Lockout / Tagout - Ohio Bureau of Workers' Compensation

contradict the guidance provided in OSHA's Instruction STD 1-7.3 which clearly states
that group meetings with all authorized employees constitutes compliance with the
standard. If the standard and the instructional guidance are to be consistent, then group
meetings between an inspector and all authorized employees comply with
1910.147(c)(6)(i), provided the inspection includes a review of the responsibilities of
each authorized employee and a demonstration of the energy control procedures.
Question: Does 1910.147(c)(6)(i) require that all authorized employee demonstrate
energy control procedures during the periodic inspection?
As stated above, the lockout/tagout standard requires that the periodic inspection
include a "review" of the employee's responsibilities under the energy control
procedures. Generally, an inspector who observes deficiencies in authorized employees
understanding of the lockout/tagout program during the period inspection will counsel
the employees on the correct energy control procedures. If several employees are
performing maintenance on a particular machine, the inspector may request that one
employee demonstrate the energy control procedures utilized on that machine, while
the other employees observe. The inspector will then review the responsibilities of each
authorized employee under the energy control procedure being inspected. Likewise, the
inspector may assemble several authorized employees and request that one employee
demonstrate the lockout procedures while the others observe. In each case, all
employees are participating in a lockout demonstration and receive feedback on the
correct procedures.
In the OSHA Memorandum, dated March 6, 1995, Mr. Wiehrdt indicates that such a
group meeting of employees will not comply with 1910.147(c)(6)(i), since each
authorized employee in the group does not individually demonstrate the energy control
procedures for the inspector. Our readings of the regulation and the interpretive
guidance provided by the National office indicates that OSHA does not require that
every employee demonstrate lockout/tagout procedures during the periodic inspection.
Based on our questions, we request that your office provide additional interpretation of
the periodic inspection requirements contained in the Lockout/Tagout Standard.
Attached to this letter is the Memorandum dated March 6, 1995 from William Wiehrdt to
Mel Lischefski. If you have any questions regarding our request, please feel free to call.
Your cooperation is appreciated.
Very truly yours,
KRUKOWSKI & COSTELLO, S.C.
Stuart Charlson
7-13