- Standard Number:
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.
April 26, 1999
|MEMORANDUM FOR:||MICHAEL CONNERS
Director, Directorate of Compliance Programs
|SUBJECT:||Request for Interpretation of OSHA Standard 29 CFR 1910.269|
In response to your memorandum of February 18, 1999, with reference to the line-clearance tree-trimming work by Wright Tree Service, Inc. (Wright), the following interpretation of the applicable Occupational Safety and Health Administration (OSHA) Standard is submitted.
The provisions of the OSHA Standard 29 CFR 1910.269 applicable to line-clearance tree-trimming operations are as follows:
- Entire Section 1910.269, except paragraph (r)(1), applies to line-clearance tree-trimming operations performed by qualified employees (those who are knowledgeable in the construction and operation of electric power generation, transmission, or distribution equipment involved, along with the associated hazards). These employees typically perform tree-trimming duties as an incidental part of their normal work activities.
- Paragraphs 1910.269(a)(2), 1910.269(b), 1910.269(c), 1910.269(g), 1910.269(k), 1910.269(p), and 1910.269(r) of this section apply to line-clearance tree-trimming operations performed by line-clearance tree-trimmers who are not qualified employees. OSHA has adopted special electrical safety-related work practice provisions for line-clearance tree trimmers that are more stringent than those that apply to qualified employees. These provisions are contained in paragraph 1910.269(r)(1) and include certain minimum approach distances. Paragraphs 1910.269(a)(2), 1910.269(b), 1910.269(c), 1910.269(g), 1910.269(k), and 1910.269(p), are general requirements addressing training, medical services and first aid, job briefing, personal protective equipment, material handling, and mechanical equipment, respectively; OSHA has determined that the requirements in these areas are necessary and appropriate for all persons performing line-clearance tree-trimming work. The remaining provisions of section 1910.269 are not necessary for the safety of line-clearance tree-trimmers who are not qualified employees and are not related to the type of work they perform.
We note that Wright's "employees will work closer to energized conductors than line clearance tree trimmers are allowed to be." At the same time, Wright states that their employees will only be trained in "the use of rubber gloves and sleeves in order to use a chain saw on trees that are in direct contact with energized conductors." if the employees from Wright will be performing work within the minimum approach distances established in paragraph 1910.269(r)(1)(iii), training them in the use of rubber gloves and sleeves alone will not satisfy the training requirements of Section 1910.269. The employees must be either (1) trained as qualified employees, or (2) must be "undergoing on-the-job training," have "demonstrated an ability to perform duties safely at [their] level of training," and be "under the direct supervision of a qualified [employee]."
Paragraph 1910.269(a)(2)(ii) lists the training requirements for qualified employees. Qualified employees must receive training and be competent in:
- The skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment;
- The skills and techniques necessary to determine the nominal voltage of exposed live parts;
- The minimum approach distances specified in this section corresponding to the voltages to which the qualified employee will be exposed; and
- The proper use of the special pre-cautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools for working on or near exposed energized parts of electric equipment.
This training is beyond that received by all employees (including line-clearance tree-trimmers who are not qualified employees) covered by Section 1910.269. At a minimum, all employees covered by Section 1910.269 must be trained in and be familiar with the safety-related work practices, safety procedures, and other safety requirements in Section 1910.269 that pertain to their respective job assignments. In addition, they must also be trained in and be familiar with any other safety practices that are not specifically addressed by Section 1910.269 but that are related to their work and are necessary for their safety. We refer Wright to paragraph (a)(2) of Section 1910.269 for a more complete discussion of the applicable training requirements.
We also note that Wright's employees will be asked to rope the energized conductors to keep them from "snapping back when the tension of a tree is released by its removal." Paragraph (r)(7) of Section 1910.269 lists certain requirements for ropes used by line-clearance tree-trimmers. These requirements include rope strength and size, rope inspection, and rope storage. We also refer Wright to ASTM standard F1701-96e1 Specification for Unused Polypropylene Rope with Special Electrical Properties which covers the requirements, sizes, construction tests, and procedures for unused polypropylene ropes for use by electrical utilities and related industries working on energized lines operating at voltages better than 1 kV.
if you have any questions, please contact [the Directorate of Enforcement Programs at (202) 693-1681].