March 3, 1992
MEMORANDUM FOR: JOHN T. PHILLIPS
FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE
SUBJECT: Request for Concurrence with an Interpretation of 29 CFR
1910.147(c)(5)(ii) - Lockout Devices
This is in response to your memorandum of April 19, 1991 asking if the use
of a lock, which had been assigned to an authorized employee for use as a
lockout device, and was also being used to lock tool boxes, was a violation
of the standard. Please accept our apologies for the extreme delay in
The answer is yes. It is a violation of the standard to use a lockout
device for other purposes. If the lock is intended for use as a lockout
device under the standard, but is also being used to lock tool boxes, then
this is a violation of 1910.147(c)(5)(ii). This confirms a conversation on
June 11, 1991 between Jeff Finch, formally of our staff, and Jonas Miniatas
of your Office of Technical Support.
We hope this helps to clarify your concerns.