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.

January 31, 1994

Mr. Charles H. Williams
Director, Codes and Standards
National Electrical Contractors Association
3 Bethesda Metro Center, Suite 1100
Bethesda, Maryland 20814

Dear Mr. Williams:

Your letter dated November 5 to Mr. Robert Reich, Secretary of Labor, requesting an interpretation of an Occupational Safety and Health Administration (OSHA) standard addressing the minimum working distances between employees and energized conductors (29 CFR 1926.950(c)(1)) has been forwarded to this office for response. I apologize for the delay in responding to your inquiry.

Please be advised that there is no generic two-foot rule that applies in all cases. As shown in paragraph 1926.950(c), Table V-1, in those situations where the protective measures set forth in paragraph (c)(1) and (2) are not maintained, the minimum distance required increases in increments as the voltage of the line increases.

With regard to whether or not the minimum distances are to be measured from the extended reach of the employee, please be advised that the standard imposes an obligation on the employer to assure that an employee, not otherwise protected as allowed in paragraphs (c)(1) and (2), does not approach or take any conductive object within the distances to any exposed energized part as listed in 1926.950. Adopting a "two feet (or greater distances as required for voltages above 15 KV) plus the employee's reach" procedure is a good way to satisfy this obligation. The situation to be prevented is where the employee's work does not necessitate his presence within the two foot zone for the phase to phase voltage range of 2.1 to 15 kilovolts, or, as stated in paragraph (c)(2)(i), "The minimum working distance and minimum hot stick distances stated in Table V-1 shall not be violated."

If we can be of any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,



Roger Clark
Director
Directorate of Compliance Programs