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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 11, 2000

Mr. Carl K. Wong
Senior Product Safety Engineer
Compliance Engineering
Applied Materials, Inc.
P. O. Box 58039
Santa Clara, CA 95052

Dear Mr. Wong:

Thank you for your August 28, 2000, letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs]. You had a question concerning 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout). Your paraphrased question and our reply are provided below.

Question: Is a lock considered a lockout device?

Reply: Yes, a lock is a lockout device. The standard, at §1910.147(b), Definitions, defines a lockout device as one that, "...utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in a safe position..."

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement at 202-693-1850].

Sincerely,


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]