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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

March 16, 1998

Mr. Robert H. Klawitter, Jr.
Johns Manville Corporation
P.O. Box 625005
Littleton, CO 80162-5005

Dear Mr. Klawitter:

This is in response to your December 15, 1997 letter requesting clarification of paragraph 1910.147(c)(5)(ii)(D) of the Lockout/Tagout Standard. Please accept our apology for the delay in responding. Your question and our reply follow.

Question: 29 CFR 1910.147(c)(5)(ii)(D) states: "Lockout devices and tagout devices shall indicate the identity of the employee applying the device(s)." Would this mean that each lockout device must leave permanent identification affixed to it, (i.e., the authorized employee's name engraved on the lock or a metal ring, with the same information, slid over the hasp) or would this mean a tag, with the same information, attached to the lock via a method which will be capable of withstanding the environment to which it is exposed (i.e., all environment-tolerant nylon cable tie) be sufficient?

Reply: Paragraph 1910.147(c)(5)(ii)(D) is written in performance-oriented language such that the methods you described and others may be used. The intent of this requirement is addressed in the preamble of the Final Rule, 55 FR 36672. A copy of the Final Rule is enclosed for your use.

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


John B. Miles, Jr.
Directorate of Compliance Programs