Is it mandatory that color coding be applied to the lockout/tagout tags for an electric utility provider?
Here’s how we answered:
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OSHA does not mandate specific color coding for the lock out /tag out tags. 1910.269(d)(3)(ii)(B) leaves it to the electric utility to determine the color coding for lockout/tagout tags. OSHA recommends (not mandates) color coding for the tags at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9795
OSHA has stated that lockout/tagout procedures at 29 CFR 1910.269(d) are taken nearly verbatim from its lockout/tagout rule at 29 CFR 1910.147. See the OSHA website about the relationship between 1910.269 and the lockout/tagout rule at 1910.127 at https://www.osha.gov/dts/osta/lototraining/hottopics/ht-rel-5-1.html .
1910.147 does not prescribe a color code, but the following OSHA interpretation says that whatever the color code, it must provide employees with the capability to identify and distinguish a lockout device from other similar devices in the workplace. See the OSHA letter of interpretation concerning color coding for the labels on tags under 1910.147(c) at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24379
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1910.269(d)(3)(ii)(F) references 1910.145, specifically 1910.145(f), Accident prevention tags, which applies only to tags and not signs. The color coding in 1910.145(a)-(e) only applies to signs. 1910.145(f) does not specify the color requirements for tags.