- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
November 7, 1990
Memorandum For: James W. Lake
Regional Administrator
Through: Leo Carey, Director
Office of Field Programs
From: Patricia K. Clark, Director
Directorate of Compliance Programs
Subject: Lockout/Tagout-Corrugated Metal Industry
This is in response to your memorandum of September 17, in which you requested responses to questions raised by the corrugated metal industry. The questions related to clarification of OSHA's application of the lockout/tagout standard.
In a memorandum (copy attached) from Roger Clark, Director of Safety Standards Programs, dated July 5, in response to the printing industry inquiry, reference was made to paragraph (a)(2)(ii)(B) of the lockout/tagout standard and the yet to be signed program directive that has since become OSHA Instruction STD 1-7.3, which stated, "Servicing and maintenance functions conducted during normal production operations are not regulated at 29 CFR 1910.147 if the safeguarding provisions of Subpart O or other applicable portions of 29 CFR 1910 prevent worker exposure to hazards created by the unexpected energization or start up of the machine or equipment. However, lockout/tagout procedures are required if the production safeguards are rendered ineffective while an employee is exposed to hazardous portions of the machine or equipment." This interpretation is considered current.
The following responses address specific questions asked by the corrugated metal industry in Oregon, as presented in your memorandum:
a. The corrugated industry, as a collective body, has not asked for clarification of the lockout/tagout standard.
b. OSHA is not considering a response to the corrugated metal industry, since a request for clarification has not been received from them.
c. The standard applies, depending on the circumstances, when minor servicing is performed during normal production operations as stated above, in Roger Clark's memorandum of July 5.
d. The standard, as well as the compliance directive, applies to all of general industry, including SIC 2760, Manifold Business Forms, mentioned in your memorandum.
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Attachment