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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 29, 1991

Mr. William E. Funcheon, Jr. & Associates
RR 2 Box 419F
Monticello, Indiana 47960

Dear Mr. Funcheon:

This is in further response to your undated letter that we received on May 24, in which you asked if the Occupational Safety and Health Administration (OSHA) requires point of operation guards and/or lockouts to be in place during the cleanup and sanitizing of machinery and equipment in the meat packing industry.

The answer to your first question is yes; OSHA requires that effective safeguards be in place for the protection of the employees engaged in both the operation, as well as cleanup and sanitizing, of machinery and equipment in the meat packing industry. Section 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout) standard, covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could cause injury to employees. Normal production operations are not covered by this standard unless during the servicing and/or maintenance, which takes place during normal production operations, the employee performing the servicing may be subjected to hazards that are not encountered as part of the production operation itself. This situation would occur if the employee must either remove or bypass machine guards or other safety devices, resulting in exposure to hazards at the point of operation, if the employee is required to place any part of his or her body in contact with the point of operation of the operational machine or piece of equipment, or finally, if the employee is required to place any part of his or her body into a danger zone associated with a machine operating cycle. If any of the above mentioned situations exist, then the provisions of the lockout/tagout standard would apply.

A note to paragraph (a)(2)(ii)(B) of the standard does provide a limited exception for minor servicing activities which take place during normal production operations, but only if these activities are routine, repetitive, and integral to the use of the equipment for production, and provided that the work is performed using alternative measures which provide effective protection.

In response to your second question, the participation or degree of support given by Mr. Barry White in the development of the lockout/tagout standard was a part of the deliberative process that takes place during the formulation of all standards. We have no record of and are unable to characterize at this time the extent or nature of his support for the standard.

If you should need additional assistance, please contact us again.


Patricia K. Clark, Director
Directorate of Compliance Programs