- Record Type: Interpretation
- Standard Number: 1910.147
- Subject: Clarification of
29 CFR 1910.147 - Control of Hazardous Energy Standard.
- Information Date:1994
August 5, 1994
Mr. M. L. Hall
Safety/Emergency Response
Program Manager
IBM Mail Drop 3600
Somers, N.Y. 10589
Dear Mr. Hall:
This is in response to your telefaxed
memorandum of July 6 to Mr. Ronald J. Davies of my staff requesting
clarification of 29 CFR 1910.147 - Control of Hazardous Energy
Standard. Specifically, you requested confirmation that the
individual performing a periodic inspection required by 1910.147(c)(6)
must be an authorized employee.
Pursuant to 1910.147(c)(6)(i)(A),
a periodic inspection must be performed by an authorized employee
other than the one(s) utilizing the energy control procedure
being inspected. For the purpose of complying with the intent
of this standard, authorized employee means a qualified person
whom the authority and responsibility to perform a specific
lockout or tagout inspection has been given by the employer.
A qualified person is a person who has been trained and has
demonstrated proficiency, in compliance with 1910.1247(c)(7),
to perform servicing and maintenance on the machine or equipment
to be inspected. In your memorandum you described three periodic
inspection scenarios. The individuals in these scenarios must
be authorized employees, as noted above.
Periodic inspection by an authorized
employee is intended to assure that the energy control procedure
continues to be implemented properly and that the employees
involved are familiar with their responsibilities under that
procedure. The inspection must be able to determine three
things: first, whether the steps in the energy control procedure
are being followed; second, whether the employees involved
know their responsibilities under the procedure; and third,
whether the procedure is adequate to provide the necessary
protection, and what changes, if any, are needed. The Final
Rule, a copy of which is enclosed for your use, provides some
additional guidance as to the inspector's duties in performing
a periodic inspection, to assure that necessary information
about the energy control procedure and its effectiveness is
obtained. The preamble discussions of the definition of an
authorized employee, page 36665, and on the periodic inspections,
page 36673, were referenced for the preceding clarifications.
We appreciate your interest in employee
safety and health. If we can be of further assistance, please
contact Mr. Davies of my staff, at (202) 219-8031, extension
110.
Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs
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