In the plant I work in, LOTO would probably be required if another operator walking by could reset the E-stop and close the gate, injuring the worker attending to the "emergency". OSHA refers to hazardous energy control, and kinetic energy of moving parts (or chemicals, pneumatics, hydraulics, etc.) can be just as deadly as electricity.
FWIW, all the equipment I design has magnetic contactors and the E-stop and interlock devices are always ahead of the start switch/holding contact.
