Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1910 Subpart O; 1910.147|
|This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.|
February 10, 2005
Mr. Brad Schiegg
Electrical Engineering Manager
Optima Machinery Corporation
1330 Contract Drive
Green Bay, WI 54304
Dear Mr. Schiegg:
This is in response to your January 17, 2005 letter to the Occupational Safety and Health Administration (OSHA) requesting a formal interpretation regarding OSHA compliance for a packaging machine, which is designed in accordance with the national consensus standards for this equipment (e.g., ANSI/PMMI B155.1-2000).
Your letter seeks OSHA's acceptance of your procedures, listed below, in terms of the design/risk assessment of this machine:
- 29 CFR 1910.147: Control of hazardous energy (lockout/tagout);
- 29 CFR Part 1910: Subpart O, Machine and machine guarding;
- ANSI/ASSE Z244.1-2003: Control of Hazardous Energy Lockout/Tagout and Alternative Methods.
Should you wish to research OSHA policy regarding your referenced topics, you may elect to consult OSHA's website at http://www.osha.gov. For example, enforcement policy for the Control of Hazardous Energy Lockout/Tagout and Alternative Methods consensus standard may be found in the November 10, 2004 letter to the Chairman of the Z244 American National Standards Committee. Specifically, OSHA has not determined that, in all cases, compliance with specific provisions of the ANSI Z244.1-2003 Standard and its annexes would constitute compliance with the relevant OSHA standards.1 Please refer to our website interpretation section for additional detail on this and other hazardous energy control (e.g., §1910.147) policy.
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. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.
Richard E. Fairfax, Director
Directorate of Enforcement Programs
1 The OSH Act contemplates a distinction between the national consensus standard process and the process of OSHA rulemaking. While the former often produces information useful in the latter, it is not equivalent. Section 5(a)(2) of the OSH Act requires employers to comply with OSHA standards (29 USC §654(a)(2)). [ back to text ]
|Standard Interpretations - (Archived) Table of Contents|