Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 15, 1990

Mr. J.H. Balch
Safety Manager
Sylvania Lighting Services Corporation
100 Endicott Street
Danvers, Massachusetts 01923

Dear Mr. Balch:

This is response to your November 30, 1989 letter to Mr. Ed Bajakian of Occupational Safety and Health Administration's (OSHA) Regional Office in Boston, Massachusetts. We apologize for the delay in our response.

You requested our opinion of your interpretation that your company should not be covered under 29 CFR 1910.147, Control of Hazardous Energy Sources, (Lockout/Tagout). The basis for your interpretation is that the activities engaged in by employees of Sylvania Lighting Services are excluded from coverage by this standard because they are covered by Subpart "S", the OSHA Electrical Subpart.

The Lockout/Tagout Standard became effective on January 2, 1990 and does not pertain to electrical hazards from work on, near or with conductors or equipment in electrical utilization installations. These are covered by 29 CFR Subpart S.

Your attention is, however, directed to the new final rule entitled Electrical Safety Related-Work Practices, which was published on August 6, (copy enclosed). This new rule requires specific safety-related procedures, including lockout/tagout of electrical equipment, and becomes effective on December 4, with the training portion having a delayed effective date of August 6, 1991.

I believe that this addresses your inquiry. If you have any further questions on this subject, please do not hesitate to contact me.

Thank you for your interest in occupational safety and health.


Patricia K. Clark
Director Designate
Directorate of Compliance Programs