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.

June 4, 1996

Mr. John D. Weagraff
Niagara Mohawk Power Corporation
300 Erie Boulevard West
Syracuse, New York 13202-4250

Dear Mr. Weagraff:

This is in response to your October 5, 1995, letter requesting interpretation of the electric power generation, transmission, and distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding. Your questions and our replies follow.

Question 1 :

Do paragraphs 1910.269(b)(1)(i) and (ii) require employees such as tree trimmers and line workers in the field or other non-fixed work locations to provide first aid and cardiopulmonary resuscitation (CPR) within four minutes and to be trained to be proficient in tree and pole top rescue within that time frame? If not, what would be an acceptable response time and proficiency criteria to provide first aid and CPR in non-fixed locations?


Under paragraph 1910.269(b)(1), first aid and CPR training is required as follows: for field crews, at least two trained employees, and for fixed work sites, enough trained employees to provide first aid and CPR within 4 minutes. OSHA intended that exposed employees be no more than 4 minutes from a CPR-trained person. As noted in the preamble of the Power Generation Standard Final rule, the 4 minute time frame was not intended as an absolute time limit for responding to an accident, nor did it account for delays in discovering the accident. (59 FR 4347, column 2) However, CPR must be given to an employee within 4 minutes after being injured by electric shock to be effective. After 4 minutes CPR has limited usefulness.

For non-fixed locations the standard requires persons trained in first aid and CPR to be available. Compliance with this requirement will be determined based on the following considerations:

1. Whether exposed employees are no more than 4 minutes from a first aid and CPR trained person;

2. Whether there are appropriate equipment and procedures to reach the injured employee who may be on a pole or otherwise difficult to rescue, and if necessary, to move to a safe location so that first aid and CPR can be given; and

3. Whether assigned personnel have been trained and have demonstrated proficiency in using the rescue equipment and procedures to climb the pole and effect the rescue even if it means going inside the minimum approach distance form an exposed, energized electric line.

Question 2:

In a generation facility using a tagout system with multiple controls, what provisions must be taken for testing and trouble shooting the equipment prior to operating? Must each tag be removed from each and every control device or can the tags remain in place while the test is being conducted?


Paragraph 1910.269(d)(8)(i) applies to testing and trouble shooting machines or equipment on which servicing and maintenance is being performed. As noted in the preamble, the standard does not require all lockout or tagout devices to be removed, only those attached to energy isolation devices that are to be changed from the "safe" or "off" position to the "on" position. (59 FR 4361, column 1)

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact the Office of Safety Compliance, Mr. Ronald Davies, telephone (202)219-8031, extension 110.


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