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.

April 10, 1975

Mr. Dave Kuebaugh
President, Local 1891
International Brotherhood of
Electrical Workers AFL-CIO, CLC
P.O. Box 229
Gloverville, New York 12078

Dear Mr. Kuebaugh:

This is in response to your letter requesting clarification of manhole entry procedures in the OSHA standard 1926.956(b)(1) on Power Transmission and Distribution.

It appears that OSHA 1926.956(b)(1) has two parts. In the first instance it states that an employee shall be available in the immediate vicinity of a manhole but that such employee may have other duties than merely acting as safety man. The same paragraph also specifies that an employee may enter a manhole alone for the purpose of inspection, housekeeping, taking readings or similar work for brief periods of time. There is no qualification for the phrase "brief periods of time", and there is no inclusion or exclusion of work procedures when a man works alone in a manhole. Therefore, interpretation of this paragraph would demand on a Compliance Officer on the job to determine if there is a hazard to an employee working alone in a manhole.

There was an enclosure with your letter entitled "Proposed Safety and Health Standards for Telecommunications". We are pleased to enclosed with this letter a copy of Part III, Vol. 40, No. 59 which reproduces an approved version of the Telecommunications standards. We would call particular attention to page 13221, 1910.268(a)(2) which emphatically excludes "installations under the exclusive control of electric utilities". Also, on page 13447, 1910.268(o)(3) repeats the same qualification we noted in our second paragraph.

Although the ultimate in safety procedures would be to protect every man each time he enters a manhole by providing a safety man, the OSHA standards were written to provide a judgmental factor to take care of varying conditions.

Please feel free to contact us if there are further questions about OSHA.

Very truly yours,

John J. Kearney
Associate Assistant Regional
Director for Technical Support/OSH