- 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.
July 26, 1994
[Name Withheld]
Dear [Name Withheld]:
This is in response to your May 13 letter, requesting clarification of the Control of Hazardous Energy (Lockout/Tagout) standard, 29 CFR 1910.147. Please accept our apology for the delay. Specifically you requested clarification on the possible use of a cotton-rayon cord of more than 60 pounds (13.49 Newtons) breaking strength or a nylon cord of more than 100 pounds (22.48 Newtons) breaking strength for attachment of tagout devices to energy isolating devices for the purpose of complying with the tagout requirement at 1910.147(c)(5)(ii)(C)(1).
By 1910.147(c)(5)(ii)(C)(1), the employer is required to provide a means of tagout device attachment having the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie. The Lockout/tagout standard uses performance language in imposing the above requirement. As such, an employer must be prepared to demonstrate equivalency to the OSHA Compliance Safety and Health Officer on inspection of his or her worksite.
In your letter you provided a sample tag with samples of the cords described above. The cords, alone, would not meet the following means of attachment requirements in 1910.147(c)(5)(ii)(C)(1). Tagout device attachment means shall be of a non-reversible type, self-locking and non-releasable with a minimum unlocking strength of no less than 50 pounds (11.14 Newtons). Neither the cords nor the tag appear to be all environment-tolerant, that is, if wet, neither would hold up.
Thank you for your interest in occupational safety and health. If we may be of further assistance, please let us know.
Sincerely,
John B. Miles, Jr.
Director
Directorate of Compliance Programs