Standard Interpretations - Table of Contents|
| Standard Number:||1910.147; 1910.147(a)(1)(i); 1910.147(c)(5)(ii)|
October 11, 2006
Mr. Nick Demianovich
NATLSCO Risk and Safety
4 Corporate Drive, Suite 100
Lake Zurich, IL 60047
Thank you for your October 5, 2005 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements herein, and may not be applicable to any question(s)/scenario not delineated within your original correspondence. You had a specific question regarding the use of lockout/tagout devices when equipment is placed "out of service" for production reasons and not related to servicing or maintenance of the equipment. We apologize for the delay in responding to your request.
Scenario: Under 29 CFR 1910.147(c)(5)(ii), lockout/tagout devices ". . . shall not be used for other purposes; . . ." Additionally, 29 CFR 1910.147(a)(1)(i) states: "This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees.
Question: When equipment is placed in an "out of service" status for business or production purposes (e.g., poor efficiency, recycled, sold, etc.) and not related to servicing or maintenance, is the use of lockout/tagout devices for this purpose a violation of 29 CFR 1910.147(c)(5)(ii)?
Reply: Yes. As you have stated in your letter, applying lockout/tagout devices to equipment that was placed out of service for business or production reasons would not ". . .preserve the integrity of the Lockout/Tagout program." The preamble to the final rule states, at 54 Federal Register 36671 (Sept. 1, 1989): ". . . the sight of a