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.

March 26, 1996

Mr. Michael L. Harbaugh
S.A.L.C.O.M. Inc.
2717 Caronado
Great Bend, Kansas 67530

Dear Mr. Harbaugh:

This is in response to your January 20, 1995, letter requesting clarifications and interpretations of the electric power generation, transmission, and distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding.

Your January 20 letter redraft of questions previously sent in your August 23, 1994, letter is acknowledged. The Northwest Public Power Association (NWPPA) interpretations and methods of compliance offered with each of the questions in your January 20 letter also are acknowledged. The NWPPA interpretations and methods of compliance were used as a reference in the formulation of our replies to your questions. Please be advised that compliance with Occupational Safety and Health Administration (OSHA) standards is determined on a workplace by workplace basis. Also, 1910.269 is a performance based standard. Your questions and our replies follow.

Question 1:

Does an employee have to go through a recognized apprenticeship training program to be considered a qualified employee who is trained in compliance with paragraph 1910.269(a)(2) to perform his job, for example, as a lineman?


No. In paragraph 1910.269(x), a qualified employee is defined as one who is knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved in his or her job, along with the associated hazards. Having power line workers go through an apprenticeship training program may not provide all the training required under paragraph 1910.269(a)(2)(ii). The employer must ensure that the program used includes all applicable training elements required under paragraph 1910.269(a)(2)(ii) and work practices throughout 1910.269.

For example, minimum approach distances covered by the training program must conform to those required under 1910.269 rather than those required under Subpart V of the 29 CFR 1926 Construction Standard. (The Subpart V minimum approach distances have been commonly used in apprenticeship programs over the past 20 years.) Additionally, even if the apprenticeship training program generally conforms to paragraph 1910.269(a)(2)(ii), the employer must supplement this with instruction in practices which specifically address safety hazards to which employees are potentially exposed in the particular workplace. Most often, such training is accomplished on the job.

Question 2:

If the answer to Question 1 is no, what training is required to be considered a qualified employee?


The training required depends on what job tasks the (lineman, meter reader, substation technician, serviceman, etc.) employee is required to perform. All employees must be trained in and familiar with the safety requirements in paragraph 1910.269(a)(2)(i). Also, qualified employees must be trained and competent in the safety requirements in paragraph 1910.269(a)(2)(ii). The electric power generation standard cannot specify requirements for every hazard the employee faces in performing his or her job. The employer must fill in the gaps by training the employee in hazards anticipated during the course of jobs the employee is expected to perform.

Question 3:

An employee has 10-25 years of on-the-job training on which there are no records. In this case, what basis could the employer use to certify that the employee has received training required by paragraph 1910.269(a)(2)?


An acceptable way of certifying training would be for the employer to certify that an employee has completed on-the-job training that complies with the applicable requirements under paragraphs 1910.269(a)(2)(i) and (a)(2)(ii). This certification can only be given when the employee demonstrates proficiency in the work practices involved.

Question 4:

An employer hires an employee on a temporary (1 week to 6 months) basis. To what extent must the employer determine that the temporary employee has been trained, for example, through union affiliation, to perform the job for which hired? Would the extent of this determination be the same for an employee hired on a permanent basis?


Whether hired on a permanent or a temporary basis, employees must be trained as required under paragraphs 1910.269(a)(2)(i) and (a)(2)(ii). As specifically required in paragraph 1910.269(a)(2)(vii), employees must demonstrate proficiency in the work practices involved before the employer may certify that the employee has received the training.

As outlined in your letter, an employer could request documentation from the union (or previous employers) or could institute a testing program to ensure that the employee has been trained. Regardless of the method chosen, however, the employer must still certify that the required training has been provided "when the employee has demonstrated proficiency [to the employer] in the work practices involved." This could be accomplished by close supervision during a short probationary period, with the supervisor when certifying that the employee has demonstrated proficiency in the work practices involved. Additionally, the employer could hold training orientation in workplace-specific practices and hazards for new and temporary employees who have been trained elsewhere.

Question 5:

Referring to Question 4 above, what training records would have to be obtained by the employer on an employee hired on a temporary basis? What would the employer have to do to verify that this temporary employee is properly trained?


The records an employer obtains have to indicate that the new (temporary or permanent) employee has received the training as required under paragraphs 1910.269(a)(2)(i) and (a)(2)(ii). Also, the records must indicate that the training establishes employee proficiency and introduces the necessary procedures required under paragraph 1910.269(a)(2)(vi).

When verified by the hiring employer, these records, whether obtained from the employee, another employer or other (for example, training) source, would be acceptable to OSHA.

The answer to the second part of your question has been provided in our reply to question 4.

Question 6:

To be in compliance with paragraph 1910.269(a)(2)(iii), does the employer have to determine that each employee is following applicable safety-related work practices through inspections conducted at least annually? Also, do records of these inspections have to be maintained by the employer?


An employer must determine that each employee is following applicable safety-related work practices not only by regular supervision but also by conducting an annual inspection. The annual inspection, in combination with regular supervision, must provide for detection of violations of the work practices required under 1910.269.

The power generation standard does not contain a requirement that the employer maintain records of these annual inspections. However, an employer may keep such records for the purpose of demonstrating compliance with paragraph 1910.269(a)(2)(iii), for example, when asked during a workplace inspection by OSHA.

Question 7:

Paragraph 1910.269(a)(2)(vi) requires that the training shall establish employee proficiency in the work practices required by 1910.269. Does the proficiency have to be a written proficiency that the employee is measured against to be in compliance with 1910.269?


We understand your question to be: Does OSHA require the criteria against which employees are judged to be in writing? The answer to this question is no. However, employers still must certify that the required training has been provided "when the employee has demonstrated proficiency [to the employer] in the work practices involved."

Written tests, supervisory inspection guidelines and the like would enable the employer to show compliance with paragraphs 1910.269(a)(2)(vi) and (vii).

Question 8:

What does OSHA intend by the paragraph 1910.269(c)(3) requirement that tasks to be performed (by an employee working alone) are "planned as if a (job) briefing were required?"


Whether working alone or with other employees, the employee must consider what equipment, procedures and practices must be set forth for the job. The Agency believes that an employee who works alone needs to plan his or her tasks no less than an employee who is assisted by others. As noted at the top of the third column of page 4349 of the preamble to the electric power generation final rule, a copy of which is enclosed for your use, several fatalities in the record involved a lone employee who could have benefitted from better job planning or perhaps a briefing with the supervisor before starting the job.

As you note in your letter, discussions with the supervisor when the job is assigned may meet this requirement. However, regardless of whether there is supervisory input, the employer must ensure that employees plan and understand all the steps necessary to complete their jobs safely. These steps must address such considerations as: what conductors and circuit parts are energized and what their voltages are; what the minimum approach distances are and how they are to be maintained; what exposed conductors must be covered with insulating materials before the actual task is begun and other safety-related job briefing requirements listed in the introductory text under paragraph 1910.269(c). While some of these considerations can be addressed in discussions with a supervisor, the employee will need to address others upon arrival at the work site.

Question 9:

If an enclosed space is not entered on a routine (daily) basis or is not vented, does paragraph 1910.269(e) or does 1910.146 apply?


An "enclosed space", as defined in paragraph 1910.269(x), is "a working space, such as a manhole, vault, tunnel, or shaft, that has a limited means of egress or entry, that is designed for periodic entry under normal operating conditions, and that under normal conditions does not contain a hazardous atmosphere, but that may contain a hazardous atmosphere under abnormal conditions."

Enclosed space is clarified by the note following the paragraph 1910.269(x) definition as follows:

"Spaces that are enclosed but not designed for employee entry under normal operating conditions are not considered to be enclosed spaces for the purposes of 1910.269. Similarly, spaces that are enclosed and that are expected to contain a hazardous atmosphere are not considered to be enclosed spaces for the purposes of 1910.269. Such spaces meet the definition of a permit-required confined space (PRCS) in 1910.146, and entry into them must be performed in accordance with the PRCS standard." Although these spaces are designed for periodic entry, such entry was not intended to be performed on a daily particular enclosed space. Rather, the term "routine entry" used in the introductory text under paragraph 1910.269(e) means that: (1) employees enter enclosed spaces as a normal or routine part of their job duties and (2) the entry in a given situation is routine in nature (such as normal maintenance and repair activities) and not due to unusual circumstances (such as a chemical spill within an enclosed space). Depending on the purpose for entering an enclosed space as defined and clarified above, either or both of the standards you referenced may apply to an employer.

When the intended purpose of a qualified employee is to enter an enclosed space to perform electric power generation, transmission, or distribution work covered under 1910.269, his or her employer must comply with 1910.269(e). When the intended purpose of an employee is to enter a permit-required confined space to perform work other than that which is covered by the electric power generation standard or when hazards cannot be controlled completely through compliance with 1910.269, the PRCS standard applies.

Question 10:

Why is an attendant allowed to enter a manhole briefly to provide assistance, other than emergency under paragraph 1910.269(t)(3)(ii), but is not permitted to enter into enclosed spaces under paragraph 1910.269(e)(7)?


Whether the attendant can enter an enclosed space depends upon the characterization of the space and the anticipated hazards. Paragraph 1910.269(t)(3) addresses the hazards of electric shock. In this situation, an attendant could briefly assist the worker in the space without compromising safety. Paragraph 1910.269(e)(7) addresses other hazards such as traffic around the entrance and concentrations of flammable vapors. In these situations, the attendant would be exposed to the same hazards against which he or she is trying to protect the original entrant. A fuller explanation can be found with respect to paragraph 1910.269(e)(7), starting at the last paragraph of the middle column on page 4368 and with respect to paragraph 1910.269(t)(3)(ii), starting at the first paragraph of the right-hand column on page 4414 of the preamble to the enclosed Final Rule.

Question 11:

Is a pole strap (in combination with pole climbers and a body belt) when used by a power line worker considered fall protection equipment?


As explained in the reply to Question 16 which follows, the answer to your question is yes, provided that the power line workers are trained as required under paragraph 1910.269(a)(2) to use such equipment.

Question 12:

Can the equipment described in Question 11 be used to provide fall protection to unqualified employees?


No. Under paragraph 1910.269(g)(2)(v), an unqualified employee undergoing training in climbing techniques must be protected fully from fall hazards. The equipment described in Question 11 does not provide such protection for an employee who is untrained in its use.

After the employee has demonstrated proficiency (to the employer) in the work practices involved and the employer has certified that the employee has been trained, the employee is considered "qualified" for the purposes of paragraph 1910.269(g)(2)(v).

Question 13:

If the employee successfully completes two weeks of wood poles, climbing training at a school at which proficiency of wood pole climbing is demonstrated, would this employee be considered qualified for the purpose of climbing work site wood poles and wood structures?


The employee is considered qualified for the purposes of complying with paragraph 1910.269(g)(2)(v) after:

  1. he or she has undergone training and has demonstrated proficiency in

    1. in using fall protection equipment and

    2. climbing the types of structures that present the same types of hazards and that require the same skills as those that will be climbed in his or her job, and

  2. after the employer certifies (as required under paragraph 1910.269(a)(2)(vii)) that the employee has received this climber training.

Question 14:

Is an employee who has been trained and demonstrated a proficiency to climb and change locations on work site like poles, towers, or similar structures, qualified to climb such structures on which energized conductors are installed?


Yes, as long as an employee is otherwise "qualified" to perform the job tasks assigned by his or her employer. (See our reply to question 2 above.)

Question 15:

What would an employer have to do to qualify an employee (who has been trained and demonstrated a proficiency to climb and change locations on worksite like poles, towers, or similar structures) to climb structures on which energized conductors are installed?


An employee who is a qualified climber must be trained as required by paragraph 1910.269(a)(2)(i) and (a)(2)(ii) before the employee can be allowed to climb if he or she could be exposed to a harmful electrical energy source that is located on the structure or nearby. (See the reply to Question 2 above.) As you noted in your letter, with respect to work on or near energized parts, an employer may qualify an employee in increments based on the types of work for which they have been trained.

Question 16:

Is a lineman's pole climbers, pole strap, and body belt considered fall arrest equipment?


Normally, a safety strap in combination with a line worker's body belt and pole climbers is work positioning (not fall arrest) equipment for the purposes of meeting paragraph 1910.269(g) requirements. The safety strap, body belt, and pole climbers support the employee, protecting the employee from falling while he or she works with both hands free. However, in certain overhead transmission and distribution work applications (for example, when a power line worker is sitting on a cross arm or horizontal support member), a pole strap in combination with a body belt is used for protection to arrest an employee's fall. As long as the maximum free fall is limited to 2 feet or less in these work applications, OSHA will still consider the use of such equipment as work positioning equipment.

If the maximum free fall is not limited to 2 feet or less, this type of fall protection may not meet paragraph 1910.269(g) requirements. Fall protection equipment meeting the requirements of paragraph 1910.269(g)(2)(i) and 29 CFR 1926, Subpart M, which apply to fall arrest equipment, must be used. Please note that Subpart M prohibits the use of a body belt as a component of fall arrest equipment after January 1, 1998. After this date a harness will be required.

Question 17:

How does Subpart M-Fall Protection of the 29 CFR 1926 Construction Standard apply to paragraph 1910.269(g)(2)?


The definitions in paragraph 1926.500 and the requirements in paragraph 1926.502(d) apply to personal fall arrest equipment covered by paragraph 1910.269(g)(2). Under paragraph 1910.269(g)(2), work positioning equipment must meet 1926.959, not Subpart M.

Question 18:

Does paragraph 1926.502(e) which covers positioning device systems apply to a lineman's pole climbers, pole strap and safety (body) belt equipment?


No. The only paragraph 1910.269(g) reference to the fall protection requirements of the Construction Standard (29 CFR 1926) is with respect to fall arrest requipment. There is no 1910.269 reference to the work positioning requirements under paragraph 1926.502(e).

Question 19:

Are employees prohibited from using conductive ladders when performing electric power generation, transmission, and distribution work?


Yes, portable metal ladders and other conductive ladders may not be used near exposed energized lines or conductors except as allowed under paragraph 1910.269(h)(3).

Question 20:

Does the word "structure" used in paragraph 1910.269(h)(2) include a building? If so, does a portable ladder leaning on the side of the building at ground level have to be tied at the top to something to prevent it from falling before the ladder is used by a qualified employee to perform servicing or maintenance on a energized line, for example, to a residential home.


Paragraph 1910.269(h)(2) applies only to specialty ladders used in overhead transmission and distribution line work. Normally, these ladders cannot comply with 29 CFR 1910, Subpart D, requirements for ladder footing and placement (specifically paragraphs 1910.25(d)(2)(i) and (d)(2)(iii) and 1910.26(c)(3)(iii)).

Therefore, paragraph 1910.269(h)(2) provides requirements that substitute for the Subpart D provisions. Portable wood and metal ladders meeting 1910.25 and 1910.26, respectively, need not comply with paragraphs 1910.269(h)(2)(i) through (h)(2)(iv).

Question 21:

Please clarify what paragraph 1910.269(i)(3)(i) means?


This provision means that a portable generator used to supply cord- and plug-connected equipment cannot supply equipment connected by permanent wiring methods, nor can it supply other wiring systems. Paragraph 1910.269(i)(3)(i) essentially extends the requirements for portable and vehicle-mounted generators under paragraph 1926.404(f)(3) to electric power transmission and distribution field operations.

Question 22:

If a hydraulic tool is supplied by a hydraulic system, for example, as installed on an aerial device, such that the separation distance between the oil reservoir and the upper end of the hydraulic system is greater than 35 feet (11.48 meters) but less than 50 feet (16.40 meters), is the employer required to install a check valve in the hydraulic system to be in compliance with paragraph 1910.269(i)(4)(iii)?


A check valve installed at the reservoir in a hydraulic line having a separation distance of more than 35 feet (10.7 m) between the oil reservoir and the upper end of the hydraulic tool complies with paragraph 1910.269(i)(4)(iii). Under the performance-oriented requirements of 1910.269, an employer has the option of using other safety applications or methods to protect against the loss of insulating value for the voltage involved due to the formation of a partial vacuum.

It should be noted that the hydraulic system poses the same hazard even if hydraulic tools are not being used. Therefore, insulated aerial lifts used in live-line bare-hand work, where the insulated portion of the lift is bonded to an energized conductor, must have protection also against loss of insulating value due to the formation of a partical vacuum.

Question 23:

If workplace live-line tools are inspected every two years at which time no defects are found, would these inspected tools also have to be tested every two years for an employer to be in compliance with paragraph 1910.269(j)(2)(iii)?


The answer to your question is no, unless:

  1. The live-line tool has been repaired or refurbished regardless of its composition; or

  2. The live-line tool is made of wood or hollow fiberglass reinforced plastic (RFP).

Question 24:

How does an employer determine by inspecting a live-line tool that it has no hazardous defects without testing it?


This provision is performance-oriented and does not specify what defects are prohibited or what defects are acceptable. Some defects that normally would indicate potential failure of the tool include scratches that penetrate the finish on the tool, contamination that cannot be removed without using a solvent that could damage the tool's finish, and areas on the tool where the finish is worn away completely. Such defects can allow moisture to penetrate the tool, decreasing its insulating value. Applying wax over such defects is, at best, a temporary barrier against contamination.

Reference sources applicable to inspection activities include national consensus standards (See Appendix E to 1910.269), manufacturers recommendations, and other recognized safe working practices of the industry. Employers may use such sources in demonstrating compliance with paragraph 1910.269(j)(2).

Question 25:

Under paragraph 1910.269(l)(3), does an employee have to wear rubber insulating sleeves in addition to rubber insulating gloves if energized parts are covered with insulating equipment rated for the voltage and if this insulating equipment is placed from a position that does not expose the employee's arms to contact with other energized parts?


Paragraph 1910.269(l)(3) applies to the use of the rubber insulated glove method when working on energized lines and equipment. This paragraph requires that rubber insulated sleeves be worn in conjunction with rubber insulated gloves unless:

(1) Energized parts on which work is not being performed are insulated from the employee, and

(2) This insulation is placed from a position such that the employee's arms are not exposed to contact with other energized parts.

The insulation must cover all exposed energized parts within the maximum extended reach of the employee's arms. When the employee places the insulation, he or she must be positioned so that his or her arms cannot contact the energized part being insulated or any other energized part. Also, the working position must minimize the employee's exposure to contact with the part being insulated. See paragraph 1910.269(l)(4).

Question 26:

If a qualified employee uses a hot line clamp to open a circuit under load, would his or her employer be in compliance with paragraph 1910.269(l)(10)? This work practice, currently, is in use throughout the country.


For the purposes of complying with paragraph 1910.269(l)(10), a device, such as a "hot line clamp," must be designed to interrupt current in order to be used to open a circuit under load. To open a circuit under load with a device that is not designed to interrupt current is considered a hazard. Non-load-break switches used to open a circuit while it is carrying a load current could fail catastrophically, severely injuring or killing any nearby employee(s).

The 1910.269 standard does not require load-break type switches to be installed at all locations where a circuit would have to be opened. The alternatives listed in your letter (deenergizing the line or removing the load) may be used to comply with this standard. Additionally, there are live-line tools designed to be used to break circuits under load conditions. Such tools are commonly called "load busters."

Lastly, the employer would not be cited for a violation of paragraph 1910.269(l)(10) when employees are not exposed to the hazards involved. This would be the case if the non-load-break disconnecting device was operated from a remote position from where the employee using the device nor other employees could not be injured in the event the device failed.

Question 27:

If a qualified employee removes a residential 120/124 electric meter under load from its socket, would his or her employer be in compliance with paragraph 1910.269(l)(10)?


If the meter is capable of interrupting the load without failure, then it would be acceptable for an employee to remove the meter while it is under load.

Question 28:

It is my understanding that OSHA will accept clothing made of 100 percent cotton at least 11 ounces in weight or fire resistant/flame-retardant-treated clothing for compliance with paragraph 1910.269(1)(6)(iii). Is this correct?


Your understanding is not completely correct with respect to clothing made of 100% cotton. Clothing made from untreated, 100% natural cotton, 11 ounces per yard (374.16 grams per meter) in weight or more, would be acceptable under the rule when the clothing weight is appropriate for the flame and electric arc conditions to which an employee could be exposed. The Power Generation Standard correction notice published in 59 FR 33658 on June 30, 1994, cited evidence that clothing made from this weight of cotton would not ignite in the presence of a 12 inch (30.48 cm) long, 3800 ampere electric arc, 12 inches away and lasting 10 cycles at the power line frequency.

Employers must consider: the weight of the material; the available current involved; the duration of exposure; the distance from any possible flames or arcs that might occur; and the presence of other flammable materials (such as flammable hydraulic fluid) that could be ignited in the presence of an arc and, in turn, ignite the clothing.

Question 29:

If I have a crew that is going to be working on an electric line and the means of disconnection is accessible, but is not visible to the crew, how would I work on this section of line to be in compliance with paragraph 1910.269(m)(2)(iii)?


If a system operator (See paragraph 1910.269(m)(2)(i)) is in charge of the lines or equipment and their means of disconnection, all of the requirements of paragraph 1910.269(m)(3) must be observed, in the order given. If there is no system operator, then one person in the crew must be designated to be in charge of the clearance as required under paragraph 1910.269(m)(2)(ii).

In this case, all the requirements of paragraph 1910.269(m) still apply, with the employee in charge of the clearance taking the place of the system operator. In other words, the line still must be deenergized and tagged following the procedures required under paragraph 1910.269(m)(3). Because the means of disconnect are not visible to the crew in your example, paragraph 1910.269(m)(2)(iii) does not apply.

Question 30:

Referencing paragraph 1910.269(n)(3), is equipotential grounding required when employees are working on poles?


According to paragraph 1910.269(n)(3), protective grounds must be so located and arranged that employees are not exposed to hazardous differences in electrical potential. As long as employees are protected, employers may use whatever grounding method they prefer. The employer must make a determination of the maximum voltage that would appear across the employee if the line on which work is being performed becomes energized. The grounding method selected must ensure that this voltage poses no hazard to the employee. In some cases, single-point grounding installed at the pole may be adequate. In other cases, it may be necessary to provide a grounding strap to minimize the potential difference across the employee.

Question 31:

Does protective grounding equipment have to be tested to verify the low impedance requirement under paragraph 1910.269(n)(4)(ii)?


There is no specific 1910.269 requirement to test protective grounding equipment for low impedance.

Question 32:

If it is required, how often must the testing be performed to verify low impedance of protective grounding equipment?


The reply to Question 31 above applies.

Question 33:

A testing trailer is used to test URD cable. Test equipment leads are run from the test trailer to the URD transformer. Would an employer be in compliance with paragraph 1910.269(o)(5)(i) if the entire area is made a test area which is barricaded accordingly? Otherwise, would the testing leads have to be in a grounded metallic sheath?


Paragraph 1919.269(o)(5)(i) requires control wiring, meter connections, and test leads and cables to be run in a grounded metallic sheath. This provision and other requirements in paragraph 1910.269(o) are intended to ensure that high voltage and high power testing does not impose voltage on test equipment cases and does not create hazardous step and touch potentials. Alternatively, the employer may use methods that the employer can demonstrate provide equivalent safety. Barricading the entire area would not provide equivalent safety because qualified employees would still be exposed to hazardous step and touch potentials. For further information on safety in high voltage and high power testing and for specific work procedures that can be used with this rule, see the Institute of Electrical and Electronics Engineers (IEEE) Inc. Standard 510.

Question 34:

Referencing the URD cable testing described in Question 33, would long, for example, 0.25 mile (0.46 km), testing leads have to be in a grounded metallic sheath when the entire testing area cannot be barricaded?


The reply to Question 33 applies.

Question 35:

Is the insulated insert in the lower portion of an aerial lift boom of a bucket truck considered insulated for the purpose of complying with paragraph 1910.269(p)(4)(iii)(B)?


When the employer opts to comply with paragraph 1910.269(p)(4)(iii)(B) such that the equipment is insulated for the voltage involved, insulated portions of the equipment can approach exposed, energized electrical lines or equipment closer than the minimum approach distances specified in Table R-6 through Table R-10 of paragraph 1910.269(l). However, uninsulated portions of the equipment may not come closer than the applicable minimum approach distance specified in these tables.

For aerial lifts to be considered insulated for the voltage involved, the employer must maintain the equipment in accordance with the American National Standards Institute's standard ANSI A92.2 and the manufacturer's recommendations. The lower insert in an aerial lift boom can be considered as insulating if the employer treats and maintains it as such. If the insulating qualities of the lower insert are not maintained, then the bottom section of the boom must be considered as conductive. Additionally, during the time the lift is closer than the minimum approach distance specified in Table R-6 through Table R-10 to an energized part (as permitted under paragraph 1910.269(p)(4)(i)), the insulated portion of the aerial lift must not be bridged by the operating employee bringing it closer than this distance to grounded objects or to other energized parts at a different voltage.

Question 36:

Is the installation of grounds required by paragraph 1910.269(q)(2)(iv)(D) intended to provide an equipotential zone for the workman?


The installation of grounds required by paragraph 1910.269 (q)(2)(iv)(D) is intended to protect employees from hazardous induced voltage in conductive lines and conductive equipment, as for example, during installation or removal of these conductive pull cables when parallel and nearby existing energized lines.

Please note that paragraph 1910.269(n)(3), which requires grounds to be installed so that employees are protected against hazardous differences in potential, still applies.

Question 37:

Under paragraph 1910.269(t)(3)(ii), an attendant "may briefly enter a manhole to provide assistance, other than emergency." What is meant by "briefly?" Are there any other limitations on what, and on when, assistance can be provided?


The attendant is permitted to enter and remain within the manhole only for a short period of time necessary to assist the employee inside the manhole with a task that one employee cannot perform alone. For example, if a second employee is needed to help lift a piece of equipment into place, the attendant could enter only for the amount of time that is needed to accomplish the task. However, if significant portions of the job require the assistance of a second worker in the manhole, the attendant would not be permitted to remain in the manhole for the length of time that would be necessary, and a third employee would be required.

Because the hazards addressed by paragraph 1910.269(t)(3) are related primarily to electric shock, allowing the attendant to enter the manhole briefly has no significant effect on the safety of the employee the attendant is protecting. In case of electric shock, the attendant would still be able to provide assistance. If other hazards are believed to endanger the employee in the manhole, paragraph 1910.269(e)(7) would apply and the attendant would not be permitted to enter the enclosed (manhole) space. Other hazards include those inside (for example, hazardous flammable vapors should the ventilation system fail) and outside (for example, hazardous traffic) the manhole.

Question 38:

Under what conditions, if any, can an employer allow an unqualified employee or unqualified person to enter energized substation areas and be in compliance with paragraph 1910.269(u)?


Electric power generating stations and transmission and distribution substations typically have areas containing energized electric lines and equipment. Unless the energized lines or equipment are guarded sufficiently, it is unsafe for unqualified persons to enter these spaces.

Paragraphs 1910.269(u)(4)(i)(A) through (C) and 1910.269(v)(4)(i)(A) through (C) set requirements for spaces within substations and generating stations, respectively, that are acceptable for unqualified persons to enter. Under paragraph 1910.269(u)(4)(ii) through (v) and 1910.269(v)(4)(ii) through (v), areas not meeting these requirements are restricted from entry by unqualified persons. The board members you identified in your letter are considered unqualified persons for the purposes of the 1910.269 standard.

Employers may train employees as qualified employees for the purpose of entering and working within restricted areas of generating stations and substations. While the training for these employees must meet paragraph 1910.269(a)(2)(ii), such training need not be as comprehensive as the training provided normally to a qualified electrical worker. These "qualified" (nonelectrical) employees must have the following minimum training:

(1) They must know what is safe to touch and what is not safe to touch in the specific areas they will be entering (paragraph 1910.269(a)(2)(ii)(A)),

(2) They must know what the maximum voltage of the area is (paragraph 1910.269(a)(2)(ii)(B)),

(3) They must know the minimum approach distances for the maximum voltage within the area (paragraph 1910.269(a)(2)(ii)(C)), and

(4) They must be trained in the recognition and proper use of protective equipment (note: only fully qualified electrical employees may install insulating equipment on energized parts) that will be used to provide protection for them and in the work practices necessary for performing their specific work assignments within the area (see the definition of "qualified employee" under paragraph 1910.269(x)).

Until these "qualified employees" have demonstrated proficiency in the work practices involved, they are considered to be employees undergoing on-the-job training and must be under the direct supervision of a qualified person at all times. According to the definition of "qualified employee," the employee also must have demonstrated an ability to perform work safely at his or her level of training. It is expected that an orientation familiarizing the employee with the safety fundamentals given here will be conducted before an employee undergoing training is allowed to enter a restricted area.

Question 39:

With reference to Question 38 above, can unqualified employees tour a substation involving energized, electric supply lines or equipment when under the direct supervision of a qualified employee or qualified person? If so, what conditions apply?


The reply to your question is no. However, an employee can be trained and then (as discussed in our reply to question 2) certified as qualified to tour a particular substation.

Question 40:

Referencing Question 38 above, under what condition can an employee enter a substation area for the purpose of reading an electric meter?


The meter reader must be a qualified employee or qualified person as delineated in the reply to Question 38 above.

Question 41:

Under what conditions, if any, can an unqualified employee, such as a janitor or an unqualified person, such as a postman, enter an electric power generation plant when it is operating such that an employer would be in compliance with paragraph 1910 269(v)?


An unqualified employee or unqualified person may enter a electric power generation plant subject to the following restrictions. Unqualified employees and unqualified persons are not permitted to enter locations, that is, rooms and spaces covered by paragraph 1910.269(v)(4)(ii) through (v)(4)(v) while the electric supply lines or equipment are energized. Also, only authorized employees or authorized persons may enter a restricted area as specified in paragraph 1910.269(v).

Question 42:

What is meant by "sufficient illumination" required by paragraph 1910.269(w)(4)? How many foot-candles of light does OSHA require the employer to provide for sufficient illumination of employee when performing other 1910.269 safetyrelated work practices?


The consensus standards, such as ANSI/IESNA RP-7 1991, can be used as guidelines to determine compliance with paragraph 1910.269(w)(4). For example, this standard prescribes an illuminance of 50 lux (lumen/m(2)) or 5 foot-candles (lumen/ft(2)) for vertical tasks in substations and transformer yards.

Note: One lumen is equal to the luminous intensity which falls on each m(2) (ft(2)) of a sphere 1 m (ft) in radius when a 1-candela (cd) isotropic light source (one that radiates equally in all directions) is at the center of the sphere. The candela is the unit of luminous intensity and is defined in terms of the light emitted by a blackbody at a freezing temperature of platinum, 1773 degrees C.

Question 43:

Under what conditions, if any, can electrical protective equipment be stored overnight, on weekends or for longer periods on bucket or digger trucks such that an employer would be in compliance with the requirements of paragraph 1910.137(b)(2)(vi)?


Carrying electrical protective equipment on trucks for the use of employees during the course of work is not considered to be storage. Keeping this equipment on a truck overnight would not be considered as storage.

On the other hand, OSHA does not believe that personal protective equipment should be stored for extended periods between use if such storage exposes this equipment to injurious conditions which adversely affect its otherwise safe condition for subsequent use. The length of time rubber insulating equipment can be "stored" on trucks will depend on the adverse environmental conditions to which the equipment is exposed. Under some circumstances, electrical personal protective equipment may have to be stored in climatically controlled conditions indoors during prolonged periods when employees would not be using it. Workers are dependent upon electrical personal protective equipment for their safety and all reasonable means of protecting this equipment from unnecessary damage must be employed.

We appreciate your interest in Occupational Safety and Health Administration programs. If we can be of further assistance, please contact [the Office of General Industry Compliance Assistance at (202) 693-1850].


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