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Lockout and ignition-key control during truck maintenance

Summary A laboratory asked whether a worker may adjust a truck from underneath while its engine is running. OSHA said that would present a hazard and violate the lockout and tagout rule. It said shutting off the engine and keeping the ignition key under the servicing worker's sole control could isolate the power source, alongside the rule's other procedures and training duties.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-05-20
Date issued
May 20, 1991
Status
Archived by the agency
OSHA labels this an archive document that may no longer represent policy.
Status last verified October 9, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 20, 1991

Mr. Raymond W. Halsey
Colin Laboratories, Inc.
[Recipient address omitted]
Dear Mr. Halsey:

This is in further response to your letter of March 16, which concerned a telephone conversation you had with Mr. Richard Sauger of our Office of Safety Standards Programs. Your concerns were whether or not the Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.147 (lockout/tagout) would apply to motor vehicles.

Specifically, you posed the following question: If a truck driver or other person were to crawl under a truck, with the engine running, to adjust a linkage or fix another problem, would this be considered a violation of the standard? The answers is yes, this would constitute a hazard, as well as a violation. We would agree with the verbal opinion offered by Mr. Sauger that turning the engine off and removing the ignition key would deenergize and isolate the power source. The key would also have to be retained by the employee performing the maintenance operation in order to provide effective protection under the standard.

When servicing or maintenance activities are to take place, on any equipment, deenergization of that equipment will provide maximum safety to an employee. The removal of a vehicle key which can be kept in the sole control of the employee performing the maintenance or service can significantly reduce the risk of serious injury or even possibly a fatal injury.

We are enclosing a copy of the lockout/tagout standard for your use. We would point out the need to put into effect the other requirements of the standard, such a setting up an energy control procedure and employee training.

We hope this helps to clarify your concerns.

Your interest in workplace safety and health is appreciated.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

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