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.

July 27, 1995

Mr. Robert P. Klein
International Brotherhood
of Electrical Workers
3922 Volunteer Drive
Suite 9
Chattanooga, Tennessee 37416

Dear Mr. Klein:

This is in response to your February 13 letter, requesting interpretation of the Electric Power Generation, Transmission, and Distribution Standard, 29 CFR 1910.269. Your work site scenario and question and our reply follow.

Scenario: A utility is requiring linemen to work alone at work sites where they are required to climb poles supporting energized lines. These linemen work on deenergized transformers such that they may be within 10 feet (3.05 meters) of an energized conductor.

Question: Would the employer of a lineman working alone as described in the scenario above be in compliance with Section 1910.269(l) Working on or near exposed energized parts?

Reply: Paragraph (l)(1)(i)(B) requires at least two qualified employees to be present during "[i]nstallation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts." In the scenario you described, a second employee would be required unless the employee performs all work from a position where he or she cannot reach or take any conductive object within the electrical component (see section III of Appendix B to section 1910.269) of the minimum approach distance. In Tables 1, 2, and 3 of Appendix B, the electrical component (in feet) of the minimum approach distance is delineated for the maximum anticipated, phase to phase, voltage for varying per-unit transient overvoltage.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact Ronald Davies of my staff, telephone (202)219-8031, extension 110.


John B. Miles, Jr., Director
Directorate of Compliance Programs

February 13, 1995

Mr. Ray Donnelly, Director
Office of General Industry Compliance
Assistant, OSHA
200 Constitution Ave., N. W.
Washington, D. C. 20210

Dear Sir:

I am writing to request from you a written confirmation of OSHA Ruling 1910.269, Electric Power Generation, Transmission, and Distribution, Paragraph L, Working On or Near Exposed Energized Parts.

A utility, where we represent the bargaining unit employees, is requiring lineman to go out and climb power poles with energized conductors attached by themselves. Although the lineman may be working on a de-energized transformer or service he/she would still be within ten (10) feet of energized primary conductor. We feel that sending this lineman out by him/herself is unsafe as well as violates Subparagraphs (i) and (b) of Paragraph L.

We feel that in order to perform this type of work safely and be within OSHA regulations two qualified lineman should be present on the job.

We are asking that if we are interpreting this ruling correctly that you send us the confirmation we have asked for so we may pursue this matter further.

Thanking you in advance for your assistance.


Robert P. Klein, Asst. Bus. Mgr.
IBEW Local Union 175