G/TBT/N/USA/1497  
 
21 June 2019  
(19-4246) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
  
NOTIFICATION  
The following notification is being circulated in accordance with Article 10.6  
 
1. Notifying Member:  UNITED STATES OF AME RICA  
If applicable, name of local government involved (Article 3.2 and 7.2):   
2. Agency responsible:  Occupational Safety and Health Administration (OSHA), 
Department of Labor [1524]  
Name and address (including telephone and fax numbers , email and website 
addresses, if available) of agency or authority designated to handle comments 
regarding t he notification shall be indicated if different from above:   
Please submit comments to: USA WTO TBT Enquiry Point  
Email: usatbtep@nist.gov  
3. Notified under Article 2.9.2 [   ], 2.10.1 [   ], 5.6.2 [   ], 5.7.1 [   ], other  [X]: 
4. Products covered (HS or CCCN where applicable, otherwise national tariff 
heading. ICS numbers may be provided in addition, where applicable):  Hazardous 
energy; Occupational safety. Industrial hygiene (ICS 13.100), Accident and disaster 
control (ICS 13.200), Industrial robots. Manipulators (ICS 25.040.30), Electrical 
accessories (ICS 29.120), Switchgear and controlgear (ICS 29.130)  
5. Title, nu mber of pages and language(s) of the notified document:  The Control of 
Hazardous Energy (Lockout/Tagout) (7 page(s), in English)  
6. Description of content:  The control of hazardous energy is regulated under OSHA's 
control of hazardous energy (Lockout/Tago ut) standard. The standard's purpose is to 
protect workers from the dangers of hazardous energy. This RFI seeks information 
regarding two areas where modernizing the Lockout/Tagout standard might better 
promote worker safety without additional burdens to e mployers: control circuit type 
devices and robotics. OSHA's Lockout/Tagout standard currently requires that all sources 
of energy, including energy stored in the machine itself, be controlled during servicing 
and maintenance of machines and equipment using  an energy -isolating device (EID). 
Control circuit type devices are specifically excluded from OSHA's definition of an EID and 
are thus not a compliant method of controlling hazardous energy during service and 
maintenance activities. But technological adva nces since the standard was issued in 1989 
suggest that, at least in some circumstances, control circuit type devices may be at least 
as safe as EIDs. OSHA requests information, data, and comments that would assist the 
agency in determining under what cond itions control circuit type devices could safely be 
used for the control of hazardous energy. OSHA may also consider changes to the 
Lockout/Tagout standard that address hazardous energy control for new robotics 
technologies. Employers are increasingly usin g robots and robotic components in their 
workplaces. OSHA would like to know more about what hazards and benefits this presents 
with respect to control of hazardous energy, safeguards that can be used, increased 
efficiencies that result, and any other info rmation related to ensuring employee safety in 
interfacing with robots. OSHA will use the information received in response to this RFI to G/TBT/N/USA/1497  
 
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  determine what action, if any, it may take to reduce regulatory burdens while maintaining 
worker safety.  
7. Objective  and rationale, including the nature of urgent problems where 
applicable:  Protection of human health or safety  
8. Relevant documents:   
• 84 Federal Register (FR) 22756, 20 May 2019; Title 29 Code of Federal 
Regulations (CFR) Part 1910:  
https://www.govinfo.gov/content/pkg/FR -2019-05-20/html/2019 -10247.htm  
https://www.govinfo.gov/content/pkg/FR -2019-05-20/pdf/2019 -10247.pdf  
9. Propo sed date of adoption:  To be determined  
Proposed date of entry into force:  To be determined  
10. Final date for comments:  19 August 2019  
11. Texts available from:  National enquiry point [ ] or address, telephone and fax 
numbers and email and website addresses, if available , of other body:   
https://members.wto.org/crnattachments/2019/TBT/USA/19_3556_00_e.pdf