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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 1, 1996

Mr. P. R. Larsen
Senior Consultant
Energy and Chemical Risk Consultants
800 Camino Del Rex
Las Cruces, New Mexico 88001

Dear Mr. Larsen:

This is in response to your letter of October 24, 1995, with regard to the various maintenance activities performed in oil and gas production operations. In your letter, you requested clarification on the applicability of the Occupational Safety and Health Administration's (OSHA's) standard, 29 CFR 1910.147 to your maintenance activities. Please accept our apologies for the delay in responding to you.

Please be advised that the lockout/tagout standard, 1910.147 is intended to protect all workers in close proximity to the maintenance task. That is, the standard provides protection to both workers conducting the maintenance activities, as well as other individuals in the work area. Further, the standard provides protection against mishaps or inadvertent acts caused by employees. Therefore, and based on our evaluation of the information that you have submitted to OSHA, we determined that 1910.147 applies to all of your maintenance activities.

With regard to the relief sought through variance determination, please be advised that the variance process is conducted in the Directorate of Technical Support. Please contact Mr. Alphonse Abadir, of the Office of Technical Support, at 200 Constitution Avenue, NW, Washington, D.C. 20210, in Room N-3653; Tel. No. 202-219-7056.

Thank you for your inquiry. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.


John B. Miles, Director
Directorate of Compliance Programs