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 https://www.osha.gov.

February 19, 1997

Mr. Ladd G. Poor
Power Supply Safety Administrator
1407 West North Temple
Salt Lake City, Utah 84140

Dear Mr. Poor:

This is response to your June 4, 1996, letter requesting interpretation of the electric power generation standard, 29 CFR 1910.269. Specifically, you requested clarification on the requirements of paragraph 1910.269(d) Hazardous energy control (lockout/tagout) procedures as they apply to your electric power generating facilities. Please accept our apology for the delay in responding. Your electric power generating scenario and question and our replies follow.

Scenario: PACIFICORP uses a group lockout, system operator concept at their main plant as required under paragraph 1910.269(d). Several miles away from the main plant, PACIFICORP has some remote locations and unmanned hydro facilities where employees are required to perform servicing and maintenance of machines or equipment.

Question 1: Is an employer prohibited under 1910.269 from

establishing an energy control program which uses an individual tagout procedure at a remote location (that is, the worker would tagout the piece of equipment to perform servicing and maintenance and when finished, remove the tag and place the equipment back in service) that also complies with 1910.269(d)?

Reply: Servicing and maintenance of machines and equipment may be performed by the individual tagout procedure as delineated in your question with the following exception. Paragraph 1910.269(d)(8)(v) applies when the system operator is involved with energy isolation at a remote location.

Question 2: If there is no prohibition to an employer

establishing the energy control program described in question 1 above, does the employee at the remote location have to use a lock as well as a tag or can a tagout be used if the employer can demonstrate that the tagout program provides a level of safety equivalent to that obtained by the use of a lockout program?

Reply: An employer may establish either a paragraph 1910.269(d) lockout program or tagout program for servicing and maintenance of machines or equipment at the remote location referenced in the scenario above.

Question 3: If you are working under the group tagout

procedure, can the individual who hangs the `tag then perform work under his own tag?

Reply: The employee in your question is identified in paragraph 1910.269(d)(8)(ii)(A) as the authorized employee who exercises overall responsibility for adherence to the employer's lockout/tagout procedure. This authorized employee may perform work under his or her own tag, but only to the extent that it does not interfere in exercising this overall responsibility.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202)219-8031, extension 110.


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