- Record Type: Interpretation
- Standard Number: 1910.147;1910.333
- Subject: Control of Hazardous
Energy Sources (Lockout/Tagout).
- Information Date:1991
January 29, 1991
Mr. Stephen C. Yohay
Jones, Day, Reavis and Pogue
Metropolitan Square
1450 G Street, N.W.
Washington, D.C. 20005-2088
Dear Mr. Yohay:
This is in response to your letter of November
30, 1990, to Mr. Thomas Seymour, Deputy Director of the Directorate
of Safety Standards, regarding 29 CFR 1910.147, Control of Hazardous
Energy Sources (Lockout/Tagout).
You expressed interest in a clarification
of the Occupational Safety and Health Administration (OSHA) interpretation
and met with appropriate representatives of OSHA on December 7,
1990, to discuss Union Carbide's approach to compliance with the
standard. During the meeting you displayed a videotape of Union
Carbide's group lockout policy and input was freely given to representatives
of Union Carbide by our Safety Standards and Compliance Programs
staffs in response to all of your questions.
You asked specifically in your letter whether,
in a group lockout situation, an employee must himself be performing
service or maintenance on de-energized equipment to be eligible
to apply a lock or tag for his own protection and/or the protection
of others. If only one person is required to perform the servicing
or maintenance task, then that person must apply the lock or tag
to the energy isolating device. If two or more persons are required
for the maintenance or servicing, then group lockout procedures
are applicable as described in 29 CFR 1910.147(f)(3) and STD 1-7.3,
paragraph H.8.(a. through h.), with detailed discussion and acceptable
examples given in Appendix C, paragraph B. The Type A example given
on page C-5 of Appendix C calls for each employee performing service
or maintenance to apply a personal lock or tag upon each energy
isolation device. The Type B, C, and D examples given in pages C-5
and C-6 would allow employees who are not performing the individual
servicing or maintenance tasks to place the locks or tags on the
energy isolation devices; however, this allowance must be addressed
in the employer's written procedures and the procedures must afford
the employees a level of protection equivalent to that provided
by the use of personal locks or tags. Each servicing/maintenance
employee in all cases must be permitted to verify that all energy
sources are isolated and to affix a personal lock or tag either
on each energy isolation device or on the group lockout device,
group lockbox, or comparable mechanism.
During our meeting with you on December
7, 1990, your concern about the interface of the Electrical Safety
Related Work Practices standard with the Lockout/tagout was also
briefly discussed. Our recommendation was that the written procedures
being developed by your client for compliance with the Lockout/Tagout
standard should incorporate requirements for compliance with the
lockout and tagging portions of the Electrical Safety Related Work
Practices standard. The latter standard was written to allow for
such combining, and at 29 CFR 1910.333(b)(2) it specifies how this
may be accomplished.
Thank you for your interest in improving
employee safety and health. If we can provide further assistance,
please do not hesitate to contact us.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
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