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 22, 1992

Mr. M. O. Brown, Jr.
Government Liaison
Virginia, Maryland and Delaware
Association of Electric Cooperatives
4201 Dominion Blvd. Suite 101
Glen Allen, Virginia 23058-2340

Dear Mr. Brown:

This is in response to your letter of July 8, and to a telephone conversation you had with James C. Dillard of my staff, in which you sought an interpretation from the Occupational Safety and Health Administration (OSHA) on whether there are OSHA standards that require the use of personal protective equipment (PPE), such as body belts and safety straps, by electric utility linemen when performing operation and maintenance work on poles and towers in the States of Virginia, Maryland and Delaware.

In your letter, you also asked if 29 CFR 1910.268(g), which covers the use of PPE for employees in the telecommunications industry, applies to employees in the electric utility industry. During the telephone conversation, Mr. Dillard informed you that our interpretation would only apply to Delaware, since Virginia and Maryland have approved State Plan programs, and that you agreed to pursue similar interpretations from those State Plan States.

We determined that electric utility linemen performing operation and maintenance work on poles and towers are covered by the PPE requirements found at 29 CFR 1910.132, Personal Protective Equipment. These workers are not covered by the requirements found at 1910.268(g). However, the specifications of 1910.268(g) may be used to meet the PPE requirements of .132 when work is performed by linemen at positions more than 4 feet (1.2m) above the ground.

As you may be aware, OSHA published Notices of Proposed Rulemaking, Walking and Working Surfaces and Personal protective Equipment (Fall Protection Systems) in the April 10, 1990, Federal Register. Paragraph 1910.130(c), Positioning device systems, of the proposed standard, would require linemen to use body belt and pole strap systems while working on poles or towers, in similar fashion as the telecommunications standard at 1910.268(g)(2)(ii)(A)(1) through 1910.268(g)(2)(ii)(D).

The proposed standard is still at the rulemaking stage, and we anticipate that it will become a final rule in the spring of 1993.

If you have any additional questions, please feel free to contact [the Office of General Industry Enforcement at 202 693-1850].


Roger A. Clark, Director
[Directorate of Enforcement Programs]

[Corrected 4/4/2005.

Note: On April 10, 1990 OSHA published proposed revisions to Walking and Working Surfaces; Personal Protective Equipment (Fall Protection Systems); Notices of Proposed Rulemaking; Slips; Falls; Trips in
Federal Register 55:13360-13441. It is available electronically only as an abstract. On May 2, 2003 OSHA reopened the rulemaking record on the proposed revisions to Walking and Working Surfaces and Personal Protective Equipment (Fall Protection Systems). It was re-published in its entirety in Federal Register 68:23527-23568 and is available electronically.]