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Verifying group lockout without a representative from every crew

Summary A requester asked whether each work group must send someone to verify group lockout. OSHA said the rule did not require that if a primary authorized employee coordinated and verified isolation before workers attached personal devices and began servicing. OSHA now labels the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
2000-10-24
Date issued
October 24, 2000
Status
Archived by the agency
OSHA labels this letter an archive document that may no longer represent OSHA policy.
Status last verified October 9, 2026

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OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."

October 24, 2000

Ms. Vernette Francis

[Recipient address omitted]

Dear Ms. Francis:

Thank you for your June 28, 2000 letter to the Occupational Safety and Health Administrations's (OSHA's) [Directorate of Enforcement Programs (DEP)]. You had a specific question regarding group lockout procedures.

Question: "...must a member of other work groups (maintenance, servicing and contractors) be present to verify the effectiveness of the lockout while the primary authorized employee is performing the steps necessary for energy isolation and control?"

Reply: 29 CFR 1910.147(f)(3), Group lockout or tagout, does not require that a member from each work group be present to verify the effectiveness of the lockout/tagout (LO/TO) procedures if the employer has designated a primary authorized employee, with the primary responsibility for a set number of employees working under the group LO/TO device(s). The primary authorized employee must implement and coordinate the LO/TO of hazardous energy sources and verify that the steps taken, in accordance with the specific energy control procedure, have in fact isolated the machine or equipment effectively from the hazardous energy sources. This should be accomplished before the authorized employees participating in the group LO/TO, affix their personal lockout or tagout device to the group LO/TO box and before they perform servicing/maintenance activities.

If the employer elects to assign a primary authorized employee to verify effective energy isolation, each authorized employee participating in the group LO/TO must be informed of their right to verify the effectiveness of the lockout measures and each authorized employee must be allowed to personally verify that hazardous energy sources have been effectively isolated, if they so choose. An authorized employee, who opts to verify the effectiveness of the isolation measures, must perform this verification after affixing his or her personal lockout or tagout device and before performing servicing/maintenance activities.

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 rule making; 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]

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