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.

August 6, 1996

Mr. Charles J. Kelly Edision Electric Institute 701 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2696

Dear Mr. Kelly:

This is in response to your June 14 letter requesting reconsideration of the reply to Question #2 in our December 7, 1995 letter to Mr. David L. White, business representative for Local Union No. Two of the International Brotherhood of Electrical Workers (IBEW) in St. Louis, Missouri. This question and our reply are reiterated below.

Question: In circumstances where a two-man crew is performing work at a level less than 600 volts (which according to the standard does not require a two-man crew), would the second employee, who may be directing traffic, providing security, or delivering materials, be required to be trained in pole-top rescue and to be qualified as a climber?

Reply: Paragraph 1910.269(a)(2)(i) requires employees to be trained in emergency procedures related to their work and necessary for their safety. An employee must be trained and must demonstrate proficiency in pole-top rescue, including getting to the injured employee, when the work being performed is expected to include the need for pole-top rescue. If pole-top rescue is not needed, as may be the case in the circumstances you describe in your question, the second employee will not have to be trained in pole-top rescue or be qualified as a climber. However, the employee on the ground must be trained and assigned the duty of taking timely action to obtain rescue assistance for the employee working on the pole, and, of course, would still have to be trained in cardio-pulmonary resuscitation as required by paragraph 1910.269(b)(1)(i).

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


Raymond E. Donnelly, Director Office of Safety Compliance Assistance