- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Clarification with
regard to the applicability of the Lockout/Tagout Standard
to inspections conducted by authorized employees.
- Information Date: 1996
October 29, 1996
Mr. Stephen M. Mabley, MS, CIH
Director of Safety and Health
11933 Tech Road
Silver Spring, MD 20904
Dear Mr. Mabley:
This is in response to your letter
of November 21, 1995, addressed to Ms. Patricia Clark, former
Director of this Directorate. In your letter, you requested
clarification with regard to the applicability of the Lockout/Tagout
Standard, 29 CFR §1910.147, to inspections conducted
by authorized employees. Please accept our apologies for the
delay in responding to you.
In your letter, you inquired whether
it is the intent of OSHA by stating that "an authorized employee"
shall conduct periodic inspections in the Lockout/Tagout Standard,
to preclude consultants and other third parties from conducting
required periodic inspections and audits of a company's Energy
Control Program. Pursuant to 1910.147(c)(6)(i)(a), a periodic
inspection must be performed by an authorized employee. For
the purpose of complying with the intent of this standard,
authorized employee means a qualified person whom the authority
and responsibility to perform a specific lockout or tagout
inspection has been given by the employer. A qualified person
is a person who has been trained and has demonstrated proficiency,
in compliance with 1910.147(c)(7), to perform servicing and
maintenance on the machine or equipment to be inspected.
Therefore, please note that the function
of conducting periodic inspections by consultants would meet
the above criteria for the purpose of complying with the lockout/tagout
Thank you for your inquiry. If you
need further assistance, please contact Alcmene Haloftis of
my staff at 202-219-8031.
John B. Miles, Jr., Director
Directorate of Compliance Programs