Can AI Draft a Lockout Tagout Procedure? What Must Be Verified

Yes, AI can draft a lockout tagout procedure for a workshop machine from its manual and a few notes, usually in minutes. It cannot see your machine. A competent person must walk it, find every energy source, test that isolation really works and sign the procedure before anyone relies on it.

The draft saves the tedious part: turning a 90-page manual into numbered steps with consistent wording, each tied to a manual page. The checking is the part that keeps fingers attached, and no chatbot can do it from a desk. A router whose manual mentions one isolator can turn out to have three separate supplies once someone follows the cables, and only the person at the machine finds the other two.

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What the draft is good for, and what it cannot know

A lockout tagout procedure (often shortened to LOTO) is the written method for making a machine safe to work on: switch it off, cut every source of energy, lock the isolators so nobody can switch them back on, release or block any stored energy, and then prove the machine cannot move. Servicing a blade, clearing a jam or changing a tool is exactly the kind of work the hazardous-energy rules were written for.

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AI is good at the language work. Given the manual's maintenance chapter, it will pull out the isolator location, the pneumatic supply, the warnings about residual pressure, and put them in a numbered order with plain verbs. It will also keep the layout the same from one machine to the next, which makes a folder of procedures easier for crews to read.

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It is poor at everything that depends on your particular site:

• The manual describes the machine as shipped. Yours may have had an extraction unit, a second vacuum pump or a light curtain added later, each with its own supply.
• The manual does not know where your isolator actually is, which breaker feeds it, or that two machines share one compressed-air drop.
• A chatbot fills gaps with typical answers. If the manual does not mention a flywheel run-down time, the draft may still give a figure that sounds right. That is how a hallucination looks in a safety document: confident, specific and unsourced. The tutorial on AI hallucinations for business owners explains why it happens.

So the working rule is simple. Everything in the draft that came from the manual can be checked against the manual. Everything that did not come from the manual must come from a person looking at the machine.

The example machine: a CNC router in a signage workshop

To keep numbers concrete, take a small signage company with a flatbed CNC router that cuts acrylic and aluminium composite panel. Three people use it. The manual runs to 88 pages. The owner wants a one-page lockout procedure for blade and collet changes, bed cleaning and servicing the dust extraction.

This is an illustration, not a real machine's data. The figures below show the kind of detail that matters.

Getting a first draft you can actually work with

Paste only the relevant manual chapters, not the whole document, and tell the AI to quote the page for every statement. That one instruction makes checking far quicker, because each line of the draft points back to a page you can open.

You are helping me draft a machine-specific lockout tagout procedure for a workshop.

Use ONLY the manual extracts below. For every step, add the manual page or section in square brackets.
If the manual does not say something, write "NOT IN MANUAL - verify on machine" instead of guessing.
Do not invent voltages, pressures, run-down times or breaker numbers.

Output:
1. Machine name and purpose of this procedure (one sentence)
2. Energy sources the manual mentions (electrical, pneumatic, hydraulic, gravity, springs, vacuum, other)
3. Numbered steps: preparation, shutdown, isolation, applying locks and tags, releasing stored energy, verifying isolation
4. Steps to restore the machine to service
5. A list of every item marked "NOT IN MANUAL"

Manual extracts:
[paste chapters]

The "NOT IN MANUAL" instruction is doing the heavy lifting. It turns the AI's gaps into a to-do list for the person with the clipboard. Without it you get a smooth document in which invented details and sourced details look identical.

Here is an illustrative slice of what comes back for the router:

Energy sources named in the manual
- Electrical: main isolator on the control cabinet, 3-phase supply [p. 14]
- Pneumatic: 6 bar supply to the tool-change cylinder and vacuum bed valves [p. 21]
- Vacuum: separate vacuum pump, supply NOT IN MANUAL - verify on machine
- Gravity: Z-axis spindle carriage can drop if the brake releases [p. 33]

Steps
1. Tell the operators nearby and finish or abort the current job. [p. 30]
2. Stop the spindle and wait for it to coast to a halt. Run-down time: NOT IN MANUAL - verify on machine
3. Switch the main isolator to OFF. [p. 14]
4. Close and lock the pneumatic supply valve. [p. 21]
5. Bleed the air line using the bleed valve. [p. 21]
...

That output already shows three things a person must resolve: the vacuum pump, the spindle run-down time, and whether "close and lock the pneumatic supply valve" means a valve that can physically take a padlock. Good drafts raise questions like these. Poor ones hide them.

Walking the machine: finding what the manual left out

The competent person takes the draft, a clipboard and the manual to the machine and works through it in a fixed order. The point is to follow every cable, pipe and hose from the machine back to where it is isolated, not to trust the diagram.

Energy sources to trace by eye

• Electrical. Trace every cable leaving the control cabinet. Count the separate supplies: main power, the extraction unit, a vacuum pump, a chiller, a separate control or UPS feed. Each must be isolated, or the procedure must say why not.
• Compressed air. Find the drop, the filter-regulator and the shut-off valve. Check the valve can take a lock and that it sits upstream of the machine, not just at the machine's own manifold.
• Vacuum and extraction. Pumps can restart on their own from a pressure switch. Check their isolators separately.
• Stored energy. Springs, gas struts, a raised carriage, accumulators, capacitors that hold charge after switch-off, a flywheel that keeps turning.
• Gravity. Anything that can fall when a brake or pressure is released. It needs blocking, not just switching off.
• Process hazards. Hot surfaces, sharp tooling and trapped material are not energy sources but belong in the procedure's warnings.

What the walk found on the router

Here is a filled-in comparison of the draft against what was actually there (illustrative):

Five lines, three real problems the draft could not have known: a second supply with no lock point, a valve that cannot be locked and a carriage that falls. This is the value of the walk, and why a signed-off AI draft with no walk is dangerous.

The test: proving the machine cannot start

OSHA's standard on the control of hazardous energy, which OSHA publishes as 29 CFR 1910.147, lists six application steps in order: preparation for shutdown, machine or equipment shutdown, isolation, applying the lockout or tagout device, dealing with stored energy, and verification of isolation. The last is the one people skip. OSHA's sample procedure, a non-mandatory appendix to the standard, describes it as operating the push button or other normal controls to make certain the equipment will not operate, then returning the controls to neutral or off.

The standard also says the written procedure must include specific requirements for testing a machine to confirm that the locks, tags and other energy control measures are effective. So the test belongs in the document, not just in someone's head. Your own regulator may word it differently; HSE's equipment and machinery pages are the place to start for its rules. The work-equipment regulations it explains (PUWER, regulation 19) require suitable means to isolate equipment from all its sources of energy, and say those means must be clearly identifiable and readily accessible. An isolator hidden behind a storage rack fails that test before anyone touches the machine.

For the router, the verification block the competent person wrote after testing reads like this:

Verification (after all locks are on)
1. Press START at the pendant. Expected: nothing. If anything moves or lights up, STOP - isolation is incomplete.
2. Try to jog X, Y and Z from the pendant. Expected: no movement.
3. Check the pressure gauge reads 0 bar.
4. Place the Z-axis block under the spindle carriage.
5. Return all controls to OFF before starting work.

Notice that every line has an expected result. A test with no expected result is not a test.

What the standard asks the document to contain

Read the regulator's text yourself rather than trusting a summary, mine included. In OSHA's standard the written procedure must clearly and specifically cover its scope, purpose, authorisation, rules and techniques, and include four items: a specific statement of the procedure's intended use; specific steps for shutting down, isolating, blocking and securing the machine; specific steps for placing, removing and transferring lockout devices and who is responsible for them; and specific requirements for testing that the measures work.

Two further points are worth checking against your own rules:

• Periodic inspection. OSHA's standard calls for an inspection at least once a year, carried out by an authorised employee other than the one using the procedure being inspected. A fresh pair of eyes catches the shortcut the regular user no longer notices.
• The single-source exception. OSHA's standard lets an employer skip a machine-specific written procedure only when eight conditions all apply, including a single readily identifiable energy source, no stored or residual energy and no history of accidents from unexpected start-up. A router with three supplies and a falling carriage is nowhere near it. The exception covers writing the procedure down, not the lockout itself.

Training is separate again. OSHA's hazardous-energy page says workers must be trained in the purpose and function of the energy control programme, and the standard requires authorised employees to be trained to recognise the hazardous energy sources in their workplace. A procedure on a wall does not train anyone.

A sign-off sheet to copy

This one-page sheet sits at the front of each machine's procedure. The filled-in values are illustrative.

MACHINE: Flatbed CNC router, bay 2
PROCEDURE VERSION: 3 (replaces version 2)
DRAFT PRODUCED FROM: manual pages 14-35, AI-assisted first draft
"NOT IN MANUAL" items resolved: 4 of 4

Walk-round (competent person)
[x] Every cable from the control cabinet traced to an isolator (3 found)
[x] Air drop and valve located, valve fitted with lock-off
[x] Vacuum pump isolator located and labelled
[x] Stored energy identified: carriage (blocked), air line (bled)
[x] Spindle run-down measured: 25 s, procedure says 30 s

Test
[x] Start attempted with all locks on: no movement (date and initials)
[x] Gauge read 0 bar (date and initials)

Corrections made to the AI draft: 6 (list attached)
Signed (competent person): ________   Date: ________
Second check (different person): ________   Date: ________
Next review due: after any change to the machine or its supplies

Keep the "corrections made to the AI draft" line. Over a few machines it tells you what the AI tends to miss in your shop, which is more useful than any general advice.

Where a convincing draft misled a reviewer

This one is an illustration, not a real incident. Picture a security installer's small fabrication bench, used for cutting enclosure plates, with a press brake beside it. The brake's AI-drafted procedure read well, listed the electrical isolator and the foot-pedal and stated that the hydraulic system "depressurises automatically within 10 seconds of shutdown". No manual page was cited for the figure, and the reviewer, reading quickly, accepted it because everything else was sourced.

The "cite the page" rule would have caught this: a number with no page reference is a flag. On the machine, the accumulator held pressure for several minutes. The corrected step reads: "Open the bleed valve and watch the gauge fall to zero before touching the tooling."

The lesson is a reviewing habit. Search the draft for numbers (seconds, bar, volts, kilograms) and check that each one traces to a manual page or a measurement taken that day. A number with neither is invented. The same technique works on proposals; the tutorial on catching made-up figures in AI-drafted proposals goes through it.

Other machines, other gaps the walk tends to find

The router is one pattern. A few quick sketches of where drafts typically fall short, from different kinds of workshop (illustrative):

• Panel saw in a signage workshop. The manual covers the motor isolator. The walk finds a sliding table with a gas strut and a dust extraction hose that keeps the blade guard open. Strut stored energy goes in the procedure.
• Air compressor at an HVAC contractor's yard. The draft isolates the electrics. The walk finds that the receiver tank holds pressure for days and that two other tools share the line. The procedure adds a receiver drain and a "tell the other users" step.
• Vacuum former at a signage company. The manual calls the heater bank "radiant". The walk adds a cooling time before anyone reaches into the oven, plus a separate isolator for the vacuum pump.
• Conveyor in a solar installer's warehouse. The draft locks out the drive motor but not the tensioner spring. The walk finds a pinch point at the tail pulley that needs guarding as well as isolating.
• Guillotine for sheet aluminium. The manual mentions the foot pedal. The walk finds a back-gauge motor with its own switch, so two separate isolations are needed.

In all five, the AI draft was a fair starting point and the gaps were things you can only see standing in the room.

Rewriting a vague step into one a tired operator can follow

AI drafts tend to produce steps that read correctly but leave room for interpretation. After the walk, rewrite each vague step so that two different people would do the same thing. An illustrative before and after from the router procedure:

The rewritten versions name the thing, the position and the colour. They are longer, and that is the point: someone doing this at the end of a shift should not have to decide what "isolate" means. You can ask the AI to make the same changes once you have the facts, giving it your corrected notes as input. It will happily polish the wording; it just cannot supply the facts.

Hours and cost for one machine's procedure

For a single machine like the router, expect roughly this (illustrative, for a shop doing it for the first time):

Most of the saving is in the first two rows. Writing a procedure from scratch is slow mainly because of formatting and wording, and that part is nearly free with AI. The hours spent standing at the machine do not shrink, and should not. The AI subscription is the smallest line. ChatGPT lists Plus at $20 a month and a Business standard seat at $20 a month billed annually ($25 monthly, from two users), and the business plan does not train on your files by default. Padlocks, lock-off devices and tags for even one machine will cost more than either.

Keeping the procedure true after the draft

A signed procedure goes stale in ordinary ways. Someone adds a dust extractor, replaces the spindle with a different model or moves the machine and the air drop with it. Set three triggers for reopening the file:

1. Any change to the machine, its guarding or its supplies.
2. Any near miss involving unexpected movement or start-up. Logging these is easier with a simple app; see logging near misses.
3. The annual inspection, done by someone other than the usual operator.

When a trigger fires, give the AI the old procedure and the change note and ask for a redline, then walk the changed part again. The same rule applies: the AI suggests the wording, the person confirms the facts.

If the plan is to roll this across a whole workshop, a short human-review routine helps. Setting up human review for AI work covers how to make the check part of the job rather than an afterthought, and the tutorial on writing a health and safety policy with AI covers the wider document this procedure would sit inside.

The short version for the person holding the clipboard

• Use AI for structure and wording, with a page citation on every step.
• Make it list what the manual does not say, and treat that list as your agenda for the walk.
• Count every supply, locate every isolator, find every store of energy, in person.
• Test with the real controls and write down the expected result of each test.
• Have a competent person sign, a second person check, and set the review triggers.

If you would rather map which of your shop documents are safe to draft this way, and which should stay fully human, that is the kind of thing an AI implementation consultation can sort out on a call; get in touch here.

Questions owners ask before using AI on safety procedures

Can I paste a machine manual into ChatGPT or Claude?

Usually yes for your own copy of the manual, but check the manual's licence wording and your plan's data settings first. A business plan that does not train on your content is the safer choice. Never paste anything that names staff, and keep the signed procedure in your own document system.

Does AI know what energy sources my machine has?

It knows what the manual says and what is typical for that type of machine. It does not know how your machine was installed, which extra supplies were added, or what is plumbed in beside it. Those only show up when a person walks the machine with the manual in hand.

Who counts as a competent person for signing off?

Someone with enough training, experience and authority to recognise every energy source on that machine and to test that isolation works. Your regulator's guidance defines the term for your sector, so read their wording rather than relying on a chatbot's summary.

How often should the procedure be reviewed?

Review it whenever the machine, its supplies or its guarding change, after any near miss involving unexpected start-up, and at least once a year. OSHA's standard requires an annual inspection by an authorised employee other than the person using the procedure. Check your own regulator's current wording.

Can the AI-drafted procedure go straight on the machine?

No. Print it only after the walk-round corrections are made, the test has been done on the real machine and the competent person has signed. A draft that was never tested is worse than none, because people will trust it.

Further reads

• Can ChatGPT Write a HACCP Plan for a Restaurant? What to Verify — Same pattern for a food-safety plan: AI drafts, a person verifies.
• AI Supplier Management: Track Prices, Lead Times, and Risk — Track the suppliers behind the locks, tags and spares you buy.
• How to Review an AI Tool After 90 Days: Keep, Fix or Cancel — Check after three months whether the drafting habit is paying off.
• Can AI Quote Machine Shop Jobs? What a Real ChatGPT Test Got Wrong — Another shop-floor task where AI helps and a person must check.
• Simpro Form Builder: Draft Job Sheets and Safety Checklists With ChatGPT — Turn the finished checklist into a digital form crews can fill in.
• Is It Worth Automating a Task You Only Do Once a Week? — Decide which recurring paperwork is worth drafting with AI.
• Can AI Quote an Injection Moulding Job? What an Engineer Must Check — Use AI to lay out an injection moulding quote, then see which four figures an engineer must confirm before it is sent.
• AI Tools and AI Development: The Complete 2026 Guide — the AI hub, including every tutorial in the AI-for-business series.

Sources: OSHA 29 CFR 1910.147 (control of hazardous energy) and its non-mandatory Appendix A sample procedure; OSHA's control of hazardous energy page; HSE's equipment and machinery pages; PUWER 1998 regulation 19 (isolation from sources of energy); ChatGPT pricing pages for Plus and Business. Check your own regulator's current text before adopting any procedure.