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 10, 1991

Mr. Duane Barns
DOW Chemical U.S.A.
2020 DOW Center
Midland, Michigan 48674

Dear Mr. Barns:

This is in response to your letter of January 31, to Joe Bode of my staff, concerning the use of work permits for compliance with aspects of the lockout/tagout standard requirements.

As you are aware, 29 CFR 1910.147(c)(4)(i) requires that employers document the procedure by which the hazardous energy of equipment is isolated during servicing/maintenance operations.

During the meetings on the lockout/tagout regulations, discussions were conducted concerning the use of a "generic" procedure for the various types of energy which would be encountered at a facility. The generic procedure would have to be included as a component of the company's lockout/tagout procedure and would additionally require that the company procedure clearly enunciate the further specific requirements for servicing and maintenance "work authorization permits". The company procedure would have to specify that the work permit identify the equipment to be serviced, the types and unique energy characteristics to be encountered, methods for safe work, and the process or procedures to be used to accomplish the task.

It was recognized during the earlier discussions that the comprehensive use of a work permit system would be more efficient and relevant to the tasks than would be a "cookbook" type procedure which might not fully account for a specific situation as it had occurred. It was recognized that at the time of servicing and maintenance the operations engineers and personnel are in the logical position to identify the tasks and the energy related hazards which would be encountered during maintenance operations and could best document a safe procedure for the tasks. The company procedure must, however, specify that the employees are required to perform their work in accordance with the terms and limitations of the work permit.

It should be noted that the effective use of a work permit system is compatible primarily with an industrial operation where sufficient engineering and administrative support is available. A company procedure which mandates that "generic" procedures are to be augmented with specific operational procedures as part of a required work permit system provides for compliance with the standard.

Thank you for your interest in workplace safety.


Patricia K. Clark, Director
Directorate of Compliance Programs