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Lockout / Tagout - Ohio Bureau of Workers' Compensation

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OSHA Standards Interpretation and Compliance Letters<br />

08/30/1991 - <strong>Lockout</strong>/<strong>Tagout</strong> for circuit breaker blocking and<br />

locking devices.<br />

• Record Type: Interpretation<br />

• Standard Number: 1910.147<br />

• Subject: <strong>Lockout</strong>/<strong>Tagout</strong> for circuit breaker blocking and locking devices.<br />

• Information Date:08/30/1991<br />

August 30, 1991<br />

Mr. Steven J. Benda<br />

President<br />

Block-Out Products, Inc.<br />

P.O. Box 782<br />

Cokato, Minnesota 55321<br />

Dear Mr. Benda:<br />

This is in response to your letter <strong>of</strong> July 1, in which you request an opinion regarding<br />

compliance with 29 CFR 1910.147 (<strong>Lockout</strong>/<strong>Tagout</strong>) for your circuit breaker blocking<br />

and locking devices. You enclosed literature on both your single pole model and multipole<br />

device, as well as your explanation <strong>of</strong> the products. We apologize for the delay in<br />

responding.<br />

A review <strong>of</strong> the literature and your explanation <strong>of</strong> the products revealed the following<br />

concern. It was noticed on the multi-pole device that a standard electrical tie wrap is<br />

being used as part <strong>of</strong> a lockout device. This does not meet the intent <strong>of</strong> 1910.147(c)(1)<br />

which states, "<strong>Lockout</strong> devices shall be substantial enough to prevent removal without<br />

the use <strong>of</strong> excessive force or unusual techniques, such as with the use <strong>of</strong> bolt cutters or<br />

other metal cutting tools." We do not feel that a standard electrical tie wrap meets this<br />

criteria.<br />

Due to constraints placed on OSHA we can neither endorse nor approve products in<br />

advance that are to be used in industry, since through improper installation or misuse,<br />

the products may not protect employees as intended.<br />

Your interest in workplace safety and health is appreciated.<br />

Sincerely,<br />

Patricia K. Clark, Director<br />

Directorate <strong>of</strong> Compliance Programs<br />

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