Color is not the only prescribed factor for the standardization of LOTO devices.

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.

August 30, 2002

Mr. Ronald E. Austin, CSP
Austin Safety LLC
10309 Salford Court
Glen Allen, VA 23060

Dear Mr. Austin:

OSHA does not test, approve, certify, or endorse any equipment, product, or procedure, including machine design and risk assessment techniques.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

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).

LOTO: Use of heavy-duty nylon cable ties as lockout devices in lieu of chains and locks.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

December 7, 2004

Mr. James Little
Safety Specialist
Georgia Gulf Lake Charles, LLC
1600 VCM Plant Road
Westlake, LA 70669

Dear Mr. Little:

LOTO: minor servicing exemption and the use of a lockable on/off switch as an alternate measure to provide effective protection.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

October 20, 2004

Mr. Mark Kaster
Dorsey and Whitney LLP
50 South Sixth Street, Suite 1500
Minneapolis, Minnesota 55402

Dear Mr. Kaster:

The obligations and responsibilities of machine manufacturers under the lockout/tagout standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

March 8, 1991

Mr. A. R. Grif
Chief Draftsman
Production and Machinery Corporation
P. O. Box 898
Mentor, Ohio 44060

Dear Mr. Grif:

This is in further response to your letter of December 17, 1990, concerning the obligations and responsibilities of machine manufacturers under the Occupational Safety and Health Administration's standard entitled "the Control of Hazardous Energy Sources (Lockout/Tagout)," (29 CFR 1910.147).

Applicability of the confined-space standard to dock-leveler pits.

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.

December 2, 2002

Mr. Art Varga
Materials Handling Equipment Company
1740 West 13th Avenue
Denver, Colorado 80204

Dear Mr. Varga:

Controlling Confined Space Hazards in Deep Tanks for Parts Cleaning

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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 8, 2012

Mr. John Elskamp
Superior Powder Coating, Inc.
600 Progress Street
Elizabeth, New Jersey 07201

Dear Mr. Elskamp:

Electronic Certification of Training

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.

September 22, 2014

William K. Principe
Constangy, Brooks & Smith, LLP
Suite 2400
230 Peachtree Street, NW
Atlanta, Georgia 20201-1557

Dear Mr. Principe:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) for a clarification of OSHA's training standards. This constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Your questions are paraphrased below and our responses follow.

Review of Panduit's lockout/tagout training video.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

November 19, 1992

Mr. Jay Whitaker
Product Manager
Panduit Corporation
Box 246,
1819 Atlanta Highway
Cummings, Georgia 30130

Dear Mr. Whitaker:

This is in further response to your July 23 letter, in which you requested that the Occupational Safety and Health Administration (OSHA) review Panduit's lockout/tagout training video entitled "A Life Is On the Line" and advise on whether or not the video conforms with the OSHA standard at 29 CFR 1910.147. Please accept our apologies for the delay in responding.

Response to Exelon Generation's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard."

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.

June 13, 2003

Mr. Robert J. Fisher
Vice-President, Operations Support
Exelon Generation
4300 Winfield Road
Warrenville, IL 60555

Dear Mr. Fisher:

Thank you for your March 17, 2003 letter commenting on the Occupational Safety and Health Administration's (OSHA's) Draft OSHA Instruction CPL 2-1.18A, Enforcement of the Electric Power Generation, Transmission and Distribution Standard.