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.

August 27, 2012

Mr. Emory M. Thomas
150 Cape Road
Hueytown, Alabama 35023

Dear Mr. Thomas:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry and Agricultural Enforcement (OGIAE) for an answer to your question regarding the potential requirement of two people working together while climbing telecommunication poles in a semi-remote location. This constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Scenario: Per your letter, you work for a company that provides internet, telephone, and cable TV service. As such, for the last 38 years, climbing poles has been a mandatory part of your job. Furthermore, you have taken your company's required pole climbing training course. Therefore, your letter implies you are a qualified climber or in the case of 29 CFR 1910.268(s)(33),"a qualified employee who by reason of his training and experience has demonstrated his ability to safely perform his duties."

Question: While climbing poles in remote or semi-remote areas, does OSHA have a requirement to have at least two workers on site?

Response: There is no OSHA requirement to have two workers on site, however OSHA requires employers to provide a safe and healthful workplace. Therefore, your employer must insure safety belts and straps are provided and used when work is performed at positions more than four feet above ground on poles. Furthermore, your employer shall provide training in the various precautions and safe practices described in paragraphs 1910.268(c)(1) through (c)(3). The requirement to provide training allows employers to evaluate their own worksites and job tasks and determine for themselves, using reason and prudence, what training is necessary. OSHA is aware that the nature of telecommunications work presents a wide variety of work locations, schedules, and work crew configurations.

For example, a crew working in a remote location may need to be trained, according to 1910.268(c)(1), in handling encounters with animal life or self-rescue if working alone, whereas a crew working in an densely populated urban area may not need the same training.

As with paragraph 1910.268(c)(1), paragraphs 1910.268(c)(2) and 1910.268(c)(3) also require training where the employer determines it is appropriate. The decision as to whether all employees covered by 29 CFR 1910.268 need to be trained in first aid and cardio-pulmonary resuscitation (CPR) would be made by the employer after assessing a variety of factors. As such, the employer is responsible for evaluating work locations, job functions, and potential hazards present. The employer must then determine what training content and method are most appropriate based upon the most reasonable possibility for employee injury. The flexibility in the language of the standard allows employers to design their training program to their own particular needs and to the anticipated hazards of the work.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs