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January 14, 2000

Mr. Kenneth B. Lieberman
OSHA/Regulatory Compliance/
Accident Prevention Specialist
Niagara Mohawk
300 Erie Boulevard West
Syracuse, NY 13202-4250

Dear Mr. Lieberman:

Thank you for your August 4, 1999 letter and follow-up telephone call to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You have a question regarding tagout devices and the Electric Power Generation, Transmission, and Distribution Standard, 29 CFR §1910.269. Your question and our response follow:

Question: If it is physically impossible to attach a tagout device using a nylon cable tie, does the 50 pound unlocking strength rule, per 1910.269(d)(3)(ii)(D) and 1910.269(d)(6)(iv)(B)(2), continue to apply?

Reply: Paragraph (d)(3)(ii)(D) of §1910.269 requires tag attachment means to have an unlocking strength of at least 50 pounds. This requirement is based on the strength of a standard 1/4-inch nylon cable tie which has a published unlocking strength of about 75 pounds. In some cases, this size cable tie is too large to fit through the tag attachment fitting on the energy isolating device that is capable of being locked or tagged out. OSHA will consider the use of a tagout device attachment means that does not meet the 50-pound unlocking strength requirement of §1910.269(d)(3)(ii)(D) as a de minimis violation provided that:

1. The point of attachment for the energy isolating device will not accept a 1/4-inch cable tie;
2. The tagout device attachment means is as strong as permitted by the point of attachment [for example, the largest size cable tie (up to one-quarter inch cable tie) that will fit through the point of attachment is used];
3. The tagout device attachment means is strong enough and is attached in such a manner to indicate that the operation or movement of the energy isolating devices from the "safe" or "off" position is prohibited [see §1910.269(d)(6)(iv)(B)]; and
4. The tagout device and its attachment means otherwise meet the requirements of §1910.269(d)(3)(ii)(D).

Where a tag cannot be affixed directly to the energy isolating device (as it is not capable of being locked out), the tag must be located as close as safely possible to the device, in accordance with paragraph 1910.269(d)(6)(iv)(B)(2). ⁽¹⁾ The tagout device must also be attached to an anchor point in a position that will be immediately obvious to anyone attempting to operate the energy isolating device. In this case, the attachment means for the tagout device must meet the 50-pound minimum strength requirement.

Lockable enclosure door handles; enclosure door rings; conduit; lockout system devices for single- or multiple-pole breaker switches and fuses are common anchor points that enable a person to attach a tag on or near the energy isolating device. These paragraph 1910.269(d)(3)(ii) specifications, including the 50-pound strength requirement, are imposed to ensure that tags do not become disconnected or lost during use, thereby negating their effectiveness.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may wish to consult OSHA's website at http://www.osha.gov. For example, this question and reply may be found on page B-3 of the Guidelines for Enforcement of 29 CFR §1910.269, the Electrical Power Generation, Transmission, and Distribution Standard (CPL 2-1.18A). If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs

FOOTNOTE (1) After November 1, 1994, whenever replacement or major repair, renovation, or modification of a machine or equipment is performed, and whenever new machines or equipment are installed, energy isolating devices for such machines or equipment must be designed to accept a lockout device. (Back to text)