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Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 18, 1995

Mr. Lonnie Bell
Oglethorpe Power Corporation
2100 East Exchange Place
Tucker, Georgia 30085

Dear Mr. Bell:

This is in response to your request for interpretation of the Electric Power Generation, Transmission, and Distribution Final Rule published in the Federal Resister, Volume 59, Number 20 on Monday, January 31, 1994. The thirteen questions you telefaxed without cover letter to our Atlanta Regional Office were forwarded to this office for response. Your questions and our replies follow. Please accept our apology for the delay in responding.

Question 1: What will the Occupational Safety and Health Administration (OSHA) accept as evidence of training?

Reply: An employer's certification made in accordance with 1910.269(a)(2)(vii) will be acceptable to OSHA. The note regarding documentation of training certification, which immediately follows this paragraph states:

  • Employment records that indicate that an employee has received the required training are an acceptable means of meeting this requirement.

Training can be noted by certification in an employee's personnel file or in another form such as an employer's file on employee training or in a file of training certification. Other means of training certification which set forth employee training as required by paragraph 1910.269(a)(2), are also acceptable. However, regardless of where the certification is contained, it must be readily available at a job site where an employee is hired or reports for work. This could include either a permanent establishment or a temporary job site.

Question 2: Will an employee's status as a Journeyman be considered as evidence of having met the training requirement?

Reply: A Journeyman who has the training required by 1910.269(a)(2)(ii) would be considered a qualified employee to the extent that he or she has been trained and has demonstrated proficiency in the work practices involved. However, simply being a journeyman does not necessarily mean that all provisions of 1910.269(a)(2)(ii) have been met. For example, a journeyman line worker may not have been trained in and familiar with cardiopulmonary resuscitation (CPR) or in selecting appropriate clothing for energized line work or in complying with minimum approach distances which meet 1910.269(l)(2) requirements, where these skills are required for the Job or are necessary for the employee's safety. An employer must ensure that all training required by 1910.269(a)(2) including the specific work practices required throughout 1910.269, in addition to the normal training given to a Journeyman, be provided.

Question 3: Will OSHA require some type of institutional certification for first aid/CPR training (such as Red Cross, American Heart Association, etc.) or will employment records or employer certification suffice?

Reply: Institutional certification is not required, but the employer will have to certify that CPR training has been accomplished. In fulfilling the requirements of 1910.269(b)(1), the employer can rely upon documented first aid and CPR training provided by a prior employer or other source so long as the first aid and CPR training documents are current and valid. The enclosed OSHA Instruction CPL 2-2.53 provides Guidelines for First Aid Training Programs. First aid and cardiopulmonary resuscitation (CPR) training (with or without institutional certification) which encompassses these OSHA guidelines would be considered in compliance with 1910.269(b)(1). This training must be tailored to the particular workplace needs for first aid and CPR.

Question 4: Almost all of our field personnel work alone. What would OSHA accept as evidence that working alone planning occurs?

Reply: Paragraph 1910.269(c)(3) requires tasks be planned as if a briefing were held. OSHA will check compliance with this rule by looking at any available documentation and interviewing affected employees. For the employer to be in compliance, each employee working alone must have adequate time and resources to plan the tasks to be performed and do his or her job safely. To the extent that the supervisor participates in the work by assigning a job to an employee, that supervisor must conduct a job briefing. The supervisor must touch on all the subjects listed in the introductory text to 1910.268(c) when the job assignment is made. This type of briefing may, of necessity, be general and may not address hazards unique to the work site. Of course, once the employee arrives at the work site, job planning to cover work site specific hazards must be conducted.

Question 5: Will training session attendance rosters serve as certification of employee lockout/tagout training required by 1910.269(d)(2)?

Reply: An attendance roster by itself is not the certification required by 1910.269(d)(2)(ix). Rather, the employer is required to make a specific finding that employee training as specified in paragraphs 1910.269(d)(2)(vi) through (viii) has been accomplished and is being kept up-to-date. The roster can be part of the certification since it will likely include the employee's name and the date of training which are required for the certification.

Question 6: Certain of our employees are required to work atop substation transformers that range in height from 13 to 15 feet (39.6 to 45.7 m) and come in a variety of designs and configurations. Would OSHA consider allowing use of fall protection devices in lieu of guard rails in these situations?

Reply: Working atop transformers is specifically excluded from the personal protective equipment requirements of 1910.269(g)(2)(v). See Note 1 following 1910.269(g)(2)(v). This note identifies Part 1910, Subpart D-Walking-Working Surfaces as the General Industry standard which applies to this workplace application. Specifically, paragraph 1910.23(c)(1) applies since the top of a transformer would be considered a platform as defined in paragraph 1910.21(a)(4). A standard railing or other method which provides equivalent fall protection must be used. Please be advised that there is a Notice of Proposed Rulemaking (NPRM) to amend Part 1910, Subpart D. A copy of this NPRM, which was published in the Federal Register, Volume 55, Number 69, on Tuesday, April 10, 1990, is enclosed. Fall protection requirements are covered by 1910.27 which is on page 13401 of the NPRM. The Final Rule on Part 1910, Subpart D and Subpart I is scheduled for publication April 1996.

Question 7: What is "maximum arresting force"?

Reply: "Maximum arresting force" as used in 1910.269(g) means the most impact force to which an employee might be subjected when using a personal fall arrest system to arrest a free fall. To comply with 1910.269(g)(2)(vi), a personal fall arrest system must be rigged such that an employee can neither free fall more than 6 feet (1.8 meters) nor contact a lower level. When a body harness is used as a component of the personal fall arrest system, the maximum arresting force must be limited to 1800 pounds force (8 kilo-newtons). This corresponds to an employee having a combined tool and body weight of 300 pounds (1667.67 newtons) free falling a distance of 6 feet.

To comply with 1910.269(g)(2)(i), personal fall arrest equipment must meet the requirements at 1926.502(d) in Subpart M of the Construction Standard. This requirement is further clarified to mean that the personal fall arrest equipment design requirements and other personal fall arrest equipment requirements at section 1926.502(d), not otherwise covered by the safety related work practices requirements of paragraphs 1910.269(g)(2)(iii) through (ix), must be met.

A copy of the Final Rule on Subpart M is enclosed for your use. As noted in the last paragraph of the middle column on page 4371 of the electric power generation Final Rule, Appendix C to the powered platforms for building maintenance standard, section 1910.66, contains additional information on personal fall arrest systems.

Question 8: What does "exposed to contact" mean?

Reply: For the purposes of complying with 1910.269(l)(1)(i) and (l)(1)(ii), "exposed to contact" is meant to apply to an employee who is in a working position from which he or she can reach or take a conductive object within the electrical component of minimum approach distances. (See section III of Appendix B to 1910.269, which includes tables on these distances for different voltages.

Question 9: Are cover-up (rubber, flexible synthetics, ABS plastic, linear polyethylene) equipment generally used in overhead line work acceptable for guarding of energized parts required by 1910.269(v)(5)(i)?

Reply: No. Paragraph (v)(5) of l910.269 requires the permanent guarding of live parts in electric power generation installations. This guarding can take the form of enclosures around electric equipment or railings or other means of guarding the energized parts by location. The type of cover-up you describe is intended as temporary guarding only.

Paragraph (v)(5)(iii) of 1910.269 requires barrier to be installed when permanent guards required by 1910.269(v)(5)(i) are removed (for example, during servicing and maintenance). The type of cover-up you describe would be an acceptable form of temporary barrier under paragraph 1910.269(v)(5)(iii).

Question 10: Are two employees required to be present when the cover-up equipment (described in the previous question) is being applied?

Reply: One employee may be used to install a barrier when the barrier is installed by the employee following a safe work procedure that includes the use of hot sticks or other equivalent means of installing the barrier from a safe distance. Otherwise, at least two employees must be present.

Question 11: Is cover-up equipment considered "insulation?"

Reply: Cover-up equipment rated for use on the voltage involved would be considered as insulation for the purpose of 1910.269(l)(2).

Question 12: Will an employer be found in compliance with 1910.269(n)(5) when his or her employees use the practices of fuzzing or buzzing, instead of a voltmeter, to test a line conductor to be grounded to be sure it is deenergized (dead) before the protective ground is installed?

Reply: Yes, however, the preferred method of testing line conductors to be sure they are deenergized (dead) before protective grounds are installed is by using a high-voltage detector (voltmeter). However, 1910.269(n)(5) permits a circuit to be tested by "fuzzing (buzzing)" but that method should be used only when a high-voltage detector (voltmeter) is not available and when the presence of nominal voltage on the lines or equipment can be detected reliably in consideration of actual workplace conditions. Fuzzing procedures are considered unreliable in detecting voltages of less than 13.2 Y/ 7.62 kV. Fuzzing procedures are discussed in "The Lineman's and Cableman's Handbook," Eighth Edition, published by McGRAW-HILL,INC., ISBN 0-07-035695-5.

Question 13: Certain of our employees frequently patrol power lines alone in remote rural areas and are occasionally required to traverse streams and swamps. Is the corporation in violation of 1910.269(w)(5)(iii) by requiring this practice?

Reply: If an employee is required to traverse streams or swamps, alone or in company with other employees where the danger of drowning exists, the employer would be in violation of paragraph 1910.269(w)(5)(iii) unless safe means of passage, such as a bridge, is provided.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact [the Office of General Industry Enforcement at (202) 693-1850].


John B. Miles, Jr., 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.]