June 28, 2000

TO:      KENNETH W. GERECKE
         Assistant Regional Administrator, Region III

FROM:    RICHARD E. FAIRFAX, DIRECTOR
         Directorate of Compliance Programs

SUBJECT: GUIDANCE ON "APPROVAL" REQUIREMENTS FOR FLEXIBLE CORRUGATED
         PLASTIC COVERS AND GENERIC CIRCUIT BREAKER PANEL SWITCH LOCKOUTS

This is in response to your March 8, 2000 memorandum requesting guidance as to "approval" requirements for: (1) flexible corrugated plastic covers meant to cover live electrical parts in switchboxes, and (2) generic circuit breaker panel switch lockouts meant to be used with circuit breakers.

1. Flexible Corrugated Plastic Covers

As described in your letter, the flexible corrugated plastic covers which are used to temporarily cover live electrical parts are considered devices and/or enclosures and not equipment as stated in your letter. Therefore, the employer shall meet the requirements as outlined in 29 CFR 1910.305(b)(2), Covers and Canopies, All pull boxes, junctions boxes, and fittings shall be provided with covers approved for the purpose. The definition for Approved for the purpose can be found in 29 CFR 1910.399. Additionally, if the corrugated plastic covers can easily be dislodged when struck by an object, as stated in your letter, then the employer may also have failed to meet the requirements in 29 CFR 1910.303(g)(2)(ii).

2. Generic Circuit Breaker Panel Switch Lockouts

The generic circuit breaker panel switch lockouts are considered to be protective materials and hardware as outlined in 29 CFR 1910.147(c)(5), Protective materials and hardware. Such protective materials used for lockout/tagout consist of locks, tags, chains, wedges, key blocks, adapters pins, self-locking fasteners or other hardware provided by the employer for isolating, servicing or blocking of machines or equipment from energy sources. Equipment accessories for lockout/tagout must meet 1910.147(c)(5)(i-iii). In particular, if the generic switch lockouts can [easily] fall off, as stated in your letter, then such protective materials and/or hardware does not meet 1910.147(c)(5)(ii)(C)(1) and therefore cannot be used.