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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 5, 1994

Mr. M. L. Hall
Safety/Emergency Response
Program Manager
IBM Mail Drop 3600
Somers, N.Y. 10589

Dear Mr. Hall:

This is in response to your telefaxed memorandum of July 6 to Mr. Ronald J. Davies of my staff requesting clarification of 29 CFR 1910.147 - Control of Hazardous Energy Standard. Specifically, you requested confirmation that the individual performing a periodic inspection required by 1910.147(c)(6) must be an authorized employee.

Pursuant to 1910.147(c)(6)(i)(A), a periodic inspection must be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected. For the purpose of complying with the intent of this standard, authorized employee means a qualified person whom the authority and responsibility to perform a specific lockout or tagout inspection has been given by the employer. A qualified person is a person who has been trained and has demonstrated proficiency, in compliance with 1910.147(c)(7), to perform servicing and maintenance on the machine or equipment to be inspected. In your memorandum you described three periodic inspection scenarios. The individuals in these scenarios must be authorized employees, as noted above.

Periodic inspection by an authorized employee is intended to assure that the energy control procedure continues to be implemented properly and that the employees involved are familiar with their responsibilities under that procedure. The inspection must be able to determine three things: first, whether the steps in the energy control procedure are being followed; second, whether the employees involved know their responsibilities under the procedure; and third, whether the procedure is adequate to provide the necessary protection, and what changes, if any, are needed. The Final Rule, a copy of which is enclosed for your use, provides some additional guidance as to the inspector's duties in performing a periodic inspection, to assure that necessary information about the energy control procedure and its effectiveness is obtained. The preamble discussions of the definition of an authorized employee, page 36665, and on the periodic inspections, page 36673, were referenced for the preceding clarifications.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact [the Office of General Industry Compliance Assistance at (202) 693-1850].


John B. Miles, Jr., Director
Directorate of Compliance Programs