- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Control of hazardous
energy (lockout/tagout) standard.
- Information Date: 1997
June 23, 1997
Mr. Stanley G. Cothrin
Department of Safety and Hygiene
ASARCO Incorporated
3422 South 700 West
Salt Lake City, Utah 84119
Dear Mr. Cothrin:
This is in response to your May 1 letter
request for interpretation of the control of hazardous energy (lockout/tagout)
standard, 29 CFR 1910.147.
In your letter you stated: paragraph 1910.147(c)(4)
requires that a procedure be developed and documented for each particular
machine and piece of equipment when more than one hazardous energy
source is present. Further you stated: [it] is understood that if
only one hazardous energy source is present, and all exceptions
of paragraph 1910.147(c)(4) are met, then a single procedure can
be developed for all sources that meet this requirement.
This appears to be a misinterpretation
of the energy control procedure requirements of paragraph 1910.147(c)(4).
Under paragraph 1910.147(c)(4), an employer must develop and document
procedures for control of potentially hazardous energy for use by
authorized employees. This requirement applies whenever there is
one or more hazardous energy sources to which an authorized
employee could be potentially exposed when performing servicing
and maintenance of machines or equipment. In other words, the requirements
of paragraph 1910.147(c)(4) are not triggered by the distinction
between a single and multiple sources of hazardous energy.
An employer need not document the
required energy control procedure for a particular machine or equipment
when all eight elements under the exception in the note following
paragraph 1910.147(c)(4)(i) exist. Please note that the second element
requires the machine or equipment to have a single energy source
that can readily be identified and isolated.
In your letter you asked the following
question. Our reply follows.
Question:
An employer subject to the
requirements of paragraph 1910.147(c)(6) must conduct a periodic
inspection of an energy control procedure at least annually. Many
workplaces have numerous machines or equipment which require servicing
and maintenance that is subject to the requirements of 1910.147.
A review of every single procedure on an annual basis would be extremely
time consuming. What does the Occupational Safety and Health Administration
(OSHA) consider to constitute a satisfactory annual periodic inspection
of energy control procedures?
Reply:
Under the requirements of
paragraph 1910.147(c)(6)(i), the employer is required to conduct
a periodic inspection of the energy control procedure [required
under paragraph 1910.147(c)(4)]. OSHA interprets this to mean that
each energy control procedure must be separately inspected at least
annually. Also, under the requirements of paragraph 1910.147(c)(6)(i),
the periodic inspection must include a review of the employee's
responsibilities under the energy control procedure being inspected.
OSHA interprets this to mean that there must be a review between
an authorized employee designated by the employer as the "inspector"
and all other authorized employees (and all affected employees when
tagout is used to control hazardous energy), of the employees' responsibilities
under the specific energy control procedure being inspected.
See the enclosed copy of OSHA's September
19, 1995 letter to the Law Offices of Keller and Heckman (Mr. Lawrence
P. Halprin) which provides further clarification of the periodic
inspection requirements.
Please be advised that OSHA information
references including lockout and tagout and other letters, clarifying
and interpreting safety and health standards, are on the Internet
World Wide Web and are accessible via the OSHA home page at http://www.osha.gov.
OSHA information references, including the aforementioned letters
of clarification and interpretation, are also available on CD-ROM
which may be purchased from the U.S. Government Printing Office,
telephone # (202) 283-3238, using GPO Order #: 729-013-00000-5.
We appreciate your interest in employee
safety and health. If we can be of further assistance, please contact
the Office of Safety Compliance Assistance, Mr. Ronald J. Davies,
telephone # 202 219-8031, extension 110.
Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs
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