- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
January 9, 1975
Mr. Avery T. Neseth
Utility Operations Department
International Brotherhood of
1125 - 15th Street, N.W.
Washington, D.C. 20005
Dear Mr. Neseth:
This is in reply to your letter of June 25, 1974, requesting an interpretation of 29 CFR 1926.556. An interim reply was sent to you in August. Please excuse our delay in giving you a final answer to your letter.
Your letter quoted three sections of the standards (1926.556(b)(2)(iii), (v) and (x)) all of which refer to "when working" or "while working." There is another standard to be considered and that is 1926.556(b)(2)(iv) which states: "Employees shall always stand firmly on the floor of the basket and shall not sit of climb on the edge of the basket or use planks, ladders or other devices for a work position."
The term "working," as used in the paragraphs in question, refers to the performance of specified task aboveground and does not include the transportation of an employee to the location where the task is to be performed. Accordingly, the requirements of these paragraphs apply while an employee is working from an aerial lift and do not apply where the aerial lift is being used to transport the employee to work location.
In answer to your specific questions, 1926.556 does not prohibit employees from climbing from the basket to a pole. The employee should fasten his safety belt to the pole, if conditions permit, before leaving the basket to transfer to the pole position. The climbers may be worn in the basket if employee is being elevated for transfer to the pole.
If I can be of further assistance, please contact me.
Barry J. White
Associate Assistant Secretary for