|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.
June 22, 1998
Mr. Robert R. Schaffer
Orange and Rockland
390 West Route 59
Spring Valley, NY 10977-5300
Dear Mr. Schaffer:
This is in response to your April 6 letter requesting interpretation of §1910.269 Electric power generation, transmission, and distribution. Please accept our apology for the delay in responding. Your procedure and question and our reply follow.
Stress Cone Work Protection Procedure
Question: Based on this procedure will we be in compliance?
- De-energize and isolate the stress cone system by lifting off the taps on the primary side of the cutouts/disconnects (high side). Pull off the elbows at the transformer/switch point, test, and ground. Include all systems new or existing.
- Pay close attention to comparing actual clearances between the closest points of the stress cone system and the work methods/equipment to be used to the energized lines with the minimum approach distances listed on the O & R Safety Manual (these are also the OSHA 29 CFR 1910.269 distances). Where there is the potential that the approach distances will be violated because of work methods and/or the equipment being used, then insulating barriers and/or cover up equipment will be utilized on the energized equipment to avoid contact or coming within the specified approach distances.
- By following steps 1 and 2 above, rubber insulating gloves and sleeves would not be required by the worker when working on the stress cone system. Note: Normal PPE in the form of hand protection to avoid hand injury will be used.
Reply: The information provided above is insufficient to determine whether an employer would be in compliance with all of the requirements under §1910.269 when his or her employee(s) follow the procedure above. However, the following comments apply and should provide you with the answer you seek.
Employees would not be required to use rubber insulating gloves (and sleeves) that meet §1910.137 when working on stress cones on cables deenergized in compliance with paragraph 1910.269(m) and grounded in compliance with paragraph 1910.269(n).
Please note the following additional considerations.
We appreciate your interest in employee safety and health. If we can be of further assistance, please contact the [Office of General Industry Enforcement at (202) 693-1850].
- An employee, who works on or nearby exposed energized lines or equipment, must be qualified and must use electrical protective equipment any time the work might bring him or her inside the minimum approach distance. It is anticipated that electrical protective equipment, including gloves and sleeves (see paragraph 1910.269(l)(2)(i)) and hotsticks, will be used to deenergize and reenergize lines and equipment. Applicable deenergizing requirements under paragraph 1910.269(m) must be followed. Paragraph 1910.269(m) requirements, in addition to isolating hazardous electrical energy sources, testing, and grounding are required. Paragraphs 1910.269(m)(3)(ix) through 1910.269(m)(3)(xiii) include the following requirements that are not addressed in your letter: transfer of clearance, release of clearance, and steps that must be taken before the lines or equipment are reenergized. Also, paragraph 1910.269(m)(3)(viii) covers two or more crews working on the same line or equipment.
- Paragraph 1910.269(n) applies to the grounding in step 1 of your procedure.
- Under paragraph 1910.269(c), a job briefing must be conducted with employees involved in stress cone work before they start each job and when significant changes, which might affect the safety of employees, occur during the course of the work. Job briefings must cover at least the following subjects: hazards associated with the job, work procedures involved, special precautions, energy source controls, and personal protective equipment requirements. Work procedures must comply with other applicable §1910.269 requirements, such as those contained in paragraph 1910.269(l), Working on or near exposed energized part.
John B. Miles, Jr., Director
Directorate of Compliance Programs