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.

August 30, 2002

Mr. Ronald E. Austin, CSP
Austin Safety LLC
10309 Salford Court
Glen Allen, VA 23060

Dear Mr. Austin:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs regarding the Control of hazardous energy (lockout/tagout), 29 CFR 1910.147, standard. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any scenario not delineated within your original correspondence. Your scenario, question, and our replies follow.

Scenario: I have found that customers are starting to use a label on their locks for lockout identification and labeling purposes. These labels are similar to the one in the text below:

 

 


DANGER

EQUIPMENT
LOCKED OUT
This lock belongs to:

NAME:  __________
DEPT:  __________
 


I suspect that the sales people may be incorrectly stating that the labels comply with the following 1910.147(c)(5)(ii)(B) requirements:

 

 

Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: color; shape; or size...

Question: Do labels, which are usually, white in background meet the requirement for the locks to be unique by size, shape or color?

Reply: Color is not the only prescribed factor for the standardization of lockout and tagout (LOTO) devices. At a minimum, a lock's shape, or size, or color must provide employees with the capability to identify and distinguish a lockout device from other similar devices (e.g., security locks) in the workplace.

This hardware standardization requirement requires devices to be unique to the particular use (the only ones authorized for that purpose); to be singularly identified, durable, standardized, and substantial; and to identify the user. Moreover, the lockout devices cannot be used for purposes other than the control of hazardous energy. Based on the information supplied to us, it is difficult to make a thorough evaluation; thus, we cannot determine if an employer using your described label would be in compliance with all the provisions of the standard.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 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