On Nov. 29, 2023, the ANSI/ASSP Z244 Committee requested that OSHA's Directorate of Enforcement issue a letter of interpretation (LOI) on 29 CFR 1910.147, related to types of energy.

Specifically, the committee is asking OSHA to update its 1995 LOI related to the federal standard due to "significant regulatory compliance implications for employers and their employees."

 In the 1995 LOI, OSHA indicated that its lockout/tagout requirements "address electro-mechanical hazards, but stated that lockout/tagout will not eliminate hazards associated with flowable materials such as steam, natural gas and other substances that can cause hazardous atmospheres or engulfment hazards in confined spaces."

However, the committee is concerned about the distinction this language makes regarding the state or type of energy to be controlled. The group notes that energy-isolating devices, including items such as valves, blanks, blinds, plugs and gates, have long been used to isolate flowable materials. 

"The 'state' of the energy (solid, liquid, gas) or its 'type' are not relevant as to the application in the the standards or to confined spaces," the committee says, specifically citing clearer language from national voluntary consensus standard ANSI/ASSP Z117.1-2022, Safety Requirements for Entering Confined Spaces. The group believes OSHA's 1995 interpretation is "conflicted, contradictory and counterproductive," and asks OSHA to administratively change the interpretation or take other appropriate regulatory action to address the issue.

Read the letter