December 7, 2004

Mr. James Little
Safety Specialist
Georgia Gulf Lake Charles, LLC
1600 VCM Plant Road
Westlake, LA 70669

Dear Mr. Little:

This is in response to your correspondence dated July 30, 2004, to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had aspecific question regarding regulatory provisions related to the use of heavy-duty nylon cable ties as lockout devices in lieu of chains and locks. You included two photos -- one depicting the practice of locking out a valve with a chain and lock, and one depicting your proposed practice of using a cable-tie to secure the valve instead. Your paraphrased scenarios and inquiries follow.

Question: Is it appropriate to use heavy-duty nylon cable ties as an alternative to chains and locks on devices that are not specifically designed to accommodate a lock?

Response: Under most foreseeable circumstances, the use of nylon cable ties would not be an appropriate substitute for more traditional and substantial lockout devices, such as locks and chains, when an energy isolation device is capable of being locked out. 29 CFR 1910.147(c)(5)(i) states that lockout devices "shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools." While a cable tie is a positive means of holding the energy isolating device in a safe position, most commercially available cable ties are not constructed such that it would require mechanisms such as bolt cutters or other metal-cutting tools to remove them. Nylon cable ties are generally removable through the use of common cutting tools (e.g., pocket knives, side cutters, or scissors) or by releasing the pawl mechanism with a device such as screwdriver; neither of which constitutes an "unusual technique," as required by the standard. Your company could, however, use the cable ties as part of a tagout system consistent with 1910.147(c)(5), as long as the use of the tagout system in the scenario depicted in your letter will provide "full employee protection," (e.g., double-block and bleed arrangement in conjunction with a tagout device, using a nylon cable tie as a means of attachment) as set forth in 1910.147(c)(3).

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 http://www.osha.gov.

Sincerely,


Richard E. Fairfax, Director
Directorate of Enforcement Programs