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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

January 7, 1992

Mr. J. J. Barry
International President
International Brotherhood of Electrical Workers
1125 Fifteenth Street, N.W.
Washington, D.C. 20005

Dear Mr. Barry:

Thank you for your letter of August 7, in which you expressed concerns about compliance with and asked for an accurate interpretation of the Occupational Safety and Health Administration's (OSHA) Electrical Safety-Related Work Practices standards. The request relates to a document forwarded by the Philadelphia Regional Office titled: "A Sample Lockout/Tagout Program." Please accept my apology for the delay in this response.

As you are aware, the primary topic of the referenced document is the requirements of 29 CFR 1910.147, the Control of Hazardous Energy (Lockout/Tagout). The August 6, 1990 promulgation of the standard for Electrical Safety-Related Work Practices (29 CFR 1910.331 to .339) allows compliance with 29 CFR 1910.147(c) through (f) to constitute compliance with 29 CFR 1910.333(b)(2); therefore, to that extent, many of the requirements of the lockout/tagout standard are equivalent to the locking and tagging requirements of the newer standard.

The "Model Programs," prepared by our field staff, is intended to provide small employers more detailed guidance relative to the compliance with the new standards. It is also intended to improve the small employer's awareness and understanding of the potentially hazardous exposures of his/her employees when they engage in certain duties. Employers who adopt the model program as company policy, without modifying the program to fit their individual needs, would not necessarily ensure compliance with the standards. This is particularly true when applying the program to electrical workers who must comply with the requirements of the Electrical Safety-Related Work Practices standard. The program is simply a guide for the use of small employers who find it difficult to assimilate the requirements specified by the standard.

OSHA does not discourage employers or organized labor from disciplining workers for the purpose of improving workplace safety and health and ensuring adherence to work safety rules; however, the "Model Program" has been modified to exclude all such discussion and/or reference to that topic. A copy of the modified "Model Program" is enclosed.

If we may be of further assistance, please contact us.


Gerard F. Scannell
Assistant Secretary