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.

October 21, 1986

Mr. John D. Easton
Manager - Transmission and
Distribution Engineering
Public Service Electric and
Gas Company
80 Park Plaza
Newark, New Jersey 07101

Dear Mr. Easton:

This is in response to your letter of March 21, 1986, addressed to our Region II, Area Office requesting a clarification of 29 CFR 1926.550. Your letter was forwarded to this office for response.

It is true as indicated in your letter that the wording in 29 CFR 1926.550 (a)(15) refers to the voltage of electric distribution and transmission lines, but does not distinguish between phase-to-phase lines. It is intended that the phase-to-ground voltage be used in applying the standard to grounded systems. For ungrounded systems, of course, the phase-to-phase voltage must be used.

We appreciate your interest in this matter. If I can be of further assistance, please feel free to contact me.


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