Whether a lock is a lockout device

OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

September 11, 2000

Mr. Carl K. Wong

Senior Product Safety Engineer

Compliance Engineering

Applied Materials, Inc.

[Recipient address omitted]

Dear Mr. Wong:

Thank you for your August 28, 2000, letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs]. You had a question concerning 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout). Your paraphrased question and our reply are provided below.

Question: Is a lock considered a lockout device?

Reply: Yes, a lock is a lockout device. The standard, at §1910.147(b), Definitions, defines a lockout device as one that, "...utilizes a positive means such as a lock, either key or combination type, to hold an energy isolating device in a safe position..."

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in this response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement at 202-693-1850].

Sincerely,

Richard E. Fairfax, Director

[Directorate of Enforcement Programs]

[Corrected 6/2/2005]