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 9, 2000

Mr. Jerry A. Stephens
Manager, Safety & Occupational Health
Tri-State Generation and Transmission Association, Inc.
P.O. Box 33695
Denver, CO 80233-0695

Dear Mr. Stephens:

Thank you for your January 10, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. Please be aware that this response may not be applicable to any work crew scenario not delineated within your original correspondence. You had specific questions regarding the independent work crew requirements of the Electrical Power Generation, Transmission, and Distribution Standard, 29 CFR 1910.269. Your concern, scenario, questions, and our replies follow:

Concern: You are concerned about the definition of "independent crews" and the need for each independent crew to have a clearance.

Scenario: Your work practices often involve three and four "man" crews, totaling 9 to 21 linemen, from three different states working as a unit to assure that there are adequate numbers available for the work and emergency actions, if necessary. The foreman in the area where the work is being performed supervises these crews at the foreman level.

A crew member will hold the clearance issued to him by your centralized dispatch facility after all the switching is done, tags are hung and locks are in place and the line is de-energized. When the line is de-energized, this clearance holder, "employee-in-charge," will hold a job briefing and complete the job briefing form. All involved employees sign this form and understand the boundaries of the clearance. The workers test the conductors to assure that they are de-energized, grounds are attached and then and only then may the work proceed.

If the work is such that all activities will take place at a single location, there is no question. However, typically there is work performed at several locations along these lines by different members of this group of workers. This work may involve separation of a distance between two or three structures where visual contact is possible. Several miles may also separate the work. In this case, voice contact can be provided reliably by your "system" radios.

Question 1: At what point do we no longer have a single crew working on this single transmission line which may be as much as 100 miles long and instead have independent crews needing a separate clearance as required by 29 CFR 1910.269(m)(3)(iii)?

Reply: Paragraph 1910.269(m)(3)(viii) requires each independent crew to follow steps outlined in §1910.269(m)(3) separately to ensure that a group of workers does not make faulty assumptions about what steps to de-energize lines or equipment have been or will be taken by another group. The preamble summary and explanation section to this rule (Federal Register, 59(20), Monday, January 31, 1994, p. 4391.) contains the following paragraph (m)(3)(iii) discussion on multiple crews:

Additionally, this paragraph does not apply to work performed by two crews working on lines or equipment controlled by the same disconnecting means. (A group of employees made up of several 'crews' of employees who are under the direction of a single employee and who are working in a coordinated manner to accomplish a task on the same lines or equipment are considered to be a single crew, rather than as multiple independent crews...)

Therefore, for purposes of paragraph 1910.269(m), workplace scenarios with two or more crews that do not meet this test are independent crews. The employee in charge of the single crew must have sole control of the work and must coordinate the activities of all employees involved in the job. In addition, the employee in charge must be responsible for the clearance for the entire job and must be the only person communicating with the system operator, unless responsibility has been transferred under §1910.269(m)(3)(ix). The procedures must include effective visual or verbal (e.g., radio) communications with all crew members. In addition, the employee in charge, in accordance with §1910.269(c), must conduct a single job briefing with all the employees involved before they start the job.

Question 2: Are the crews "independent" when separated by the span of two or three structures or only if they are separated by several miles? If the latter, how many miles?

Reply: As described above, whether multiple crews are "independent crews" is not based primarily on the distance between workers.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that the enforcement guidance contained in the response represents the views of OSHA at the time the letter was written based on the facts of an individual case, question, or scenario and is subject to periodic review and clarification, amplification, or correction. It could also be affected by subsequent rulemaking; past interpretations may no longer be applicable. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]



1 Paragraph 1910.269(m)(2)(i) requires that all of the provisions of (m)(3) apply when a system operator, or a centralized dispatcher in this case, is in charge of the lines and equipment and of their means of disconnection. The information provided above is insufficient to determine whether all of the procedural steps are performed as required by this standard; the employer has the responsibility for determining compliance with OSHA regulations. OSHA does not endorse, or approve, any employer analyses, procedures or products. [ Back to text ]