Challenge Testing as a Substitute for Annual Refresher Training.

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.

November 27, 1995

MEMORANDUM FOR:     R. DAVIS LAYNE
                   Regional Administrator

FROM:               JOHN B. MILES, Director 
                   Directorate of Compliance Programs

SUBJECT:            Challenge Testing as a Substitute for Annual Refresher
                   Training

This is in response to your letter of April 10, forwarding Florida Power Corporation's request for comments regarding their tentative plans to initiate challenge testing as a substitute for mandatory annual refresher training.

Interpretation of the electric power generation, transmission, and distribution standard.

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.

December 7, 1995

Mr. David L. White
Business Representative
IBEW-Local Union No. Two
2131 59th Street
St. Louis, MO. 63110

Dear Mr. White:

This is in response to your December 9, 1994 letter and your April 12 follow-up letter requesting interpretation of the electric power generation, transmission, and distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding. Your questions and our replies follow.

Installation and Placement of temporary protective grounds

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.

December 7, 1995

Mr. Andrew J. Woodacre
Brotherhood of Utility Workers of New England, Inc.
New Bedford, Massachusetts

Dear Mr. Woodacre:

This is in response to your August 24 letter to Mr. John T. Phillips, Administrator of Region I in the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to this directorate for response. Please accept our apology for the delay in responding. Your question and our reply follow applicable information (provided in you letter) which is reiterated below.

Guidelines for the Enforcement of the Apparel Standard

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 10, 1995

 

 

Electric power generation, transmission, and distribution standard.

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.

March 26, 1996

Mr. Michael L. Harbaugh
President
S.A.L.C.O.M. Inc.
2717 Caronado
Great Bend, Kansas 67530

Dear Mr. Harbaugh:

This is in response to your January 20, 1995, letter requesting clarifications and interpretations of the electric power generation, transmission, and distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding.

An interpretation of the electric power generation standard

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.

February 19, 1997

Mr. Ladd G. Poor
Power Supply Safety Administrator
PACIFICORP
1407 West North Temple
Salt Lake City, Utah 84140

Dear Mr. Poor:

Clarification o-f the electric power generation, transmission, and distribution standard.

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 23, 1997

Mr. Gregory C. Bird
Clean Harbors Environmental Services, Inc.
32 Bask Road
Glenmont, NY 12077

Dear Mr. Bird:

Fall Protection in the power distribution industry

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

September 1, 1995

Mr. Lance Murray
Safety Representative
General Atomics
P.O. Box 85608
San Diego, California 92186-9784

Dear Mr. Murray:

Your letter addressed to Mr. James Foster, dated October 14, 1994, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standards addressing fall protection in the power distribution industry, (29 CFR 1910.269 and 29 CFR 1926.502) was forwarded to the Office of Construction and Maritime Compliance Assistance for response.

Clarification of the Electric Power Generation, Transmission and Distribution Standard.

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 29, 1995

Mr. Daryld Ray
Crow Aluminum Company of America
100 Riverview Tower 900 South Gay Street
Knoxville, TN 37902

Dear Mr. Crow:

Imposing an undue hardship on the working man who is trying to do his job by keeping the electricity on for America to enjoy.

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 21, 1995

The Honorable Robert E. Goodlatte
House of Representatives
114 North Central Avenue
Staunton, VA 24401

Dear Congressman Goodlatte: