• 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 https://www.osha.gov.

March 10, 1975

Mr. Raymond G. Ritthamel
Director-Safety & Security
GPU Service Corporation
Post Office Box 1018
Reading, Pennsylvania 19603

Dear Mr. Ritthamel:

This is in response to your letter of February 18, 1975, with reference to work in manholes.

The rules quoted in your letter; i.e., 1926.956(a)(3)(i), (ii), and (iii), do not require the presence of emergency respiratory equipment in the immediate vicinity when work is being performed on underground lines.

However, 1926.103, which also applies to this type of work, states: "In emergencies, or when controls required by Subpart D of this Part either fail or are inadequate to prevent harmful exposure to employees, appropriate respiratory protective devices shall be provided by the employer and shall be used."

It is important to remember that, although Subpart V of the Construction Standards is specific for power transmission and distribution lines, other parts of Part 1926, the Construction Standards, may also apply. In this instance, the rules for toxic gases and vapors (not mentioned in Subpart V) and emergency respiratory equipment contained in Subpart D and E are applicable.

We trust this provides you with the information you requested.


Barry J. White
Associate Assistant Secretary for
Regional Programs