OSHA: Response to Query Regarding Use of LOTO Device Placed in “Out of Service” Status

Date First Published on SafetySmart Compliance: September 26th, 2011
Topics: Lockout Tagout | Machine Guarding |

Retrieved from: Occupational Safety & Health Administration


Scenario: Under 29 CFR 1910.147(c)(5)(ii), lockout/tagout devices “. . . shall not be used for other purposes; . . .” Additionally, 29 CFR 1910.147(a)(1)(i) states: “This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy could cause injury to employees.

Question: When equipment is placed in an “out of service” status for business or production purposes (e.g., poor efficiency, recycled, sold, etc.) and not related to servicing or maintenance, is the use of lockout/tagout devices for this purpose a violation of 29 CFR 1910.147(c)(5)(ii)? 

Reply: Yes. As you have stated in your letter, applying lockout/tagout devices to equipment that was placed out of service for business or production reasons would not “. . .preserve the integrity of the Lockout/Tagout program.” The preamble to the final rule states, at 54Federal Register 36671 (Sept. 1, 1989): “. . . the sight of a distinctive lock or tag will provide a constant message of the use that the device is being put to and the restrictions which this device is intended to convey. If lockout or tagout devices are used for other purposes they can lose their significance in the workplace. For the energy control procedure to be effective, these devices must have a single meaning to employees: ‘Do not energize the equipment when such a device is affixed to it.'”