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.

September 21, 1978

Mr. G. A. Mudrick
Assistant Safety Director
Pennsylvania Powe
and Light Company
Two North Ninth Street
Allentown, Pennsylvania 18101

Dear Mr. Mudrick:

This is in response to your letter requesting an interpretation of 29 CFR 1926.955(c)(10) in its entirety and as it relates to 29 CFR 1926.954(b)(2) and 29 CFR 1926.955(c)(3). The OSHA Philadelphia Regional Office forwarded your letter to this office for reply. Please accept my apology for the delay in response.

29 CFR 1926.955(c)(10) does require transmission clipping and tying crews to work between grounds at all times when working on bare conductors. However, other overhead line work may be performed on ungrounded conductors provided the hazard of induced voltages is not present, and adequate clearances or other means are implemented to prevent contact with energized lines or equipment and the new lines or equipment as indicated in 29 CFR 1926.954(b)(2).

In work situations where the hazard of induced voltages is present, and adequate clearances or other means are not implemented to prevent contact with energized lines or equipment and the new lines or equipment, the lines or equipment shall be grounded or provisions made to insulate or isolate the employee as indicated in 29 CFR 1926.955(c)(3). The 29 CFR 1926.955(c)(10) is a specific requirement and the other two standards are general requirements.

If I may be of any further assistance, please feel free to contact me.

Sincerely,



John K. Barto, Chief
Division of Occupational
Safety Programming