- Standard Number:
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 https://www.osha.gov.
April 4, 1991
Mr. Steven J. Benda
Benda Products/Block-out Products, Inc.
P.O. Box 782
Cokato, Minnesota 55321
Dear Mr. Benda:
This is in response to your letter of February 11, in which you enclosed material on your new Block-Out safety product line. You requested an opinion regarding compliance with the Occupational Safety and Health Administration (OSHA) standard entitled the Control of Hazardous Energy Sources (Lockout/Tagout) (29 CFR 1910.147).
A review of the brochure and your explanation of the products was made. Based on the amount of information supplied to us, it was difficult to make a thorough evaluation, and because of that we cannot determine if an employer using your products would be in compliance with all the provisions of the standard.
It was noted that the tags in your brochure, although they contain signature lines, do not specifically indicate the individual authorized employee who is putting the devices in use. The standard requires that lockout devices and tagout devices shall indicate the identity of the authorized employee applying the device(s). An authorized employee is a person who locks or implements a tagout system procedure on machines or equipment to perform the servicing or maintenance on that machine or equipment.
In addition, the use of your products may result in exposure to live electrical parts by utilizing employees. The electrical power must be shut off to the four smaller fuse holders displayed in your brochure before your devices are installed. For this reason, we recommend you take into consideration the requirements of the Electrical Safety Related Workpractices standards 1910.331 through .399 (copy enclosed).
If your products do in fact accommodate the above requirements, then the products may be acceptable under the related OSHA standards. Due to constraints placed on OSHA we can neither endorse nor approve products in advance that are to be used in industry, since through improper installation or misuse, the products may not protect employees as intended.
Your interest in workplace safety and health is appreciated. If you should need additional assistance, please do not hesitate to contact us.
Patricia K. Clark, Director
Directorate of Compliance Programs