- 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.
March 3, 1992
MEMORANDUM FOR: JOHN T. PHILLIPS
REGIONAL ADMINISTRATOR
FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE
PROGRAMS
SUBJECT: Request for Concurrence with an Interpretation of 29 CFR
1910.147(c)(5)(ii) - Lockout Devices
This is in response to your memorandum of April 19, 1991 asking if the use of a lock, which had been assigned to an authorized employee for use as a lockout device, and was also being used to lock tool boxes, was a violation of the standard. Please accept our apologies for the extreme delay in responding.
The answer is yes. It is a violation of the standard to use a lockout device for other purposes. If the lock is intended for use as a lockout device under the standard, but is also being used to lock tool boxes, then this is a violation of 1910.147(c)(5)(ii). This confirms a conversation on June 11, 1991 between Jeff Finch, formally of our staff, and Jonas Miniatas of your Office of Technical Support.
We hope this helps to clarify your concerns.