When Lockout Isn't an Option: OSHA Clarifies “Alternative Methods” in 2024 Interpretation
October 21, 2024 – OSHA Interpretation 2024-10-21
The U.S. Occupational Safety and Health Administration (OSHA) has issued a significant letter of interpretation (LOI) dated October 21, 2024, clarifying how employers must handle service and maintenance tasks that require machine power — and how far they can rely on so-called “alternative methods” under the Lockout/Tagout (LOTO) standard, 29 CFR §1910.147.
The Scenario
A safety professional, writing on behalf of a client, posed a common real-world challenge: What if a setup or changeover task isn’t “normal production” (and therefore falls under LOTO), but still requires machine power to jog or inch components into place? Many such tasks fall outside the “minor servicing exception” and thus trigger full LOTO requirements — yet isolating all energy sources would make the task impossible.
OSHA’s Answer
OSHA reaffirmed that full LOTO is required during servicing and maintenance, unless the specific exception in §1910.147(f)(1) is met. That provision allows for temporary removal of lockout devices and re-energization only for testing or positioning — and only under strict procedural controls:
Clear tools and materials (§1910.147(e)(1))
Remove employees from danger zones (§1910.147(e)(2))
Remove LOTO devices (§1910.147(e)(3))
Re-energize with protective measures in place
De-energize again and reapply LOTO once testing is done
Importantly, this is not a green light for using powered methods as part of regular setup or maintenance without full LOTO. The powered phase must be temporary, tightly controlled, and well-documented.
Rejection of ANSI’s “Alternative Methods” and “Feasibility” Definitions
OSHA also declined to formally recognize the more flexible definitions found in ANSI B11.0-2020 and ANSI Z244.1-2016, which introduce the concept of “alternative methods” — energy control strategies other than full isolation, provided they reduce risk to an acceptable level.
Although ANSI’s definitions are helpful for designing practical risk-based systems, OSHA emphasized that compliance with ANSI is not the same as compliance with OSHA, unless explicitly adopted into the OSHA standards. In other words, national consensus guidance can inform — but not replace — regulatory obligations.
Similarly, OSHA does not accept ANSI’s broader definition of “feasibility” (as "practicability of implementing risk reduction") and instead holds to its own technical and economic feasibility criteria as laid out in the 2020 Field Operations Manual.
Implications for Safety Professionals
This interpretation draws a clear line in the sand:
Testing and repositioning are valid reasons to momentarily restore power — but not for general setup or maintenance.
There is no regulatory substitute for energy isolation — alternative methods may reduce risk but do not equal compliance.
Safety practitioners relying on ANSI standards must also meet OSHA’s stricter requirements.
Procedures must document the transition into and out of energized states, and must prioritize the removal of employees from danger zones.
Key Takeaway
The October 21, 2024 OSHA interpretation makes it clear: while engineering controls and innovative technology can enhance protection, they do not replace the legal duty to isolate hazardous energy unless strictly within the bounds of §1910.147(f)(1). “Alternative methods” may be valuable, but they are not legally binding substitutes for lockout/tagout.
Link to the interpretation letter: https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21
