- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Electrical safety related
work practices standard.
- Information Date:1992
January 7, 1992
Mr. J. J. Barry
International President
International Brotherhood of Electrical Workers
1125 Fifteenth Street, N.W.
Washington, D.C. 20005
Dear Mr. Barry:
Thank you for your letter of August 7,
in which you expressed concerns about compliance with and asked
for an accurate interpretation of the Occupational Safety and Health
Administration's (OSHA) Electrical Safety-Related Work Practices
standards. The request relates to a document forwarded by the Philadelphia
Regional Office titled: "A Sample Lockout/Tagout Program." Please
accept my apology for the delay in this response.
As you are aware, the primary topic of
the referenced document is the requirements of 29 CFR 1910.147,
the Control of Hazardous Energy (Lockout/Tagout). The August 6,
1990 promulgation of the standard for Electrical Safety-Related
Work Practices (29 CFR 1910.331 to .339) allows compliance with
29 CFR 1910.147(c) through (f) to constitute compliance with 29
CFR 1910.333(b)(2); therefore, to that extent, many of the requirements
of the lockout/tagout standard are equivalent to the locking and
tagging requirements of the newer standard.
The "Model Programs," prepared by our field
staff, is intended to provide small employers more detailed guidance
relative to the compliance with the new standards. It is also intended
to improve the small employer's awareness and understanding of the
potentially hazardous exposures of his/her employees when they engage
in certain duties. Employers who adopt the model program as company
policy, without modifying the program to fit their individual needs,
would not necessarily ensure compliance with the standards. This
is particularly true when applying the program to electrical workers
who must comply with the requirements of the Electrical Safety-Related
Work Practices standard. The program is simply a guide for the use
of small employers who find it difficult to assimilate the requirements
specified by the standard.
OSHA does not discourage employers or organized
labor from disciplining workers for the purpose of improving workplace
safety and health and ensuring adherence to work safety rules; however,
the "Model Program" has been modified to exclude all such discussion
and/or reference to that topic. A copy of the modified "Model Program"
is enclosed.
If we may be of further assistance, please
contact us.
Sincerely,
Gerard F. Scannell
Assistant Secretary
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