- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Work permits in lockout/tagout standard requirements
- Information Date:1991
April 10, 1991
Mr. Duane Barns
DOW Chemical U.S.A.
2020 DOW Center
Midland, Michigan 48674
Dear Mr. Barns:
This is in response to your letter of January
31, to Joe Bode of my staff, concerning the use of work permits
for compliance with aspects of the lockout/tagout standard requirements.
As you are aware, 29 CFR 1910.147(c)(4)(i)
requires that employers document the procedure by which the hazardous
energy of equipment is isolated during servicing/maintenance operations.
During the meetings on the lockout/tagout
regulations, discussions were conducted concerning the use of a
"generic" procedure for the various types of energy which would
be encountered at a facility. The generic procedure would have to
be included as a component of the company's lockout/tagout procedure
and would additionally require that the company procedure clearly
enunciate the further specific requirements for servicing and maintenance
"work authorization permits". The company procedure would have to
specify that the work permit identify the equipment to be serviced,
the types and unique energy characteristics to be encountered, methods
for safe work, and the process or procedures to be used to accomplish
the task.
It was recognized during the earlier discussions
that the comprehensive use of a work permit system would be more
efficient and relevant to the tasks than would be a "cookbook" type
procedure which might not fully account for a specific situation
as it had occurred. It was recognized that at the time of servicing
and maintenance the operations engineers and personnel are in the
logical position to identify the tasks and the energy related hazards
which would be encountered during maintenance operations and could
best document a safe procedure for the tasks. The company procedure
must, however, specify that the employees are required to perform
their work in accordance with the terms and limitations of the work
permit.
It should be noted that the effective use
of a work permit system is compatible primarily with an industrial
operation where sufficient engineering and administrative support
is available. A company procedure which mandates that "generic"
procedures are to be augmented with specific operational procedures
as part of a required work permit system provides for compliance
with the standard.
Thank you for your interest in workplace
safety.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
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