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Historical enforcement of the lockout/tagout standard

Summary OSHA instructed its regional administrators to keep enforcing the lockout/tagout standard while a court challenge was pending in 1991. It said enforcement would continue unless the court changed the standard’s enforceability. OSHA labels this memo archival and warns it may no longer reflect policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-10-21
Date issued
October 21, 1991
Status
Archived by the agency
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Lockout Tagout Enforcement
Source
View the official document

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This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 21, 1991

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: CONTINUING ENFORCEMENT OF THE LOCKOUT/TAGOUT
STANDARD, 29 CFR 1910.147.

The lockout/tagout standard, 29 CFR 1910.147, continues to remain in full effect during the ongoing considerations by the U.S. Court of Appeals for the District of Columbia Circuit. This decision was issued on September 16, by the court.

As you may know, the United Auto Workers (UAW) and National Association of Manufacturers (NAM) filed case #89-1559 pertaining to this standard in the District Court. Unless the court, at some future date, modifies the enforceability of the existing standard, all enforcement personnel shall apply the stipulations of the standard and utilize OSHA Instruction STD 1-7.3, dated September 11, 1990.

Should further information concerning this very important standard be provided by the court, subsequent direction will be provided.

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