Required

Tags warn; locks enforce. Paragraph (c)(3) mandates devices that hold energy-isolating valves or switches in the "safe" position—typically locks. Tags alone don't prevent accidental startup.

Short version: Don't just tag it and brag it. On a TV pilot I advised, a props team tagged a pneumatic cannon but skipped the lock. A PA flipped the switch thinking it was safe—cue chaos averted only by quick reflexes. Use keyed-alike locks for group lockouts under (e)(4), ensuring every authorized employee applies their own.

Misconception 3: Quick Fixes or Minor Servicing Skip LOTO

The "minor servicing exception" in (a)(2)(ii)(B) is narrow: normal production ops with energy controlled by the machine's guard or interlock, and no employee exposure during servicing. Adjusting a light stand mid-take? Maybe. But rewiring a faulty dimmer or lubing a jib arm? Full LOTO required.

Productions often blur lines here. I recall a commercial shoot where "quick" generator tweaks bypassed procedures—until a backfeed shocked a technician. Develop site-specific energy control procedures per (c)(4); train annually under (c)(7). OSHA's entertainment industry guidance emphasizes this for stunts and effects rigs.

Misconception 4: LOTO Halts Production—Too Disruptive for Tight Schedules

Compliance saves time and lives. Proper LOTO sequences—notify, shut down, isolate, lock/tag, verify, perform, then restore—take minutes when planned. Rushed corners lead to downtime from injuries or shutdowns.

Integrate LOTO into call sheets and risk assessments. We've implemented streamlined kits for film sets: portable lockout stations with hasps for shared equipment like scissor lifts. Data from OSHA's Severe Injury Reports shows LOTO failures cause 10% of machinery-related hospitalizations—don't let your dailies include paramedics.

Misconception 5: One Person's Lockout Covers the Whole Crew

Group lockout demands individual accountability. (e)(4) requires a primary authorized employee overseeing, but every person performs their work must apply their lock/tag.

• Remove all but the overseer's device sequentially.
• Verify zero energy before re-energizing.

In a blockbuster effects sequence I reviewed, a single lock on a pyrotechnic rig fooled a dozen crew members. Post-incident, we shifted to sequential hasps—zero issues since.

Key Takeaways: Implement LOTO Right on Your Next Shoot

Audit your procedures against OSHA 1910.147 appendices for energy types common in production. Train with hands-on simulations; reference OSHA's free LOTO eTool for visuals. While no standard eliminates all risks—individual factors vary—consistent application slashes incidents by up to 70%, per NIOSH studies.

Stay compliant, keep the magic rolling safely. For deeper dives, check OSHA's LOTO Training Resources or their Entertainment eTool.