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March 8, 1991

Mr. A. R. Grif
Chief Draftsman
Production and Machinery Corporation
P. O. Box 898
Mentor, Ohio 44060

Dear Mr. Grif:

This is in further response to your letter of December 17, 1990, concerning the obligations and responsibilities of machine manufacturers under the Occupational Safety and Health Administration's standard entitled "the Control of Hazardous Energy Sources (Lockout/Tagout)," (29 CFR 1910.147).

29 CFR 1910.147(c)(2)(iii) states, "After January 2, 1990, whenever major replacement, repair, renovation or modification of machines or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machines or equipment shall be designed to accept a lockout device." This standard requires energy isolation devices for the described machines or equipment to be designed to accept a lockout device. We believe that this standard may be enforced by OSHA against both the owner/operator and the designer/manufacturer, all of whom would therefore be subject to citations and proposed penalties. However, OSHA has not yet established a policy or procedure to enforce the standard against the designer/manufacturer.

As a builder and supplier of coil strip processing machinery, you are of course obligated to provide protection for your own employees as required in the lockout/tagout Standard. Copies of pages 36644 through 36696 of the Federal Register Volume 54, No. 169, are enclosed per your request. In addition, we are enclosing the corrections and amendments to this standard, publishing on September 20, 1990.

Your interest in workplace safety and health is appreciated.

Sincerely,



Gerard F. Scannell
Assistant Secretary