One of the most overlooked LOTO program requirements is the "Means to Enforce".

OSHA regualtions state the following about procedures to enforce the program...

Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section.  The procedures shall clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, and the means to enforce compliance including, but not limited to, the following:
1910.147(c)(4)(ii)(A) A specific statement of the intended use of the procedure;
1910.147(c)(4)(ii)(B) Specific procedural steps for shutting down, isolating, blocking and securing machines or equipment to control hazardous energy;
1910.147(c)(4)(ii)(C) Specific procedural steps for the placement, removal and transfer of lockout devices or tagout devices and the responsibility for them; a
1910.147(c)(4)(ii)(D) Specific requirements for testing a machine or equipment to determine and verify the effectiveness of lockout devices, tagout devices, and other energy control measures.