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.

September 6, 1984

Mr. Robert R. Clark
Manager, System Overhead Line
Arizona Public Service Company
Post Office Box 21666
Phoenix, Arizona 85036

Dear Mr. Clark:

This is in response to your letter of May 23, 1984, requesting an interpretation of 29 CFR 1926.955, which was forwarded to this Directorate for response from our Phoenix Area Office. This also confirms your telephone conversation with Mr. Simms of my staff.

The Exhibit "D" drawings attached to your letter appear to show equipment and operations that are in general compliance with the requirements of paragraphs (e) and (c) of Section 29 CFR 1926.955. In your telephone conversation of August 28, 1984, you informed Mr. Simms that the drawing on page 7.9 was not intended to show a de-energized and grounded conductor bonded to an energized 12 KV conductor.

In regard to the problems with the distribution stringing roller with a grounding bar attached but not assigned a fault current rating, we refer you to 29 CFR 1926.954(j). The above-mentioned standard provides that if the device used to ground a conductor or equipment (stringing block or roller) is not known to be capable of carrying this current, then the conductor or equipment must be considered and treated as energized, rather than as de-energized and grounded.

If we can be of further assistance, please let us know.


John B. Miles, Jr., Director
Directorate of Field Operations