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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 31, 1991

Mr. David J. McGuan
Safety Engineering Supervisor
Champion International Corporation
Publication Papers
P.O. Box 1200
Bucksport, Maine 04416

Dear Mr. McGuan:

This is in response to your letter of March 27, in which you requested written confirmation on 29 CFR 1910.147 (lockout/tagout), following a verbal interpretation from Mr. Rolland Stroup, of my staff. Specifically, you were concerned with the section of the standard covering periodic inspections. Please accept our apology for the delay in this response.

The section of the standard on periodic inspections requires that at least annually, the employer shall ensure that an authorized employee other than the one(s) utilizing the energy control procedure being inspected, is required to inspect and verify the effectiveness of the company energy control procedures. These inspections shall at least provide for a demonstration of the procedures and may be implemented through random audits and planned visual observations. These inspections are intended to ensure that the energy control procedures are being properly implemented and to provide an essential check on the continued utilization of the procedures.

When lockout is used, the inspection shall include a review with all authorized employees for the procedure being inspected, of their responsibilities under that procedure. Group meetings between the authorized employee who is performing the inspection and all authorized employees who implement the procedure would constitute compliance with this requirement. When tagout is used, this review must be performed with all affected employees, as defined in the standard, as well as with all authorized employees, for the procedure being inspected.

Periodic inspections must provide for and ensure effective correction of identified deficiencies. Finally, the employer is required to certify that the prescribed periodic inspections have been performed.

We hope this helps to clarify your concerns.

Your interest in workplace safety and health is appreciated.


Patricia K. Clark, Director
Directorate of Compliance Programs