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.

November 15, 1982

Mr. Robert Felix
Executive Vice President
National Arborist Association Inc.
3537 Stratford Road
Wantagh, New York 11793

Dear Mr. Felix:

Thank you for your letter of October 15, 1982, concerning the ANSI Z133.1 standard and requesting our documentation and notification to the proper individuals to avoid any unnecessary conflicts.

The Occupational Safety and Health Administration (OSHA) has not adopted the ANSI Z133.1, Safety Requirements for Pruning, Trimming, Repairing, Maintaining, and Removing Trees, and for Cutting Brush. Therefore, our Safety and Health Officers would not inadvertently cite "within the parameters of" ANSI Z133.1, revised or not.

For your information, enclosed is a copy of our telecommunications standards, some provisions of which are relevant to your concern about qualified employees or trainees in line clearance. Note Section 1910.268(g). Tree trimming - electrical hazards and in particular, note the requirement in subparagraph 1910.268(g)(2)(ii) that "Only qualified employees or trainees...shall be permitted to perform the work if it is found an electrical hazard exists". "Qualified employee" is defined in 1910.268(s)(33), also note the similarity in definition of "qualified line-clearance tree trimmer" to that in your enclosure (ANSI Z133.1-1982). However, our definition has no reference to a line-clearance contractor. In general, our standards apply to any employer in the private sector having at least one employee.

In regards to your reference in your first paragraph to a "utility" and "to work within the same proximity of electrical hazards", note the non-coverage to electric utilities stated in 1910.268(a)(2)(ii) and the approach distances indicated in Table R-3 of 1910.268(q)(2)(iv) of our telecommunications standards.

In summary, your member companies may safely undertake line clearance tree trimming operations if the operations are conducted in accordance with relevant OSHA regulations (e.g., (1910.268(g)).

In regards to your request to notify the proper individuals, all ten Regional Administrators will receive a copy of this correspondence.

I hope this information will be of help to you. Should you have any further questions, please do not hesitate to contact me.


John K. Barto
Chief, Division of Occupational
Safety Programming