OSHA Establishes Policy and Procedures for Side-Locks
Attorneys:
Jacqueline Bollas Caldwell
On September 14, 2007, OSHA issued a compliance directive that establishes enforcement policies and inspection procedures for use of slide-locks in connection with OSHA’s lockout/tagout standard. OSHA defines a “slide-lock device” as a positive mechanical engaging device that is capable of preventing the slide from closing of its own dead weight.
OSHA had previously prohibited the use of slide-locks to replace safety blocks on mechanical power presses. However, due to improved technology, OSHA is canceling its previous interpretation letter and has issued the September 14, 2007, directive, allowing the use of slide-locks in place of safety blocks in certain prescribed situations.
Slide-locks may be used if their use provides a level of protection equal to or better than the use of safety blocks. Such use will be considered a de minimis violation of the lockout/tagout standard. However, a compliance officer may still issue a citation if the use of a slide-lock device presents a hazard. Companies should review this OSHA directive carefully to understand OSHA’s criteria for evaluating the design, construction, installation, testing, maintenance, and use of slide-lock systems. See Slide-Locks – Enforcement Policy, Inspection Procedures and Performance Guidance Criteria (CPL 02-01-043).
If you have any questions about this article, please contact Jacqueline Bollas Caldwell at: 330-244-2856 or jcaldwell@kwgd.com.
NOTE: This general summary of the law should not be used to solve individual problems since slight changes in the fact situation may require a material variance in the applicable legal advice.
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