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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 19, 1992

Mr. Jay Whitaker
Product Manager
Panduit Corporation
Box 246,
1819 Atlanta Highway
Cummings, Georgia 30130

Dear Mr. Whitaker:

This is in further response to your July 23 letter, in which you requested that the Occupational Safety and Health Administration (OSHA) review Panduit's lockout/tagout training video entitled "A Life Is On the Line" and advise on whether or not the video conforms with the OSHA standard at 29 CFR 1910.147. Please accept our apologies for the delay in responding.

An employer must comply with the control of hazardous energy (lockout/tagout) standard at 1910.147 to provide for the safety and health of employees performing servicing and maintenance of machines and equipment in the workplace. As delineated in 1910.147(a)(1)(ii), the 1910 Subpart S - Electrical standards cover employee exposure to electrical hazards for work on, near, or with conductors or equipment in electrical utilization installations in general industry. Standards for the lockout/tagout of electrical conductors and parts of electrical equipment are contained in 1910.333 of the Safety-Related Work Practices sections, 1910.331-335, of Subpart S.

An employer is required to establish a program which includes training and procedures on lockout/tagout of machines and equipment on which employees perform servicing and maintenance. Through analysis and evaluation, an employer identifies hazardous energy sources for the specific workplace applications and develops a program to protect employees by complying with the appropriate lockout/tagout standard.

Advising you on whether or not the Panduit training video conforms to the 1910.147 lockout/tagout standard outside the context of specific workplace applications could be misleading. We are therefore returning the video (enclosed) without further comment. Please note that OSHA does not officially endorse, approve or certify any product or materials, including training videos.

Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.


Roger A. Clark,
Directorate of Compliance Programs