- Standard Number:
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.
May 21, 2021
303 Avenue D
Nederland, TX 77627
Dear Mr. Sanders:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the control of hazardous energy. This letter constitutes OSHA’s interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. The scenarios and questions you provided in your inquiry are paraphrased below. OSHA’s responses follow your questions.
Scenario 1: Three authorized employees are removing and replacing a pump. First, each energy source is deenergized and locked out by an employee in plant operations. Then, the plant operations employee places the keys for each lockout device in a group lockbox in the plant control room. Next, the supervisor verifies that the equipment is in a zero energy state and places his/her personal lock on the lockbox in the control room. The three authorized employees then perform the pump replacement under the protection of the crew supervisor’s lock and do not use their personal locks.
Question: Is scenario 1 in compliance with 29 CFR § 1910.147(f)(3) if the supervisor kept a written log of the three authorized employees and ensured that all were accounted for and clear of the equipment after the work was completed prior to the removal of his/her personal lock?
Response: No. 29 CFR § 1910.147(f)(3)(ii)(D) requires each authorized employee to affix a personal lockout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work and to remove those devices when he or she stops working on the machine or the equipment being serviced or maintained.
Scenario 2: Three authorized employees are removing and replacing a pump. All potential energy sources are deenergized and locked out by an employee in plant operations. The employee in plant operations then places the key to his/her personal lock or locks in a lockbox in the control room. The crew supervisor then verifies that the equipment is in a zero energy state and attaches his personal lock to the operations lockbox, so that operations employee cannot access the key in the operations lockbox. Next, the crew supervisor places the key to his/her personal lock affixed to the operations lockbox in a satellite lockbox located at the site of the pump. Finally, each crew member verifies that the equipment is in a zero energy state and then attaches his or her own lock to the satellite lockbox before beginning maintenance activities on the pump. Once the work is finished, the crew members remove their locks from the satellite lockbox and the supervisor retrieves his/her key from the satellite lockbox. The supervisor then returns to the control room and uses the key from the satellite lockbox to unlock the operations lockbox. The employee in plant operations then takes the key out of the operations lockbox unlocks the energy sources and places the pump in operation.
Question: Is scenario 2 in compliance with 29 CFR § 1910.147(f)(3), if each individual authorized employee applied his or her own lock to the satellite box so that the crew supervisor could not retrieve his/her key in order to remove his personal lock on the operations lockbox?
Response: Yes. Scenario 2 meets the 29 CFR § 1910.147(f)(3) requirements.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA’s website at https://www.osha.gov. If you have any questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs