Electric Power Generation, Transmission, and Distribution; Electrical Protective Equipment, 20315-20743 [2013-29579]
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Vol. 79
Friday,
No. 70
April 11, 2014
Part II
Department of Labor
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Occupational Safety and Health Administration
29 CFR Parts 1910 and 1926
Electric Power Generation, Transmission, and Distribution; Electrical
Protective Equipment; Final Rule
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Federal Register / Vol. 79, No. 70 / Friday, April 11, 2014 / Rules and Regulations
DEPARTMENT OF LABOR
Occupational Safety and Health
Administration
29 CFR Parts 1910 and 1926
[Docket No. OSHA–S215–2006–0063]
RIN 1218–AB67
Electric Power Generation,
Transmission, and Distribution;
Electrical Protective Equipment
Occupational Safety and Health
Administration (OSHA), Labor.
ACTION: Final rule.
AGENCY:
OSHA last issued rules for the
construction of transmission and
distribution installations in 1972. Those
provisions are now out of date and
inconsistent with the more recently
promulgated general industry standard
covering the operation and maintenance
of electric power generation,
transmission, and distribution lines and
equipment. OSHA is revising the
construction standard to make it more
consistent with the general industry
standard and is making some revisions
to both the construction and general
industry requirements. The final rules
for general industry and construction
include new or revised provisions on
host employers and contractors,
training, job briefings, fall protection,
insulation and working position of
employees working on or near live
parts, minimum approach distances,
protection from electric arcs,
deenergizing transmission and
distribution lines and equipment,
protective grounding, operating
mechanical equipment near overhead
power lines, and working in manholes
and vaults. The revised standards will
ensure that employers, when
appropriate, must meet consistent
requirements for work performed under
the construction and general industry
standards.
The final rule also revises the general
industry and construction standards for
electrical protective equipment. The
existing construction standard for the
design of electrical protective
equipment, which applies only to
electric power transmission and
distribution work, adopts several
national consensus standards by
reference. The new standard for
electrical protective equipment, which
matches the corresponding general
industry standard, applies to all
construction work and replaces the
incorporation of out-of-date consensus
standards with a set of performanceoriented requirements that is consistent
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SUMMARY:
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with the latest revisions of the relevant
consensus standards. The final
construction rule also includes new
requirements for the safe use and care
of electrical protective equipment to
complement the equipment design
provisions. Both the general industry
and construction standards for electrical
protective equipment will include new
requirements for equipment made of
materials other than rubber.
OSHA is also revising the general
industry standard for foot protection.
This standard applies to employers
performing work on electric power
generation, transmission, and
distribution installations, as well as
employers in other industries. The final
rule removes the requirement for
employees to wear protective footwear
as protection against electric shock.
DATES: The final rule becomes effective
on July 10, 2014. (Certain provisions
have compliance deadlines after this
date as explained later in this
preamble.)
ADDRESSES: In accordance with 28
U.S.C. 2112(a), the Agency designates
the Associate Solicitor of Labor for
Occupational Safety and Health, Office
of the Solicitor of Labor, Room S4004,
U.S. Department of Labor, 200
Constitution Avenue NW., Washington,
DC 20210, to receive petitions for
review of the final rule.
FOR FURTHER INFORMATION CONTACT:
General information and press
inquiries: Mr. Frank Meilinger, Office of
Communications, Room N3647, OSHA,
U.S. Department of Labor, 200
Constitution Avenue NW., Washington,
DC 20210; telephone (202) 693–1999.
Technical information: Mr. David
Wallis, Directorate of Standards and
Guidance, Room N3718, OSHA, U.S.
Department of Labor, 200 Constitution
Avenue NW., Washington, DC 20210;
telephone (202) 693–1950 or fax (202)
693–1678.
For additional copies of this Federal
Register document, contact OSHA,
Office of Publications, U.S. Department
of Labor, Room N3101, 200 Constitution
Avenue NW., Washington, DC 20210;
telephone (202) 693–1888. Electronic
copies of this Federal Register
document are available at https://
www.regulations.gov. Electronic copies
of this Federal Register document, as
well as news releases and other relevant
documents, are available at OSHA’s
Web page at https://www.osha.gov.
SUPPLEMENTARY INFORMATION:
Executive Summary
Table of Contents
I. Executive Summary
A. Introduction
B. Need for Regulation
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C. Affected Establishments
D. Benefits, Net Benefits, and Cost
Effectiveness
E. Cost Effectiveness
F. Compliance Costs
G. Economic Impacts
H. Final Regulatory Flexibility Analysis
II. Background
A. Acronyms and Abbreviations
B. Need for the Rule
C. Accident Data
D. Significant Risk and Reduction in Risk
III. Development of the Final Rule
A. History of the OSHA Standards
B. Relevant Consensus Standards
C. Advisory Committee on Construction
Safety and Health
IV. Legal Authority
V. Summary and Explanation of the Final
Rule
A. Section 1926.97, Electrical Protective
Equipment
B. Subpart V, Electric Power Transmission
and Distribution
C. Part 1910, Revisions
D. Part 1926, Removal of Incorporations by
Reference
E. Part 1926, Subpart CC Revisions
VI. Final Economic Analysis and Regulatory
Flexibility Analysis
A. Introduction
B. Need for the Rule
C. Examination of Alternative Regulatory
Approaches
D. Profile of Affected Industries
E. Benefits, Net Benefits, and Cost
Effectiveness
F. Technological Feasibility
G. Costs of Compliance
H. Final Regulatory Flexibility Analysis
I. References
VII. Federalism
VIII. Unfunded Mandates
IX. Consultation and Coordination With
Indian Tribal Governments
X. Office of Management and Budget Review
Under the Paperwork Reduction Act of
1995
A. Information Collection Request for the
Proposed Rule
B. Information Collection Requirements in
the Final Rule
XI. State-Plan Requirements
XII. Dates
A. The New Requirements for Transferring
Information Between Host Employers
and Contract Employers (§§ 1926.950(c)
and 1910.269(a)(3))
B. Revised Provisions on the Use of Fall
Protection Systems (§§ 1926.954(b)(3)(iii)
and (b)(3)(iv) and 1910.269(g)(2)(iv)(C),
and (g)(2)(iv)(D))
C. Revised Requirements for Minimum
Approach Distances (§§ 1926.960(c)(1)
and 1910.269(l)(3))
D. New Requirements for Protecting
Employees From the Hazards Associated
with Electric Arcs (§§ 1926.960(g) and
1910.269(l)(8))
XIII. Authority and Signature
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A. Introduction
OSHA last issued rules for the
construction of transmission and
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Federal Register / Vol. 79, No. 70 / Friday, April 11, 2014 / Rules and Regulations
distribution installations in 1972. Those
provisions are now out of date and
inconsistent with the more recently
promulgated general industry standard
covering the operation and maintenance
of electric power generation,
transmission, and distribution lines and
equipment. OSHA is revising the
construction standard to make it more
consistent with the general industry
standard and is making some revisions
to both the construction and general
industry requirements. The final rules
for general industry and construction
include new or revised provisions on
host employers and contractors,
training, job briefings, fall protection,
insulation and working position of
employees working on or near live
parts, minimum approach distances,
protection from electric arcs,
deenergizing transmission and
distribution lines and equipment,
protective grounding, operating
mechanical equipment near overhead
power lines, and working in manholes
and vaults. The revised standards will
ensure that employers, when
appropriate, must meet consistent
requirements for work performed under
the construction and general industry
standards.
The new provisions on host
employers and contractors include
requirements for host employers and
contract employers to exchange
information on hazards and on the
conditions, characteristics, design, and
operation of the host employer’s
installation. These new provisions also
include a requirement for host
employers and contract employers to
coordinate their work rules and
procedures to protect all employees.
The revised provisions on training add
requirements for the degree of training
to be determined by the risk to the
employee for the hazard involved and
for training line-clearance tree trimmers
and remove the existing requirement for
the employer to certify training. The
revised requirements for job briefings
include a new requirement for the
employer to provide information about
existing characteristics and conditions
to the employee in charge. The revised
fall protection provisions include new
requirements for the use of fall restraint
systems or personal fall arrest systems
in aerial lifts and for the use of fall
protection equipment by qualified
employees climbing or changing
location on poles, towers, or similar
structures. The revised provisions on
insulation and working position of
employees working on or near live parts
include new requirements relating to
where an employee who is not using
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electrical protective equipment may
work. The revised provisions on
minimum approach distances include a
new requirement for the employer to
determine maximum anticipated perunit transient overvoltages through an
engineering analysis or, as an
alternative, assume certain maximum
anticipated per-unit transient
overvoltages. These provisions also
replace requirements for specified
minimum approach distances with
requirements for the employer to
establish minimum approach distances
using specified formulas. The new
provisions for protection from electric
arcs include new requirements for the
employer to: Assess the workplace to
identify employees exposed to hazards
from flames or from electric arcs, make
reasonable estimates of the incident heat
energy to which the employee would be
exposed, ensure that the outer layer of
clothing worn by employees is flame
resistant under certain conditions, and
generally ensure that employees
exposed to hazards from electric arcs
wear protective clothing and other
protective equipment with an arc rating
greater than or equal to the estimated
heat energy. The revised provisions on
deenergizing transmission and
distribution lines and equipment clarify
the application of those provisions to
multiple crews and to deenergizing
network protectors. The revised
requirements for protective grounding
now permit employers to install and
remove protective grounds on lines and
equipment operating at 600 volts or less
without using a live-line tool under
certain conditions. The revised
provisions for operating mechanical
equipment near overhead power lines
clarify that the exemption from the
requirement to maintain minimum
approach distances applies only to the
insulated portions of aerial lifts. The
revised provisions on working in
manholes and vaults clarify that all of
the provisions for working in manholes
also apply to working in vaults and
include a new requirement for
protecting employees from electrical
faults when work could cause a fault in
a cable.
The final rule also revises the general
industry and construction standards for
electrical protective equipment. The
existing construction standard for the
design of electrical protective
equipment, which applies only to
electric power transmission and
distribution work, adopts several
national consensus standards by
reference. The new standard for
electrical protective equipment applies
to all construction work and replaces
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the incorporation of out-of-date
consensus standards with a set of
performance-oriented requirements that
is consistent with the latest revisions of
the relevant consensus standards. The
final construction rule also includes
new requirements for the safe use and
care of electrical protective equipment
to complement the equipment design
provisions. Both the general industry
and construction standards for electrical
protective equipment will include new
requirements for equipment made of
materials other than rubber.
OSHA is also revising the general
industry standard for foot protection.
This standard applies to employers
performing work on electric power
generation, transmission, and
distribution installations, as well as
employers in other industries. The final
rule removes the requirement for
employees to wear protective footwear
as protection against electric shock.
B. Need for Regulation
Employees doing work covered by the
final rule are exposed to a variety of
significant hazards that can and do
cause serious injury and death. As
explained fully in Section II.B, Need for
the Rule, later in this preamble, after
carefully weighing the various potential
advantages and disadvantages of using a
regulatory approach to reduce risk,
OSHA concludes that in this case
mandatory standards represent the best
choice for reducing the risks to
employees. In addition, rulemaking is
necessary in this case to replace older
existing standards with updated, clear,
and consistent safety standards.
Inconsistencies between the
construction and general industry
standards can create difficulties for
employers attempting to develop
appropriate work practices for their
employees. For example, an employer
replacing a switch on a transmission
and distribution system is performing
construction work if it is upgrading the
cutout, but general industry work if it is
simply replacing the cutout with the
same model. Under the existing
standards, different requirements apply
depending upon whether the work is
construction or general industry work.
Under the final rule, the requirements
are the same.
C. Affected Establishments
The final rule affects establishments
in a variety of different industries
involving electric power generation,
transmission, and distribution. The rule
primarily affects firms that construct,
operate, maintain, or repair electric
power generation, transmission, or
distribution installations. These firms
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include electric utilities, as well as
contractors hired by utilities and
primarily classified in the construction
industry. In addition, potentially
affected firms are found in a variety of
manufacturing and other industries that
own or operate their own electric power
generation, transmission, or distribution
installations as a secondary part of their
business operations. The rule also
affects establishments performing lineclearance tree-trimming operations.
D. Benefits, Net Benefits, and Cost
Effectiveness
OSHA expects the final rule to result
in an increased degree of safety for the
affected employees, thereby reducing
the numbers of accidents, fatalities, and
injuries associated with the relevant
tasks and reducing the severity of
certain injuries, such as burns or
injuries that employees could sustain as
a result of an arrested fall, that may still
occur during the performance of some of
the affected work procedures.
An estimated 74 fatalities and 444
serious injuries occur annually among
employees involved in the electric
power generation, transmission, and
distribution work addressed by the
provisions of this rulemaking. Based on
a review and analysis of the incident
reports associated with the reported
injuries and fatalities, OSHA expects
full compliance with the final rule to
prevent 79.6 percent of the relevant
injuries and fatalities, compared with
52.9 percent prevented with full
compliance with the existing standards.
Thus, OSHA estimates that the final rule
will prevent approximately 19.75
additional fatalities and 118.5
additional serious injuries annually.
Applying an average monetary value of
$62,000 per prevented injury and a
value of $8.7 million per prevented
fatality results in estimated monetized
benefits of $179.2 million annually.
OSHA estimated the net monetized
benefits of the final rule to be about
$129.7 million annually when costs are
annualized at 7 percent ($179.2 million
in benefits minus $49.5 million in
costs), and $132.0 million when costs
are annualized at 3 percent ($179.2
million in benefits minus $47.1 million
in costs). Note that these net benefits
exclude any unquantified benefits
associated with revising existing
standards to provide updated, clear, and
consistent regulatory requirements for
electric power generation, transmission,
and distribution work. OSHA believes
that the updated standards are easier to
understand and to apply. Accordingly,
the Agency expects the final rule to
improve safety by facilitating
compliance.
Table 1 summarizes the costs,
benefits, net benefits, and cost
effectiveness of the final rule.
TABLE 1—NET BENEFITS AND COST EFFECTIVENESS *
7 percent
Annualized Costs:
Calculating Incident Energy and Arc-Hazard Assessment (ArcHazard Assessment).
Provision of Arc-Flash Protective Equipment ..................................
Fall Protection ..................................................................................
Host-Contractor Communications ....................................................
Expanded Job Briefings ...................................................................
Additional Training ...........................................................................
Other costs for employees not already covered by § 1910.269 ......
MAD Costs .......................................................................................
Total Annual Costs ...................................................................
Annual Benefits:
Number of Injuries Prevented ..........................................................
Number of Fatalities Prevented .......................................................
Monetized Benefits (Assuming $62,000 per injury and $8.7 million
per fatality prevented.
OSHA standards that are updated and consistent ..........................
Total Annual Benefits ................................................................
Net Benefits (Benefits minus Costs): ......................................................
3 percent
$2.2 million ....................................
$1.8 million.
$17.3 million ..................................
$0.6 million ....................................
$17.8 million ..................................
$6.7 million ....................................
$3.0 million ....................................
$0.2 million ....................................
$1.8 million ....................................
$49.5 million ..................................
$15.7 million.
$0.4 million.
$17.8 million.
$6.7 million.
$2.7 million.
$0.2 million.
$1.8 million.
$47.1 million.
118.5 ..............................................
19.75 ..............................................
$179.2 million ................................
118.5.
19.75.
$179.2 million.
Unquantified ...................................
118.5 injuries and 19.75 fatalities
prevented.
$129.7 million ................................
Unquantified.
118.5 injuries and 19.75 fatalities
prevented.
$132.0 million.
* Totals may not equal the sum of the components due to rounding.
Source: Office of Regulatory Analysis, OSHA. Details provided in text.
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E. Cost Effectiveness
OSHA estimates that compliance with
the final rule will result in the
prevention of an one fatality and six
injuries per $2.4 million in costs (using
a 7-percent annualization rate) and one
fatality and six injuries per $2.2 million
in costs (using a 3-percent annualization
rate).
F. Compliance Costs
The estimated costs of compliance
with this rule represent the additional
costs necessary for employers to achieve
full compliance. They do not include
costs for employers that are already in
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compliance with the new requirements
imposed by the final rule; nor do they
include costs employers must incur to
achieve full compliance with existing
applicable requirements.
OSHA based the Preliminary
Regulatory Impact Analysis and Initial
Regulatory Flexibility Analysis (PRIA)
for the proposed rule, in part, on a
report prepared by CONSAD Corp.
(Exhibit 0080) under contract to OSHA.
Eastern Research Group, Inc., (ERG)
under contract to OSHA, assisted in
preparing the analysis of the final rule
presented here. With ERG’s assistance,
OSHA updated data on establishments,
employment, wages, and revenues, and
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updated the analyses in the final rule
with these new cost inputs. OSHA also
calculated costs for provisions of the
final rule not accounted for in the PRIA.
These costs are for the use of upgraded
fall protection equipment resulting from
revised fall protection requirements, the
provision of arc-rated head and face
protection for some employees, the
training of employees in the use of new
fall protection equipment, the
calculation of minimum approach
distances, and, in some cases, the use of
portable protective gaps (PPGs) to
comply with the new minimum
approach-distance requirements. The
FEA also modifies the PRIA’s approach
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to estimating costs for arc-hazard
assessments.
OSHA estimated the total annualized
cost of compliance with the present
rulemaking to be between about $47.1
million (when costs are annualized at 3
percent) and $49.5 million (when costs
are annualized at 7 percent). The final
rule’s requirements for employers to
provide arc-flash protective equipment
account for the largest component of the
total compliance costs, at approximately
$15.7 million to $17.2 million (when
costs are annualized at 3 and 7 percent,
respectively). Other nonnegligible
compliance costs associated with the
final rule include costs related to hostcontractor communications ($17.8
million), job briefings ($6.7 million),
training ($2.7 million to $3.0 million),
minimum approach distances ($1.8
million to $1.8 million), fall protection
($0.4 million to $0.6 million),
compliance with existing § 1910.269 for
employees not already covered by that
standard ($0.2 million), and arc-hazard
assessments ($1.8 million to $2.2
million).
G. Economic Impacts
To assess the economic impacts
associated with compliance with the
final rule, OSHA developed quantitative
estimates of the potential economic
impact of the requirements in this rule
on entities in each affected industry.
OSHA compared the estimated costs of
compliance with industry revenues and
profits to provide an assessment of
potential economic impacts.
The costs of compliance for the final
rule are not large in relation to the
corresponding annual financial flows
associated with the regulated activities.
The estimated costs of compliance
(when annualized at 7 percent)
represent about 0.007 percent of
revenues and 0.06 percent of profits, on
average, across all entities; compliance
costs do not represent more than 0.1
percent of revenues or more than about
2 percent of profits in any affected
industry.
The economic impact of the present
rulemaking is most likely to consist of
a small increase in prices for electricity,
of about 0.007 percent on average. It is
unlikely that a price increase on the
magnitude of 0.007 percent will
significantly alter the services
demanded by the public or any other
affected customers or intermediaries. If
employers can substantially recoup the
compliance costs of the present
rulemaking with such a minimal
increase in prices, there may be little
effect on profits.
In general, for most establishments, it
is likely that employers can pass some
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or all of the compliance costs along in
the form of increased prices. In the
event that unusual circumstances may
inhibit even a price increase of 0.1
percent (the highest estimated cost as a
percent of revenue in any of the affected
industries), profits in any of the affected
industries would be reduced by a
maximum of about 2 percent.
OSHA concludes that compliance
with the requirements of the final rule
is economically feasible in every
affected industry sector.
In addition, based on an analysis of
the costs and economic impacts
associated with this rulemaking, OSHA
concludes that the effects of the final
rule on international trade,
employment, wages, and economic
growth for the United States are
negligible.
H. Final Regulatory Flexibility Analysis
The Regulatory Flexibility Act, as
amended in 1996 by the Small Business
Regulatory Enforcement Fairness Act,
requires the preparation of a Final
Regulatory Flexibility Analysis for
certain rules promulgated by agencies (5
U.S.C. 601–612). Under the provisions
of the law, each such analysis must
contain: (1) A succinct statement of the
need for, and objectives of, the rule; (2)
A summary of the significant issues
raised by the public comments in
response to the initial regulatory
flexibility analysis, a summary of the
assessment of the agency of such issues,
and a statement of any changes made in
the final rule as a result of such
comments; (3) a description and an
estimate of the number of small entities
to which the rule will apply or an
explanation of why no such estimate is
available; (4) a description of the
projected reporting, recordkeeping, and
other compliance requirements of the
rule, including an estimate of the classes
of small entities that will be subject to
the requirement, and the type of
professional skills necessary for
preparation of the report or record; and
(5) a description of the steps the agency
took to minimize the significant
economic impact on small entities
consistent with the stated objectives of
applicable statutes, including a
statement of the factual, policy, and
legal reasons for selecting the alternative
adopted in the final rule, and why the
agency rejected each one of the other
significant alternatives to the rule
considered by the agency which affect
the impact on small entities.
OSHA analyzed the potential impact
of the final rule on small and very small
entities, as described further under the
heading ‘‘Final Regulatory Flexibility
Analysis,’’ in Section VI, Final
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Economic Analysis and Regulatory
Flexibility Analysis, later in this
preamble. OSHA concludes that the
compliance costs are equivalent to
approximately 0.086 percent of profits
for affected small entities generally, and
less than approximately 2.9 percent of
profits for small entities in any
particular industry, and approximately
0.39 percent of profits for affected very
small entities generally, and less than
approximately 5.61 percent of profits for
very small entities in any particular
industry.
II. Background
A. Acronyms and Abbreviations
The following acronyms have been
used throughout this document:
ACCSH Advisory Committee on
Construction Safety and Health
AED automated external defibrillator
AGC Associated General Contractors of
America
ALJ administrative law judge
ANSI American National Standards
Institute
APPA American Public Power Association
ASTM American Society for Testing and
Materials
BLS Bureau of Labor Statistics
BPA Bonneville Power Administration
CFOI Census of Fatal Occupational Injuries
CPL 02–01–038 the compliance directive
for existing § 1910.269, CPL 02–01–038,
‘‘Enforcement of the Electric Power
Generation, Transmission, and Distribution
Standard’’ (June 18, 2003, originally CPL
2–1.38D)
CPR cardiopulmonary resuscitation
CRIEPI Central Research Institute of Electric
Power Industry
EEI Edison Electric Institute
EIA Energy Information Administration
E.O. Executive Order
EPRI Electric Power Research Institute
ERG Eastern Research Group, Inc.
ESCI Electrical Safety Consultants
International
Ex. Exhibit 1
FCC Federal Communications Commission
FEA Final Economic Analysis and
Regulatory Flexibility Analysis
FR flame-resistant 2
1 Exhibits are posted on https://
www.regulations.gov and are accessible at OSHA’s
Docket Office, Docket No. OSHA–S215–2006–0063,
U.S. Department of Labor, 200 Constitution Avenue
NW., Room N2625, Washington, DC 20210;
telephone (202) 693–2350. (OSHA’s TTY number is
(877) 889–5627.) OSHA Docket Office hours of
operation are 8:15 a.m. to 4:45 p.m., E.T.
Throughout this notice exhibit numbers are
referred to in the form Ex. XXXX, where XXXX is
the last four digits of the full document number on
https://www.regulations.gov. For example, document
number OSHA–S215–2006–0063–0001 is referred
to as Ex. 0001. Exhibit numbers referred to as ‘‘269–
Ex.’’ are from the record for the 1994 final rule on
§§ 1910.137 and 1910.269 and are contained in
Docket Number OSHA–S015–2006–0645.
2 In citations, such as 70 FR 34822, ‘‘FR’’ means
‘‘Federal Register.’’
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FRA flame-resistant apparel
FRECC Farmers Rural Electric Cooperative
Corporation
FRFA Final Regulatory Flexibility Analysis
FTE full-time equivalent [employee]
IBEW International Brotherhood of
Electrical Workers
IEC International Electrotechnical
Commission
IEEE Institute of Electrical and Electronic
Engineers
IMIS OSHA’s Integrated Management
Information System
IRFA Initial Regulatory Flexibility Analysis
IRS Internal Revenue Service
ISEA International Safety Equipment
Association
MAD minimum approach distance
MAID minimum air-insulation distance
MCC motor control center
MTID minimum tool-insulation distance
NA not applicable
NAHB National Association of Home
Builders
NAICS North American Industry
Classification System
NAM National Association of
Manufacturers
NECA National Electrical Contractors
Association
NEPA National Environmental Policy Act
of 1969
NESC National Electrical Safety Code
NFPA National Fire Protection Association
NIOSH National Institute for Occupational
Safety and Health
NRECA National Rural Electric Cooperative
Association
OIRA Office of Information and Regulatory
Affairs
OMB Office of Management and Budget
OSH Act (or the Act) Occupational Safety
and Health Act of 1970
OSHA Occupational Safety and Health
Administration
OSHRC Occupational Safety and Health
Review Commission
PPE personal protective equipment
PPG portable protective gap
PRIA Preliminary Regulatory Impact
Analysis and Initial Regulatory Flexibility
Analysis
PSM process safety management
p.u. per unit
RIN regulatory information number
SBA Small Business Administration
SBAR Panel (or Panel) Small Business
Advocacy Review Panel
SBREFA Small Business Regulatory
Enforcement Fairness Act
SER small entity representative
SIC Standard Industrial Classification
T maximum transient overvoltage, which is
defined as the ratio of the 2-percent
statistical switching overvoltage expected
at the worksite to the nominal peak lineto-ground voltage of the system
TCIA Tree Care Industry Association
the 1994 § 1910.269 rulemaking the
rulemaking in which existing §§ 1910.137
and § 1910.269 were developed and
published on January 31, 1994
Tr. Transcript page number or numbers
from the March 6–14, 2006, public hearing
on the proposed rule 3
3 Exhibit
numbers 0509 through 0515.
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Tr2. Transcript page number or numbers
from the October 28, 2009, public hearing
on the limited reopening of the proposed
rule 4
TVA Tennessee Valley Authority
ULCC Utility Line Clearance Coalition
USDA United States Department of
Agriculture
UWUA Utility Workers Union of America
WCRI Worker Compensation Research
Institute
Record citations. References in
parentheses are to exhibits or transcripts
in the rulemaking record. Documents
from the Subpart V rulemaking record
are accessible at the Docket Office under
Docket OSHA–S215–2006–0063
(originally Docket S–215). (The 2006
transcripts, abbreviated as ‘‘Tr.,’’ are
listed in this docket as ‘‘exhibits’’ 0509
through 0515. The 2009 transcript,
abbreviated as ‘‘Tr2.,’’ is listed as
‘‘exhibit’’ 0571.) Because the subpart V
proposal was based in large part on
existing § 1910.269, OSHA has also
relied on the record developed during
the earlier rulemaking for that general
industry standard (the 1994 § 1910.269
rulemaking). EEI ‘‘incorporate[d] into
[the subpart V] record the entire record
in . . . the record underlying existing
Section 1910.269’’ (Ex. 0227).
References in this preamble that are
prefixed by ‘‘269’’ are to exhibits and
transcripts in the rulemaking record
from OSHA’s 1994 rulemaking on
§ 1910.137 and § 1910.269 (59 FR 4320–
4476, Jan. 31, 1994). These documents
are accessible at the Docket Office under
Docket OSHA–S015–2006–0645
(originally Docket S–015).5
Some exhibits (see, for example, Exs.
0002, 0003, 0004, and 0400) contain
records of accidents that are relevant to
work covered by the final rule. In
several instances in this preamble,
OSHA has included hyperlinks to
accident descriptions from those
exhibits. Those hyperlinks link to one or
more accident records in OSHA’s IMIS
system. The hyperlinked pages contain
the most recent version of those records,
which might have been edited since
being placed in the record for this
rulemaking. Consequently, the accident
descriptions could differ slightly from
the description included in the
rulemaking record. However, the
accident record numbers in the
4 Exhibit
number 0571.
in the records, with the exception of
copyrighted material such as ASTM standards, are
also generally available electronically at
www.regulations.gov. The subpart V and 1994
§ 1910.269 dockets are available at: https://
www.regulations.gov/#!docketDetail;
dct=FR+PR+N+O+SR+PS;rpp=250;po=0;D=OSHAS215-2006-0063 and https://www.regulations.gov/
#!docketDetail;dct=FR+PR+N+O+SR+PS
;rpp=250;po=0;D=OSHA-S015-2006-0645,
respectively.
5 Documents
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hyperlinked page match the accident
record numbers in the relevant exhibit.
B. Need for the Rule
Employees performing work involving
electric power generation, transmission,
and distribution are exposed to a variety
of hazards, including fall, electric shock,
and burn hazards, that can and do cause
serious injury and death. These workers
are often exposed to energized parts of
the power system, and the voltages
involved are generally much higher than
voltages encountered in other types of
work. OSHA estimates that, on average,
74 fatalities and 444 serious injuries
occur annually among these workers.
(See Section VI, Final Economic
Analysis and Regulatory Flexibility
Analysis, later in the preamble, for a
detailed discussion of the methodology
used to develop these estimates.)
Although some of these incidents may
have been prevented with better
compliance with existing safety
standards, OSHA concludes that many,
in fact almost half of, fatal and nonfatal
injuries among employees covered by
the final rule would continue to occur
even if employers were in full
compliance with existing standards.
Discounting incidents that would
potentially have been prevented with
compliance with existing standards, an
estimated additional 19.75 fatalities and
118.5 serious injuries will be prevented
each year through full compliance with
the final rule. (See Section VI, Final
Economic Analysis and Regulatory
Flexibility Analysis, later in the
preamble, for a detailed discussion of
the methodology used to develop these
estimates.)
This rulemaking will have the
additional benefit of providing updated,
clear, and consistent safety standards for
electric power generation, transmission,
and distribution work. OSHA currently
has different standards covering
construction and general industry work
on electric power transmission and
distribution systems. In most instances,
the work practices used by employees
are the same whether they are
performing construction or general
industry work. Which standard applies
to a particular job depends upon
whether the employer is altering the
system (construction work) or
maintaining the system (general
industry work). For example, an
employer replacing a cutout (disconnect
switch) on a transmission and
distribution system is performing
construction work if it is upgrading the
cutout, but general industry work if it is
simply replacing the cutout with the
same model. Since the work practices
used by the employees would most
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likely be identical, the applicable OSHA
standards should be as similar as
possible. Inconsistencies between the
construction and general industry
standards can create difficulties for
employers attempting to develop
appropriate work practices for their
employees. Currently, it is conceivable
that, for work involving two or more
cutouts, different and conflicting OSHA
standards (that is, one for construction
work, the other for general industry
work) might apply. For this reason,
employers and employees have told
OSHA that it should make the two
standards more consistent with each
other. This final rule does so. (This
issue is addressed in greater detail in
the summary and explanation for
§ 1926.950, in Section V, Summary and
Explanation of the Final Rule, later in
this preamble.)
Moreover, the final rule adds
important updates to, and clarifies,
existing standards. The existing
standards for the construction of electric
power transmission and distribution
lines and equipment and for electrical
protective equipment are contained in
subpart V of OSHA’s construction
standards (29 CFR 1926.950 through
1926.960). Subpart V was promulgated
on November 23, 1972, around 40 years
ago (37 FR 24880, Nov. 23, 1972). Some
of the technology involved in electric
power transmission and distribution
work has changed since then, and the
current standards do not reflect those
changes. For example, methods for
determining minimum approach
distances have become more exact since
1972, and the minimum approach
distances in existing § 1926.950(c)(1) are
not based on the latest methodology.
The minimum approach distances in the
final rule are more protective and more
technologically sound than the
distances specified in the existing
standard. Even the newer general
industry standards on the operation and
maintenance of electric power
generation, transmission, and
distribution installations (29 CFR
1910.269) and electrical protective
equipment (29 CFR 1910.137) are not
entirely consistent with the latest
advances in technology.
Finally, the final rule clarifies certain
confusing parts of the regulations. See,
for example, Wisconsin Elec. Power Co.
v. OSHRC, 567 F.2d 735, 738 (7th Cir.
1977) (‘‘[r]evision of the regulations by
any competent draftsman would greatly
improve their clarity’’).
C. Accident Data
OSHA has looked to several sources
for information on accidents in the
electric utility industry in preparing this
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final rule. Besides OSHA’s own accident
investigation files (recorded in the
Agency’s Integrated Management
Information System (IMIS)), statistics on
injuries are compiled by the Edison
Electric Institute (EEI) and by the
International Brotherhood of Electrical
Workers (IBEW). Additionally, the
Bureau of Labor Statistics (BLS)
publishes accident data, including
incidence rates for total cases, lostworkday cases, and lost workdays, and
the National Institute for Occupational
Safety and Health (NIOSH) publishes
accident data as part of its Fatality
Assessment and Control Evaluation
Program.
To develop estimates of the potential
benefits associated with the standards
during the proposal stage, CONSAD
Corp., under contract to OSHA,
researched and reviewed potential
sources of useful data. CONSAD, in
consultation with the Agency,
determined that the most reliable data
sources for this purpose were OSHA’s
IMIS data and the Census of Fatal
Occupational Injuries developed by
BLS. A majority of the accidents
reviewed by CONSAD involved
electrocutions or shocks. In addition, a
significant percentage of victims (5.5
percent) suffered from burns to their
arms, abdomen, or legs from electric arc
blasts and flashes, and another sizeable
group of victims (3.2 percent) died or
sustained injuries after falling out of
vehicle-mounted aerial lifts.6
D. Significant Risk and Reduction in
Risk
Section 3(8) of the Occupational
Safety and Health Act of 1970 (OSH Act
or the Act) defines an ‘‘occupational
safety and health standard’’ as ‘‘a
standard which requires conditions, or
the adoption or use of one or more
practices, means, methods, operations,
or processes, reasonably necessary or
appropriate to provide safe or healthful
employment and places of
employment.’’ 29 U.S.C. 652(8). This
definition has been interpreted to
require OSHA to make a threshold
showing of ‘‘significant risk’’ before it
can promulgate a safety or health
standard. See, for example, Industrial
Union Dept., AFL–CIO v. American
Petroleum Institute (Benzene), 448 U.S.
607 (1980) (plurality opinion); see also,
for example, UAW v. OSHA (Lockout/
Tagout II), 37 F.3d 665 (D.C. Cir. 1994).
6 ‘‘ Analytical Support and Data Gathering for a
Preliminary Economic Analysis for Proposed
Standards for Work on Electric Power Generation,
Transmission, and Distribution Lines and
Equipment (29 CFR 1910.269 and 29 CFR 1926—
Subpart V),’’ 2005, CONSAD Research Corp. (Ex.
0080).
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The Agency’s obligation to show
significant risk is not, however, a
‘‘mathematical straitjacket.’’ Benzene,
448 U.S. at 655. In fact, the Agency has
discretion to ‘‘determine, in the first
instance, what it considers to be a
‘significant’ risk[,]’’ and it ‘‘is not
required to support its finding that a
significant risk exists with anything
approaching scientific certainty.’’ Id. at
655–56; see also, for example, Public
Citizen Health Research Group v. Tyson
(Ethylene Oxide), 796 F.2d 1479, 1486
(D.C. Cir. 1986).
Although OSHA makes significant
risk findings for both health and safety
standards, see Lockout/Tagout II, 37
F.3d 665, the methodology used to
evaluate risk in safety rulemakings is
more straightforward. Unlike the risks
related to health hazards, which ‘‘may
not be evident until a worker has been
exposed for long periods of time to
particular substances,’’ the risks
associated with safety hazards such as
burns and falls, ‘‘are generally
immediate and obvious.’’ Benzene, 448
U.S. at 649, n.54. See also 59 FR 28594,
28599 (June 2, 1994) (proposed rule for
longshoring and marine terminals,
explaining that health hazards ‘‘are
frequently undetectable because they
are subtle or develop slowly or after
long latency periods,’’ whereas safety
hazards ‘‘cause immediately noticeable
physical harm’’). As OSHA explained in
its lockout-tagout rulemaking:
For health standards, such as benzene, risk
estimates are commonly based upon
mathematical models (e.g., dose response
curves) and the benefits are quantified by
estimating the number of future fatalities that
would be prevented under various exposure
reductions. [In contrast, f]or safety standards
risk is based upon the assumption that past
accident patterns are representative of future
ones. OSHA estimates benefits [for safety
standards] by determining the percentage of
accidents that will be prevented by
compliance with the standard. . . . [58 FR
16612, 16623, Mar. 30, 1993]
OSHA’s Final Economic and
Regulatory Flexibility Analysis presents
the Agency’s assessment of the risks and
benefits of this final rule. (See Section
VI, Final Economic Analysis and
Regulatory Flexibility Analysis, later in
the preamble.) In these analyses, as
previously mentioned, OSHA estimates
that there are 74 fatalities and 444
serious injuries among employees
covered by this final rule each year. The
Agency has determined that almost half
of those injuries and fatalities would
have occurred even if employers were in
full compliance with existing standards.
(See Section VI, Final Economic
Analysis and Regulatory Flexibility
Analysis, later in the preamble, in
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which OSHA estimates that 53 percent
of injuries and fatalities could have been
prevented through full compliance with
existing standards.) The accident data
reviewed during this rulemaking, as
explained in detail in the economic and
regulatory analyses, reveals that the
injuries and fatalities suffered by
workers in power generation,
transmission, and distribution result
from electric shocks, burns from electric
arcs, and falls, as well as other types of
harmful incidents, including ones in
which employees are struck by, struck
against, or caught between, objects.
Based on the large number of injuries
and fatalities occurring in this industry
each year, and the fact that existing
standards are inadequate to prevent
almost half of those incidents, OSHA
has determined that employees working
on electric power generation,
transmission, and distribution
installations are currently exposed to a
significant risk of injury or death.7
The Agency estimates that the
changes implemented in this final rule
will prevent 19.75 fatalities and 118.5
serious injuries each year. (See Section
VI, Final Economic Analysis and
Regulatory Flexibility Analysis, later in
the preamble.) OSHA, therefore,
concludes that this final standard
substantially reduces the significant risk
that currently exists at power
generation, transmission, and
distribution worksites. As noted in
Section VI, Final Economic Analysis
and Regulatory Flexibility Analysis,
later in the preamble, the various new
provisions and amendments being
adopted target the hazards the Agency
has identified as contributors to the
significant risk associated with electric
power generation, transmission, and
distribution work. Therefore, each
element of this final rule is reasonably
7 In industries in which worker exposure is less
frequent than in other industries, the number of
injuries or fatalities associated with the hazards
covered by the final rule will most likely be less
than that of industries that have a higher rate of
exposure. But even for industries with low,
negligible, or even no reported injuries or fatalities,
the workers exposed to the hazards covered by the
final rule face a ‘‘significant risk of material harm.’’
As such, there is a significant risk to any worker
of any industry exposed to the hazards covered by
the final rule. See, for example, Lockout/Tagout II,
37 F.3d at 670 (‘‘even in industries with low or
negligible overall accident rates, the workers who
engage in the operations covered by the standard
face a ‘significant risk of material harm’’’);
Associated Builders and Contractors, Inc. v. Brock,
862 F.2d 63, 67–68 (3d Cir. 1988) (where the Court
ordered OSHA to expand its rule to cover
additional industries, there was no need to make
separate significant risk findings for those
industries because ‘‘the significant risk requirement
must of necessity be satisfied by a general finding
concerning all potentially covered industries’’).
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necessary and appropriate to achieve
the anticipated reduction in overall risk.
No rulemaking participants
meaningfully disputed OSHA’s
conclusion that the aforementioned
estimates establish a significant risk for
power generation, transmission, and
distribution work. EEI, however, argued
that OSHA has an obligation to make an
independent significant risk showing for
each of the hazards addressed by this
rulemaking (See, for example, Exs. 0227,
0501; see also Ex. 0237 (comments of
the American Forest & Paper
Association).) OSHA does not agree that
it is required to make multiple, hazardspecific significant risk findings.
As OSHA has explained in prior
rulemakings, ‘‘[v]ertical standards [such
as § 1910.269 and subpart V of part
1926] apply specifically to a given
industry’’ or type of work (59 FR 28596
(proposed rule for longshoring and
marine terminals)). They generally
address multiple hazards faced by
employees performing the covered
work. See, for example, 66 FR 5196 (Jan.
18, 2001) (steel erection standards
address, among other hazards, risks
from working under loads, dangers
associated with landing and placing
decking, and falls to lower levels); 62 FR
40142 (July 25, 1997) (standards
covering longshoring and marine
terminals address multiple hazards,
including hazards associated with
manual cargo handling and exposure to
hazardous atmospheres); 52 FR 49592
(Dec. 31, 1987) (standard covering grainhandling facilities includes provisions
related to fire and explosion hazards, as
well as other safety hazards, such as the
danger associated with entering bins,
silos, and tanks). OSHA believes that
vertical ‘‘standards can encourage
voluntary compliance because they are
directed to the particular problems of
[an] industry’’ (59 FR 28596). The
adoption of vertical standards is
recognized as a legitimate exercise of
OSHA’s standard-setting authority
under the OSH Act. See Forging Indus.
Ass’n v. Secretary of Labor (Noise), 773
F.2d 1436, 1455 (4th Cir. 1985) (‘‘[T]he
Agency has determined that a particular
industry should be made the subject of
a vertical standard. . . . That decision
was not arbitrary or capricious . . . .
Nor does the use of a comprehensive
vertical standard amount to a prohibited
special treatment’’).
Although the Agency can identify the
general types of hazards addressed by
its vertical standards, and has done so
in this rulemaking, there is no legal
requirement for hazard-by-hazard
significant risk findings in vertical
standards. First, the DC Circuit Court of
Appeals has already rejected the
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argument ‘‘that Benzene requires that
the agency find that each and every
aspect of its standard eliminates a
significant risk faced by employees.’’
Ethylene Oxide, 796 F.2d at 1502, n. 16.
Once OSHA makes a general finding of
significant risk, the question becomes
whether the requirements of the
standard are reasonably related to the
standard’s purpose. See, for example,
Noise, 773 F.2d at 1447. Second, when
the Supreme Court first construed the
OSH Act as imposing a significant risk
requirement, it spoke in terms of the
Agency making findings about unsafe
workplaces, not individual hazards.
Benzene, 448 U.S. at 642 (‘‘before
promulgating any standard, the
Secretary must make a finding that the
workplaces in question are not safe
[and] a workplace can hardly be
considered ‘unsafe’ unless it threatens
the workers with a significant risk of
harm’’). See also, for example, id.
(framing the ‘‘significant risk’’
requirement as obligating OSHA ‘‘to
make a threshold finding that a place of
employment is unsafe—in the sense that
significant risks are present and can be
eliminated or lessened by a change in
practices’’); Texas Indep. Ginners Ass’n
v. Marshall, 630 F.2d 398, 400 (5th Cir.
1980) (‘‘[t]he Supreme Court recently
ruled that the Act requires OSHA to
provide substantial evidence that a
significant risk of harm arises from a
workplace or employment’’). Third,
courts have held that the OSH Act does
not require the disaggregation of
significant risk analyses along other
lines. See, for example, Lockout/Tagout
II, 37 F.3d at 670 (upholding OSHA’s
decision not to conduct individual
significant risk analyses for various
affected industries); American Dental
Ass’n v. Martin, 984 F.2d 823, 827 (7th
Cir. 1993) (OSHA is not required to
evaluate risk ‘‘workplace by
workplace’’); Associated Builders and
Contractors, 862 F.2d at 68 (‘‘the
significant risk requirement must of
necessity be satisfied by a general
finding concerning all potentially
covered industries’’).
Requiring OSHA to make multiple,
hazard-specific significant risk findings
would place an unwarranted burden on
OSHA rulemaking because of
difficulties in specifically defining each
of the hazards addressed by a vertical
standard.8 Hazards can be defined
8 Indeed, disputes over how to define hazards are
commonplace in enforcement cases under the
general duty clause of the OSH Act. See, for
example, Secretary of Labor v. Arcadian Corp., 20
BNA OSHC 2001 (OSHRC, Sept. 30, 2004);
Secretary of Labor v. Inland Steel Co., 12 BNA
OSHC 1968 (OSHRC, July 30, 1986); Secretary of
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broadly, for example, falling from an
elevation, or more narrowly, for
example, falling from an elevated aerial
lift while performing tree-trimming
work. The outcome of the significant
risk analysis called for by EEI would be
largely (and somewhat arbitrarily)
dependent on where along this vast
spectrum OSHA defined the relevant
dangers.
OSHA reviewed the authority EEI
relied on in support of the purported
requirement for hazard-specific risk
findings, but does not find it persuasive.
First, EEI argued that the Supreme
Court, in its Benzene decision, held that
the Agency had to make separate
significant risk findings for the aircontaminant and dermal-contact
provisions of that standard (Ex. 0227). A
close reading of the decision in that case
reveals no such holding. Instead, the
dermal-contact provisions in that case
were remanded on the same basis that
the air-contaminant provisions were
rejected—namely that the provisions
were not supported by any significant
risk findings. See Benzene, 448 U.S. at
661–62. While the Court did suggest
that OSHA needed to find that a
prohibition on dermal contact was
reasonably necessary and appropriate to
address a significant risk, that is, that
preventing dermal contact would reduce
the overall risk associated with
workplace exposure to benzene, it did
not address whether a single significant
risk finding could ultimately support
both the dermal-contact and aircontaminant provisions in the standard.
Id.
Second, EEI relied on the Eleventh
Circuit’s decision in AFL–CIO v. OSHA
(PELs), 965 F.2d 962 (11th Cir. 1992),
which vacated and remanded OSHA’s
Air Contaminants Standard (Ex. 0227).
That rule set permissible exposure
limits for more than 400 toxic
substances. Although in that case the
court said that OSHA needed to explain
its assessment of risk for each regulated
substance, that rulemaking is readily
distinguished from this final rule. In
PELs, the various regulated substances
were ‘‘unrelated’’ and had ‘‘little [in]
common.’’ 965 F.2d at 972. Here, in
contrast, the various hazards addressed
by this final rule are closely related.
They all arise at power generation,
transmission, and distribution worksites
and jointly contribute to the large
number of injuries and fatalities
suffered by covered workers. OSHA
does not believe that the PELs decision
limits its discretion to adopt provisions
it deems reasonably necessary and
Labor v. Pelron Corp., 12 BNA OSHC 1833 (OSHRC,
June 2, 1986).
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appropriate to abate the existing
electrocution, burn, fall, and other
hazards that, together, result in covered
employees being exposed to an overall
workplace risk that is significant.
Finally, EEI’s reliance on the Agency’s
ergonomics rulemaking is misplaced.
EEI pointed out that OSHA’s risk
assessment in its ergonomics
rulemaking considered only accidents
that resulted from hazards covered by
that standard (Ex. 0227). But this
interpretation offers no support for EEI’s
position, as the risk assessment in this
rulemaking similarly considered only
injuries and fatalities that occurred
during the performance of work covered
by this final rule (Ex. 0080). (See also
Section VI, Final Economic Analysis
and Regulatory Flexibility Analysis,
later in the preamble.)
Although OSHA does not agree that
hazard-specific significant risk findings
are necessary, the Agency believes that
the record supports such findings for
the critical hazards addressed in this
rulemaking—namely electrocutions and
electric shocks, burns from arc flashes,
and falls. The Agency has found that a
significant number of injuries and
fatalities occur every year as a result of
employee exposure to each of these
hazards. (See Section VI, Final
Economic Analysis and Regulatory
Flexibility Analysis, later in the
preamble.) Moreover, as EEI points out,
‘‘most of the hazards’’ addressed in this
rulemaking ‘‘are already covered by the
existing standards that OSHA [is] now
. . . modify[ing] and supplement[ing]’’
(Ex. 0227). Furthermore, some of the
hazards addressed by this rulemaking
are already the subject of generally
applicable hazard-specific horizontal
standards. See, for example, 29 CFR part
1926, subpart K (electrical hazards) and
subpart M (fall hazards). All of these
existing standards were supported by
findings of significant risk, and OSHA
simply concludes that the additional
provisions of this final rule are
reasonably necessary and appropriate to
reduce a substantial portion of the
remaining significant risk at power
generation, transmission, and
distribution worksites.
III. Development of the Final Rule
A. History of the OSHA Standards
OSHA first adopted standards for the
construction of power transmission and
distribution lines and equipment in
1972 (subpart V of 29 CFR part 1926).
OSHA defines the term ‘‘construction
work’’ in 29 CFR 1910.12(b) as ‘‘work
for construction, alteration, and/or
repair, including painting and
decorating.’’ The term ‘‘construction’’ is
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broadly defined in § 1910.12(d) and
existing § 1926.950(a)(1) to include the
original installation of, as well as the
alteration, conversion, and
improvement of electric power
transmission and distribution lines and
equipment.
The general industry standard at 29
CFR 1910.269 applies to the operation
and maintenance of electric power
generation, transmission, and
distribution installations. OSHA
adopted § 1910.269 on January 31, 1994.
That standard is a companion standard
to subpart V of the construction
standards and addresses work to which
subpart V did not apply. When
promulgated, § 1910.269 was also based
on the latest technology and national
consensus standards.
OSHA revised its Electrical Protective
Equipment Standard in § 1910.137 at
the same time § 1910.269 was
promulgated. The revision of § 1910.137
eliminated the incorporation by
reference of national consensus
standards for rubber insulating
equipment and replaced it with
performance-oriented rules for the
design, manufacture, and safe care and
use of electrical protective equipment.
OSHA published a proposed rule (the
subpart V proposal) on June 15, 2005
(70 FR 34822). That document proposed
revising the construction standard for
electric power transmission and
distribution work (29 CFR part 1926,
subpart V) and the general industry
standards for electric power generation,
transmission, and distribution work (29
CFR 1910.269). That document also
proposed a new construction standard
for electrical protective equipment (29
CFR 1926.97) and revisions to the
general industry standards for foot
protection (29 CFR 1910.136) and
electrical protective equipment (29 CFR
1910.137). Public comments were
originally due by October 13, 2005, but
in response to requests from interested
parties, including EEI, OSHA extended
the comment period 90 days to January
11, 2006 (70 FR 59290, Oct. 12, 2005).
OSHA held an informal public hearing
beginning on March 6, 2006, and ending
on March 14, 2006. After the hearing,
interested parties had until May 15,
2006, to submit additional information
and until July 14, 2006, to file
posthearing briefs (Tr. 1415).
On October 22, 2008, OSHA reopened
the record for 30 days to gather
information from the public on specific
questions related to minimum approach
distances (73 FR 62942). EEI requested
a public hearing and an additional 60
days to submit comments on the issues
raised in the reopening notice (Ex.
0530). On September 14, 2009, OSHA
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opened the record for an additional 30
days to receive more comments on
minimum approach distances and
announced a public hearing to be held
on October 28, 2009, addressing the
limited issues raised in the two
reopening notices (74 FR 46958). After
the hearing, interested parties had until
December 14, 2009, to submit additional
information and until February 10,
2010, to file posthearing briefs (Tr2.
199).
The record for this rulemaking
consists of all prehearing comments, the
transcripts of the two public hearings,
all exhibits submitted prior to and
during the two hearings, and
posthearing submissions and briefs.
Administrative Law Judge Stephen
Purcell issued an order closing the
record and certified the record to the
Assistant Secretary of Labor for
Occupational Safety and Health. The
Agency carefully considered the entire
record in preparing this final standard.
B. Relevant Consensus Standards
The National Electrical Safety Code
(American National Standards Institute
(ANSI) Standard ANSI/IEEE C2, also
known as the NESC) contains provisions
specifically addressing electric power
generation, transmission, and
distribution work. ANSI/IEEE C2 does
not, however, address the full range of
hazards covered by this final rule. It is
primarily directed to the prevention of
electric shock, although it does contain
a few requirements for the prevention of
falls and burns from electric arcs.
The American Society for Testing and
Materials (ASTM) has adopted
standards related to electric power
generation, transmission, and
distribution work. ASTM Committee
F18 on Electrical Protective Equipment
for Workers has developed standards on
rubber insulating equipment, climbing
equipment, protective grounding
equipment, fiberglass rod and tube used
in live-line tools, and clothing for
workers exposed to electric arcs.
The National Fire Protection
Association (NFPA) has adopted a
standard on electrical safety for
employees, NFPA 70E, Standard for
Electrical Safety in the Workplace.
Although it does not apply to electric
power generation, transmission, or
distribution installations, the NFPA
standard contains provisions addressing
work near such installations performed
by unqualified employees, that is,
employees who have not been trained to
work on or with electric power
generation, transmission, or distribution
installations. It also contains methods
for estimating heat energy levels from
electric arcs and describes ways to
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protect employees from arc-flash
hazards.
The Institute of Electrical and
Electronic Engineers (IEEE) writes
standards for electric power generation,
transmission, and distribution
installations and for work on those
installations. Many of these standards
have been adopted by ANSI. Among
these IEEE standards are: IEEE Std 516,
IEEE Guide for Maintenance Methods on
Energized Power-Lines, and IEEE Std
1048, IEEE Guide for Protective
Grounding of Power Lines.
OSHA recognizes the important role
consensus standards can play in
ensuring worker safety. A
comprehensive list of consensus
standards relating to electric power
generation, transmission, and
distribution work can be found in
existing Appendix E to § 1910.269.
OSHA proposed to add the same list as
Appendix E to subpart V. OSHA
considered the latest editions of all the
standards listed in Appendix E in the
development of this final rule. Any
substantial deviations from these
consensus standards are explained in
Section V, Summary and Explanation of
the Final Rule, later in this preamble.
C. Advisory Committee on Construction
Safety and Health
Under 29 CFR parts 1911 and 1912,
OSHA must consult with the Advisory
Committee on Construction Safety and
Health (ACCSH or the Committee),
established pursuant to Section 107 of
the Contract Work Hours and Safety
Standards Act (40 U.S.C. 3701 et seq.),
in setting standards for construction
work. Specifically, § 1911.10(a) requires
the Assistant Secretary to provide
ACCSH with a draft proposed rule
(along with pertinent factual
information) and give the Committee an
opportunity to submit
recommendations. See also § 1912.3(a)
(‘‘[W]henever occupational safety or
health standards for construction
activities are proposed, the Assistant
Secretary [for Occupational Safety and
Health] shall consult the Advisory
Committee.’’).
OSHA has a long history of consulting
with ACCSH on this rulemaking. On
May 25, 1995, OSHA took a draft of the
proposed construction standards to
ACCSH, providing the Committee with
a draft of the proposal and with a
statement on the need to update the
standards. The Committee formed a
workgroup to review the materials, and
the workgroup provided comments to
OSHA. The Agency gave a status report
on the proposal to the Committee on
August 8, 1995, and an updated draft of
the proposal to ACCSH on December 10,
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1999. On February 13, 2003, OSHA gave
ACCSH another status report and
summarized the major revisions it had
made to the proposal. On May 22, 2003,
OSHA provided the Committee with the
same copy of the draft proposal that had
been provided to the small entity
representatives who were participating
in the Small Business Regulatory
Enforcement and Fairness Act
(SBREFA) proceedings, which were
being conducted at that time. OSHA
also explained the major issues being
raised by the small entity
representatives on the draft proposal.
On May 18, 2004, ACCSH gave the
Agency formal recommendations on the
proposal. OSHA sought ACCSH’s
recommendations on the proposal
generally, as well as on issues
specifically related to host employercontractor communications and flameresistant clothing. ACCSH voted
unanimously that: (1) The construction
standards for electric power
transmission and distribution work
should be the same as the general
industry standards for the same type of
work; (2) it was necessary to require
some safety-related communications
between host employers and
contractors; and (3) employees need to
be protected from hazards posed by
electric arcs through the use of flameretardant clothing. ACCSH
recommended, by unanimous vote, that
OSHA issue its proposal, consistent
with these specific recommendations.9
EEI suggested that OSHA had to seek
additional input from ACCSH if it
decided to rely on the recent work of the
IEEE technical committee responsible
for revising IEEE Std 516, which has not
been presented to ACCSH, in
developing the final rule’s minimum
approach-distance provisions (Tr2. 18–
19). EEI is not correct. In making its
assertion, EEI relies on Nat’l
Constructors Ass’n. v. Marshall (Nat’l
Constructors), 581 F.2d 960 (D.C. Cir.
1978). EEI’s reliance on this case is
misplaced. Although the court stated
that the OSH Act and OSHA’s
procedural regulations (29 U.S.C.
655(b)(1); 29 CFR 1911.10(a)) place ‘‘a
‘stricter’ requirement on when, and how
often, the agency must utilize the
advisory committee procedure than
does the [Administrative Procedure Act
(APA)] with respect to public comment
during informal rulemaking,’’ id. at 970,
that statement in the decision is
nonprecedential dicta. The court did
not ‘‘decide how much stricter the
requirement is’’ because, the court
9 ACCSH transcript for May 18, 2004, pages 224–
239. This document can be viewed in the OSHA
Docket Office or online at https://www.osha.gov.
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concluded, the rule at issue did not
meet ‘‘even the APA’s . . . standard.’’
Id. at 971 n.27. As such, the case stands,
at most, for the proposition that OSHA
must return to ACCSH where the final
rule at issue does not meet the APA’s
‘‘logical outgrowth’’ test.
OSHA’s consultation with ACCSH in
this rulemaking was consistent with the
Nat’l Constructors decision. The Nat’l
Constructors court stated that OSHA
had to engage in further consultation
with ACCSH regarding its ground-fault
circuit protection standard where the
final rule recognized ‘‘assured
equipment grounding conductor
programs’’ as a method of compliance,
but ACCSH had never had the
opportunity to comment on that
particular form of employee protection.
The DC Circuit concluded that the
compliance program in question was
neither presented to ACCSH, nor
‘‘gr[e]w logically out of anything that
was presented to, or heard from, the
Committee.’’ Id. at 970—971. In this
Subpart V rulemaking, in contrast, the
basic requirement to adhere to
minimum approach distances was
presented to ACCSH. (See, for example,
ACCSH Docket ACCSH 1995–2.) The
Agency is simply refining the method
used to establish the minimum
approach distances 10 in light of
technical progress that has been made
since the proposal was reviewed by
ACCSH. (For a complete discussion of
the minimum approach-distance
requirements and OSHA’s rationale for
adopting them, see the summary and
explanation for final § 1926.960(c)(1), in
Section V, Summary and Explanation of
the Final Rule, later in this preamble.)
In any event, ACCSH had an
opportunity to comment on whether
OSHA should rely on the work of the
IEEE committee generally. ACCSH knew
that OSHA might base the minimum
approach distances for subpart V on
existing § 1910.269. (See, for example,
Exhibit 12 in Docket ACCSH 1995–2
and Exhibit 101–X in Docket ACCSH
1995–3.) In fact, ACCSH ultimately
concluded in its recommendation that
the construction standards for electric
power transmission and distribution
work should be the same as the general
industry standards for the same type of
work. As existing § 1910.269’s
minimum approach-distance
requirements were derived from IEEE
Std 516 (59 FR 4320, 4382–4384 (Jan.
31, 1994)), ACCSH was on notice that
the work of the IEEE 516 committee
10 The basic equation for computing minimum
approach distances in the final rule is the same as
the one used in existing § 1910.269 and in the draft
proposal submitted to ACCSH.
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might be used by the Agency in
formulating the minimum approachdistance requirements for this final rule.
That ACCSH did not specifically pass
on the question of whether OSHA
should derive its minimum approachdistance requirements from work done
in the formulation of an IEEE standard
that was not yet issued at the time of the
ACCSH consultation is of no
consequence. The OSH Act and OSHA’s
procedural regulation (29 U.S.C.
655(b)(1); 29 CFR 1911.10(a)) ‘‘make
clear that the Assistant Secretary need
only supply whatever information he
has available to him at the time he
submits his proposal to the Committee.’’
Nat’l Constructors, 581 F.2d at 968. As
the Nat’l Constructors Court recognized,
‘‘by designing the Advisory Committee
option as a procedural step that must
precede public notice, comment, and
the informal hearing, [Congress]
assumed that the Committee would not
be provided with all information that
the Labor Department eventually
developed on the subject.’’ Id. at 968
n.16. Thus, OSHA’s action in the final
rule is consistent with Nat’l
Constructors.
IV. Legal Authority
The purpose of the OSH Act, 29
U.S.C. 651 et seq., is ‘‘to assure so far
as possible every working man and
woman in the Nation safe and healthful
working conditions and to preserve our
human resources.’’ 29 U.S.C. 651(b). To
achieve this goal, Congress authorized
the Secretary of Labor to promulgate
and enforce occupational safety and
health standards. 29 U.S.C. 654, 655(b),
658.
A safety or health standard ‘‘requires
conditions, or the adoption or use of one
or more practices, means, methods,
operations, or processes, reasonably
necessary or appropriate to provide safe
or healthful employment and places of
employment.’’ 29 U.S.C. 652(8). A safety
standard is reasonably necessary or
appropriate within the meaning of 29
U.S.C. 652(8) if:
• It substantially reduces a significant
risk of material harm in the workplace;
• It is technologically and
economically feasible;
• It uses the most cost-effective
protective measures;
• It is consistent with, or is a justified
departure from, prior Agency action;
• It is supported by substantial
evidence; and
• It is better able to effectuate the
purposes of the OSH Act than any
relevant national consensus standard.
Lockout/Tagout II, 37 F.3d at 668. In
addition, safety standards must be
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20325
highly protective. See, for example, id.
at 669.
A standard is technologically feasible
if the protective measures it requires
already exist, can be brought into
existence with available technology, or
can be created with technology that can
reasonably be expected to be developed.
See, for example, American Iron and
Steel Inst. v. OSHA (Lead II), 939 F.2d
975, 980 (D.C. Cir. 1991) (per curiam).
A standard is economically feasible
when industry can absorb or pass on the
costs of compliance without threatening
industry’s long-term profitability or
competitive structure. See, for example,
American Textile Mfrs. Inst. v. Donovan,
452 U.S. 490, 530 n. 55 (1981); Lead II,
939 F.2d at 980. A standard is cost
effective if the protective measures it
requires are the least costly of the
available alternatives that achieve the
same level of protection. See, for
example, Lockout/Tagout II, 37 F.3d at
668.
Section 6(b)(7) of the OSH Act
authorizes OSHA to include among a
standard’s requirements labeling,
monitoring, medical testing, and other
information-gathering and informationtransmittal provisions. 29 U.S.C.
655(b)(7). Finally, the OSH Act requires
that when promulgating a rule that
differs substantially from a national
consensus standard, OSHA must
explain why the promulgated rule is a
better method for effectuating the
purposes of the Act. 29 U.S.C. 655(b)(8).
Deviations from relevant consensus
standards are explained elsewhere in
this preamble.
V. Summary and Explanation of the
Final Rule
OSHA is adopting a new construction
standard on electrical protective
equipment, 29 CFR 1926.97, and is
revising the standard on the
construction of electric power
transmission and distribution lines and
equipment, 29 CFR part 1926, subpart
V. The Agency is also revising the
general industry counterparts to these
two construction standards, 29 CFR
1910.137 and 1910.269, respectively.
Finally, OSHA is revising its general
industry standard on foot protection, 29
CFR 1910.136, to require employers to
ensure that each affected employee uses
protective footwear when the use of
protective footwear will protect the
affected employee from an electrical
hazard, such as a static-discharge or
electric-shock hazard, that remains after
the employer takes other necessary
protective measures.
This section discusses the important
elements of the final rule, explains the
individual requirements, and explains
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any differences between the final rule
and existing standards. This section also
discusses issues that were raised at the
two public hearings, significant
comments received as part of the
rulemaking record, and substantive
changes from the language of the
proposed rule. Unless otherwise noted,
paragraph references in the summary
and explanation of the final rule fall
under the section given in the heading
for the discussion. For example, except
as otherwise noted, paragraph
references in V.A, Section 1926.97,
Electrical Protective Equipment, are to
paragraphs in final § 1926.97. Except as
noted, the Agency has carried proposed
provisions into the final rule without
substantive change.
The final rule contains several
differences from the proposal and
existing §§ 1910.137 and 1910.269 that
are purely editorial and nonsubstantive.
For example, the Agency amended the
language of some provisions to shift
from passive to active voice, thereby
making the standard easier to read.
OSHA does not discuss explicitly in the
preamble all of these differences. The
purpose of these differences, unless
otherwise noted, is to clarify the final
standard.
A. Section 1926.97, Electrical Protective
Equipment
Workers exposed to electrical hazards
face a risk of death or serious injury
from electric shock. According to BLS,
there were 192 and 170 fatalities
involving contact with electric current
in 2008 and 2009, respectively (https://
www.bls.gov/iif/oshwc/cfoi/cftb0240.pdf
and https://www.bls.gov/iif/oshwc/cfoi/
cftb0249.pdf). About half of these
fatalities (89 in both years) occurred in
construction (id.).11
The use of properly designed,
manufactured, and cared-for electrical
protective equipment helps protect
employees from this risk. Therefore,
OSHA is issuing final § 1926.97,
Electrical protective equipment, which
addresses the design, manufacture, and
proper care of electrical protective
equipment. In addition, OSHA is
revising existing § 1910.137, which also
contains provisions addressing the
design, manufacture, and proper care of
electrical protective equipment. For
reasons described at length in this
section of the preamble, OSHA
concludes that the final rule will be a
more effective means of protecting
employees from the risk of electric
shock than existing OSHA standards.
11 Similar data are available at https://
www.bls.gov/iif/oshcfoi1.htm#2009 for each year
back to 2003.
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The existing requirements for
electrical protective equipment in
construction work are in
§ 1926.951(a)(1), which only applies to
the construction of electric power
transmission and distribution lines and
equipment. However, employers
throughout the construction industry
use electrical protective equipment, and
OSHA believes that provisions for
electrical protective equipment, as
specified by final § 1926.97, should
apply, not only to electric power
transmission and distribution work, but
to all construction work. Therefore,
OSHA is issuing new § 1926.97,
Electrical protective equipment, which
applies to all construction work.
Existing § 1926.951(a)(1) incorporates
by reference the following six American
National Standards Institute (ANSI)
standards:
Item
ANSI Standard
Rubber insulating gloves
Rubber matting for use
around electric apparatus.
Rubber insulating blankets.
Rubber insulating hoods
Rubber insulating line
hose.
Rubber insulating
sleeves.
J6.6–1971
J6.7–1935
(R1971)
J6.4–1971
J6.2–1950
(R1971)
J6.1–1950
(R1971)
J6.5–1971
These standards contain detailed
specifications for manufacturing,
testing, and designing electrical
protective equipment. However, these
standards have undergone several
revisions since the 1971 publication
date of existing subpart V and are now
seriously out of date. Following is a
complete list of the corresponding
current national consensus standards:
ASTM D120–09, Standard
Specification for Rubber Insulating
Gloves.
ASTM D178–01 (Reapproved 2010),
Standard Specification for Rubber
Insulating Matting.
ASTM D1048–12, Standard
Specification for Rubber Insulating
Blankets.
ASTM D1049–98 (Reapproved 2010),
Standard Specification for Rubber
Insulating Covers.
ASTM D1050–05 (Reapproved 2011),
Standard Specification for Rubber
Insulating Line Hose.
ASTM D1051–08, Standard
Specification for Rubber Insulating
Sleeves.
Additionally, there are now standards
on the in-service care of insulating line
hose and covers (ASTM F478–09),
insulating blankets (ASTM F479–06
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(2011)), and insulating gloves and
sleeves (ASTM F496–08), which OSHA
did not incorporate or reference in
existing § 1926.951(a)(1).12
OSHA derived proposed new
§ 1926.97 from these national consensus
standards, but drafted it in performance
terms. OSHA is carrying this approach
forward into the final rule. The final
rule relies on provisions from the
consensus standards that are
performance based and necessary for
employee safety, but the final rule does
not contain many of the detailed
specifications from those standards.
Thus, the final rule will provide greater
flexibility for compliance.
BGE commented that OSHA’s
performance-based approach leaves the
standards ‘‘vague’’ and creates
‘‘opportunities for unsafe practices’’ (Ex.
0126).
OSHA disagrees with this comment
for the following reasons.
The Agency recognizes the
importance of the consensus standards
in defining basic requirements for the
safe design and manufacture of
electrical protective equipment for
employees. To this end, OSHA will
allow employers to comply with the
final rule by following specific
provisions in the consensus standards.
OSHA believes that the option of
following these specific provisions
addresses the commenter’s concern
about vagueness.
However, OSHA determined that it
would be inappropriate to adopt the
consensus standards in toto in this
rulemaking. First, each of the currently
referenced standards has undergone
several revisions since OSHA adopted
the standards in existing
§ 1926.951(a)(1). Because of the
continual process by which the
consensus standards development
organizations periodically revise their
consensus standards, any specific
editions that OSHA might adopt likely
would be outdated within a few years.
Additionally, since OSHA’s rulemaking
process is lengthy, it would not be
practical for OSHA to revise its
standards as often as necessary to keep
pace with the changes in the consensus
12 The relevant ASTM standards are in the record
as Exs. 0048, 0049, 0050, 0051, 0066, 0067, 0068,
0069, 0070. In several cases, the version of the
consensus standard in the record is older than the
version listed in the preamble. However, OSHA
based final §§ 1926.97 and 1910.137 only on the
ASTM documents and other data in the record. The
preamble lists editions of the consensus standards
not in the record because OSHA evaluated them for
consistency with the final rule. OSHA determined
that these later ASTM standards conform to the
requirements of final §§ 1926.97 and 1910.137. See
the discussion of the notes following paragraphs
(a)(3)(ii)(B) and (c)(2)(ix) for the significance of this
determination.
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standards. Final § 1926.97 is flexible
enough to accommodate changes in
technology, obviating the need for
constant revision. Wherever possible,
OSHA wrote the final rule in
performance terms to allow alternative
methods of compliance that provide
comparable safety to employees.
Another difficulty with incorporating
the consensus standards by reference is
that they contain details that go beyond
the scope of the OSHA standard and are
not directly related to employee safety.
In final § 1926.97, OSHA relied only on
consensus standard provisions that are
relevant to employee safety in the
workplace. Furthermore, to make the
requirements easier for employers and
employees to use and understand,
OSHA adopted language in the final
rule that is simpler than that in the
consensus standards. Because all
relevant requirements are in the text of
the regulations, employers will not need
to refer to the consensus standards to
determine their obligations under final
§ 1926.97. Although OSHA is no longer
incorporating the consensus standards
by reference, notes throughout the rule
clarify that OSHA will deem
compliance with the consensus
standards listed in the notes to be
compliance with the performance
requirements of final § 1926.97.
OSHA notes that it recently decided
not to adopt a proposed performancebased approach when it revised the
design requirements contained in
several personal protective equipment
standards (74 FR 46350, Sept. 9, 2009).
In issuing that final rule, OSHA
reasoned that ‘‘widespread opposition’’
to, and misunderstanding of, the
proposal indicated ‘‘possible
misapplication . . . if adopted’’ (74 FR
46352).
This rationale does not apply to this
rulemaking. First, there was no
widespread opposition to the proposed
performance-based approach in this
rulemaking. A number of commenters
did request that OSHA deem employers
that are in compliance with all future
revisions of the listed consensus
standards as being in compliance with
the final rule (see, for example, Exs.
0156, 0180, 0183, 0202, 0206, 0229,
0231, 0239). The Agency believes that
the performance-based approach it
adopts in final § 1926.97 will provide
these commenters with the flexibility
they requested by permitting employers
to follow future versions of consensus
standards so long as those future
versions meet the final rule’s
performance-based criteria. Second,
OSHA adopted a performance-based
approach when it previously revised
existing § 1910.137 in 1994 (59 FR
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4323–4325). Several participants in the
1994 rulemaking supported a
performance-based approach (59 FR
4324). Third, OSHA believes that
harmonizing § 1926.97 and § 1910.137
will reduce misapplication by the
regulated community and, thereby,
reduce the risk of electric shock.
Promulgating inconsistent standards
would increase misapplication by the
regulated community and,
consequently, increase the risk of
electric shock. Finally, OSHA has had
no difficulty enforcing § 1910.137 since
issuing it in 1994.
Regarding the commenters’ requests
that OSHA deem employers that are in
compliance with all future revisions of
the listed consensus standards as being
in compliance with the final rule, OSHA
has no basis on which to find that future
revisions of the consensus standards
will provide suitable guidance for
compliance with the performance
criteria of the final rule. Revised
consensus standards may or may not
meet the final rule’s performance
criteria. If a revised consensus standard
does not satisfy this final rule’s
performance criteria, however, the
Agency may consider compliance with
that consensus standard to be a de
minimis condition if the consensus
standard clearly provides protection
equal to, or greater than, the protection
provided by § 1926.97.13
An employer seeking to rely on an
updated consensus standard may
evaluate for itself whether the
consensus standard meets the
performance criteria contained in final
§ 1926.97. An employer that is unsure
about whether a revised consensus
standard meets the OSHA standard’s
performance criteria may seek guidance
from OSHA. If a revised consensus
standard does not appear to meet the
OSHA standard’s performance criteria,
but the employer nonetheless wants to
follow the revised consensus standard,
the employer should seek guidance from
OSHA as to whether the Agency would
consider an employer’s following the
13 De
minimis conditions are conditions in which
an employer implemented a measure different from
one specified in a standard, but that has no direct
or immediate relationship to safety or health. The
Agency does not issue citations or penalties for de
minimis conditions, nor is the employer required to
bring the workplace into compliance, that is, there
are no abatement requirements. Pursuant to OSHA’s
de minimis policy, which is set forth in OSHA
Instruction CPL 02–00–148 (‘‘Field Operations
Manual’’), a de minimis condition exists when an
employer complies with a consensus standard
rather than with the standard in effect at the time
of the inspection and the employer’s action clearly
provides equivalent or more effective employee
protection.
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revised consensus standard to be a de
minimis condition.14
Some rulemaking participants asked
OSHA to provide the applicable
consensus standards to employers at no
cost. (See, for example, Exs. 0156, 0161,
0183, 0202, 0206, 0229, 0231, 0233; Tr.
1287–1288.) For instance, Mr. Terry
Williams with the Electric Cooperatives
of South Carolina stated: ‘‘If OSHA is to
rely on procedures that it does not
describe in full, . . . the agency should
provide a cost-free way for employers to
review these procedures to make sure
they are following them’’ (Ex. 0202). Mr.
Don Adkins with Davis H. Elliot
Construction Co. stated that the ‘‘cost of
securing and reviewing these voluntary
standards place[s] a financial burden on
small employers’’ (Ex. 0156).
OSHA is rejecting these requests. The
Agency stated the rule in performancebased terms, which allows employers
flexibility in complying with the rules.
The Agency understands that employers
may want additional guidance in terms
of precise procedures or detailed
specifications to follow. Final § 1926.97
references relevant consensus standards
to provide such additional guidance, but
those standards are not mandatory.
In any event, even when OSHA
incorporates consensus standards by
reference, the Agency does not provide
those consensus standards to employers
at no cost. Many consensus standards
are copyrighted documents; and, in
those cases, the copyright holder has
certain legal rights regarding the public
distribution of those documents. Note
that some consensus standards
development organizations, for
example, NFPA, do provide free, viewonly access to their standards (https://
www.nfpa.org/
itemDetail.asp?categoryID=
279&itemID=18123
&URL=Codes%20&%20Standards/
Code%20development%20process/
Online%20access).15 OSHA also will
continue to explore other ways of
informing the regulated community
14 Note that this approach applies to the use of
any consensus standard referenced in the final rule.
Moreover, the same principles described with
respect to subsequent versions of the consensus
standards also apply to earlier versions of the
consensus standards.
15 For instance, NFPA 70E, Standard for
Electrical Safety in the Workplace, one of the
documents listed in Appendix G to Subpart V,
described later in this section of the preamble, is
available at https://www.nfpa.org/aboutthecodes/
AboutTheCodes.asp?DocNum=70E&cookie_test=1.
Select either the 2009 or 2012 edition from the
drop-down box labeled ‘‘Edition to display’’ and
click the link labeled ‘‘View [selected] edition
online.’’ Note that registration with NFPA is
required to view the standard.
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about applicable compliance obligations
specified by the final rule.
Moreover, employers can often rely
on the assurances of third parties that
equipment or test methods meet the
listed consensus standards. First, OSHA
expects that employers will typically get
the assurance of manufacturers that
electrical protective equipment is
capable of withstanding the appropriate
electrical proof tests required by final
paragraphs (a) and (b). In this regard, an
employer can simply look for
equipment labeled as meeting the listed
consensus standards. Manufacturers
attest, through such a label, typically
required by the relevant consensus
standard, that their equipment passed
the requisite tests.
Second, it is OSHA’s understanding
that many employers, particularly small
employers, do not test their own
equipment to determine whether
employees can use the equipment, as
required by final paragraph (c). Instead,
these employers send the equipment to
an electrical laboratory for testing (see,
for example, the testimony of Mr. Frank
Brockman of Farmers Rural Electric
Cooperative Corporation about the use
of testing laboratories, Tr. 1301–1302). It
is OSHA’s understanding that, as a
matter of practice, such laboratories
follow the test methods in the
applicable consensus standards for
testing a wide range of products (see, for
example, Ex. 0211).16 To determine
whether employees can use the
equipment in accordance with final
paragraph (c), employers can rely on the
assurance of these testing laboratories
that they followed the listed consensus
standards, as well as the requirements of
OSHA’s standard.
OSHA expects that, when consensus
standards development organizations
revise their consensus standards,
manufacturers’ labels will certify that
the equipment meets the latest
consensus standards, and that testing
laboratories will use the test methods in
the latest consensus standards, rather
than the consensus standards listed in
the notes. OSHA is sympathetic to
concerns that employers, especially
small businesses, do not have the
resources to purchase and check
whether revised consensus standards
meet the final rule’s performance
criteria. As discussed previously, an
employer that does not have the
resources to purchase and review an
updated consensus standard (indeed,
any employer) may request guidance
from OSHA on whether compliance
16 When a question arises as to the validity of a
test method a laboratory is using, OSHA will
investigate the validity of the method.
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with an updated consensus standard
would conform to this final rule or bring
the employer within OSHA’s de
minimis policy.
In the final rule, OSHA reworded the
headings for paragraphs (a), (b), and (c)
to more accurately reflect the content of
the respective paragraphs. Paragraph
(a). Paragraph (a) of § 1926.97 addresses
the design and manufacture of the
following types of rubber insulating
equipment: Blankets, matting, covers,
line hose, gloves, and sleeves.17
(Paragraph (b) of § 1926.97 contains
general requirements for other types of
insulating equipment (see the
discussion of this paragraph later in this
section of the preamble).) Paragraphs (a)
and (c) of proposed § 1926.97 were
based on existing § 1910.137(a) and (b);
however, the proposal added Class 00
equipment to the classes addressed by
the existing provisions to reflect the
coverage of this new class of equipment
in the consensus standards (Exs. 0048,
0051). This class of electrical protective
equipment is used with voltages of 500
volts or less. OSHA received no
comments on the proposed addition of
Class 00 electrical protective equipment.
Paragraph (a)(1)(i), which is being
adopted without change from the
proposal, requires blankets, gloves, and
sleeves to be manufactured without
seams. This method of making the
protective equipment minimizes the
chance that the material will split.
Because they are used when workers
handle energized lines, gloves and
sleeves are the only defense an
employee has against electric shock.
Additionally, the stresses placed on
blankets, gloves, and sleeves by the
flexing of the rubber during normal use
could cause a seam to separate from
tensile or shear stress.
The prohibition on seams does not
apply to the other three types of
electrical protective equipment covered
by paragraph (a) (covers, line hose, and
matting). These types of equipment
generally provide a more indirect form
of protection because they insulate the
live parts from accidental, rather than
intended, contact. Moreover, they are
not usually subject to similar amounts
or types of flexing and, thus, are not
subject to the same stress.18
17 The language in proposed paragraph (a) has
been editorially revised in the final rule to make it
clearer that the paragraph applies to rubber
insulating equipment only.
18 Flexing can cause different types of stress on
rubber, including tensile, compression, and shear
stress. Rubber insulating line hose and covers are
subject to the greatest amount of flexing while
employees are installing them on an energized part.
However, employees install this equipment either
with live-line tools or while wearing rubber
insulating gloves and sleeves. Thus, when seam
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Paragraph (a)(1)(ii), which is being
adopted with one modification from the
proposal, requires electrical protective
equipment to be marked to indicate its
class and type. The class marking
indicates the voltage with which the
equipment can be used; 19 the type
marking indicates whether the
equipment is ozone resistant. These
markings enable employees to know the
uses and voltages for which the
equipment is suited. This provision also
permits equipment to contain other
relevant markings, for example, the
manufacturer’s name, the size of the
equipment, or a notation that the
equipment is manufactured in
accordance with the relevant consensus
standards.
Proposed paragraphs (a)(1)(ii)(G) and
(a)(1)(ii)(H) would have required rubber
insulating equipment ‘‘other than
matting’’ to be marked as Type I or Type
II to indicate whether or not it was
ozone-resistant. Mr. James Thomas,
President of ASTM International,
submitted comments recommending
that the quoted language be deleted
from these paragraphs because the ‘‘type
classification denotes the manufacturing
material being either Nonresistant to
Ozone (Type I) or Resistant to Ozone
(Type II) and applies to all [rubber
insulating equipment], including
[m]atting’’ (Ex. 0148).
OSHA agrees that the ASTM
standards require matting to be marked
with the type to indicate whether or not
it is ozone-resistant, and the Agency has
adopted the commenter’s
recommendation in the final rule.
Mr. Leo Muckerheide of Safety
Consulting Services recommended that
OSHA require marking the maximum
use voltage on electrical protective
equipment, stating:
Many electrical workers work with
multiple voltages and are infrequent users of
electrical protective equipment. Therefore,
expecting them to remember which class to
use with which voltage is a potentially
hazardous problem. This problem can be
easily eliminated by having the maximum
use voltage marked on the electrical
protective equipment. [Ex. 0180]
OSHA rejects this recommendation.
First, workers using electrical protective
equipment receive training that ensures
that they know which class of
equipment to use on which voltage. The
separation is likely, the employee is protected by
other means.
Rubber insulating matting is generally laid on the
floor and is not subject to the type of flexing that
is likely to cause separation.
19 The maximum use voltages for individual
classes of equipment are provided in Table E–4,
discussed under the summary and explanation for
paragraph (c)(2)(i), infra.
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record demonstrates that most of the
workers covered by § 1910.269 and
subpart V are highly trained (see, for
example, Tr. 1228) and use electrical
protective equipment to work on
energized lines on a regular, often daily,
basis (see, for example, Tr. 394, 889,
1218–1219). Furthermore, several OSHA
standards require training for employees
working on or near exposed energized
parts, when electrical protective
equipment would also be required. For
instance, final §§ 1910.269(a)(2)(ii)(D)
and 1926.950(b)(2)(iv) require training
in the use of electrical protective
equipment for qualified employees
performing electric power generation,
transmission, and distribution work.
Paragraph (c)(2) of § 1910.333 contains a
similar requirement for workers
performing other types of general
industry electrical work. Paragraph
(b)(2) of § 1926.21 contains training
requirements for workers performing
construction work. Although this
requirement is more general than the
training requirement in this final
standard, § 1926.21 requires training in
OSHA standards applicable to the
employee’s work environment.
Second, electrical protective
equipment meeting the applicable
consensus standards is manufactured
with the Class ratings included, but
generally without labels for maximum
use voltages. (See, for example, Exs.
0048, 0049, 0050, 0066, 0067, 0068.)
Requiring electrical protective
equipment to be marked with its
maximum use voltage would likely
force employers to mark the equipment
themselves. OSHA believes that the
permanent class-rating marking placed
on electrical protective equipment by
the manufacturer provides adequate
information and is less likely to wear off
over the useful life of the equipment
than any marking put in place by an
employer. Thus, the Agency concludes
that a requirement for marking the
maximum use voltage on electrical
protective equipment is unnecessary.
Mr. Frank Owen Brockman,
representing Farmers Rural Electric
Cooperative Corporation, recommended
that OSHA also require that the
markings include the company testing
the equipment, the test date, and owners
of the equipment (Ex. 0173). He did not
explain how including this additional
information in the markings would
better protect employees. Moreover,
although requiring the employer to note
the date equipment is tested does
enhance worker protection, final
paragraph (c)(2)(xii) of § 1926.97
addresses this matter by requiring the
employer to certify that equipment has
successfully passed the periodic testing
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required by the final rule and by
requiring this certification to identify
the equipment that passed the test and
the date it was tested. OSHA agrees with
Mr. Brockman that keeping workers
aware of the date of last testing would
enhance worker protection. Therefore,
OSHA revised the language in final
paragraph (c)(2)(xii) to also require that
the certification required by the rule be
made available to employees or their
authorized representatives.
It should be noted that, although not
required, the markings suggested by Mr.
Muckerheide and Mr. Brockman are
permitted under paragraph (a)(1)(ii)(I).
Paragraph (a)(1)(iii) requires all
markings to be nonconductive and to be
applied so as not to impair the
insulating properties of the equipment.
OSHA did not receive any comments on
this provision in the proposal and has
carried it forward without change into
the final rule. This requirement ensures
that no marking interferes with the
protection to be provided by the
equipment.
Paragraph (a)(1)(iv), which is being
adopted without change from the
proposal, requires markings on gloves to
be confined to the cuff area.20 As OSHA
explained in the preamble to the
proposed rule, markings in other areas
could possibly wear off (70 FR 34828).
Moreover, having the markings in one
place will allow the employee to
determine the class and type of glove
quickly. Finally, as discussed later in
this section of the preamble, final
paragraph (c)(2)(vii) requires that rubber
gloves normally be worn under
protector gloves. Because a protector
glove is almost always shorter than the
corresponding rubber glove with which
it is worn, and because the cuff of the
protector glove can easily be pulled
back without removal, it is easy to see
markings on the cuff portion of the
rubber glove beneath. Any marking
provided on the rubber glove in an area
outside of the cuff could not be seen
with the protector glove in place.
Paragraph (a)(2) of final § 1926.97
contains electrical requirements for
rubber insulating blankets, matting, line
hose, gloves, and sleeves. As previously
discussed, this provision uses
performance language, and does not
contain a lengthy discussion of specific
test procedures.
Paragraph (a)(2)(i), which is being
carried forward from the proposed rule,
requires electrical protective equipment
to be capable of withstanding the ac
proof-test voltages in Table E–1 or the
dc proof-test voltages in Table E–2 of
20 The cuff area is the area near the reinforced
edge of the glove.
PO 00000
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20329
the standard.21 The proof-test voltages
listed in these tables have been derived
from the current ASTM standards,
which also contain detailed test
procedures that can be used to
determine whether electrical protective
equipment is capable of withstanding
these voltages. As previously discussed,
these details were not included in the
proposed rule, and this approach is
being carried forward in the final rule.
Paragraph (a)(2)(i)(A) replaces those
details with a performance-oriented
requirement that any proof test can be
used as long as it reliably indicates that
the equipment can withstand the prooftest voltage involved.
Mr. Muckerheide with Safety
Consulting Services stated that the
standard for rubber insulating gloves,
ASTM D120, lists a 280-millimeter
glove instead of the 267-millimeter
glove listed in Table E–1 in the
proposed rule (Ex. 0180). He
recommended making OSHA’s standard
consistent with the ASTM standard or
explaining the difference in the
standard.
OSHA is revising Table E–1 from the
proposal in response to this comment.
OSHA based proposed Table E–1 on
Table I–2 in existing § 1910.137, which,
in turn, was based on the 1987 edition
of ASTM D120. Section 10.3.1 of ASTM
D120–1987 lists four standard lengths
for Class 0 rubber insulating gloves: 279,
356, 406, and 457 millimeters. Table 2
in that edition, however, listed 267
millimeters as the shortest length glove
even though the shortest standard
length was 279 millimeters.
Unlike the 1987 edition of the
consensus standard, the latest edition,
ASTM D120–2009, rounds up the
standard metric sizes. Thus, the relevant
consensus standards for rubber
insulating gloves list four standard sizes
of 280, 360, 410, and 460 millimeters for
Classes 00, 0, 1, 2, 3, and 4 gloves. The
table in the 2009 edition of the
consensus standard corresponding to
Table 2 in the 1987 edition lists a 280millimeter glove as the shortest one.
Based on this information, OSHA
concludes that the appropriate length
for the shortest glove is 280 millimeters.
In addition, the Agency does not
consider the difference between the 280millimeter length recommended by Mr.
21 Existing § 1910.137 contains Table I–2 through
Table I–6, and the proposal did not redesignate
those tables. The final rule revises all of § 1910.137
so as to redesignate the tables, starting with Table
I–1. Consequently, existing Table I–2 corresponds
to Table I–1 in the final rule, existing Table I–3
corresponds to Table I–2 in the final rule, existing
Table I–4 corresponds to Table I–3 in the final rule,
existing Table I–5 corresponds to Table I–4 in the
final rule, and existing Table I–6 corresponds to
Table I–5 in the final rule.
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Muckerheide and the 267-millimeter
proposed length to be substantial. The
1987 and 2009 editions of the consensus
standard each permit a glove to vary
from the standard length by as much as
13 millimeters. Thus, a 280-millimeter
glove can be as short as 267 millimeters.
However, to ensure consistency with the
latest consensus standard, OSHA is
adopting, in Table E–1, both the 280millimeter glove length in place of the
proposed 267-millimeter length and the
rounded-up metric sizes, as listed in the
latest edition of the consensus standard.
Paragraph (a)(2)(i)(B), which is being
adopted as proposed, requires the prooftest voltage to be applied continuously
for 1 minute for insulating matting and
3 minutes for other insulating
equipment. These times are derived
from on the proof-test times given in the
ASTM design standards and are
appropriate for testing the design
capabilities of electrical protective
equipment.
Paragraph (a)(2)(i)(C), which is being
adopted as proposed, requires rubber
insulating gloves to be capable of
withstanding the ac proof-test voltage
indicated in Table E–1 of the standard
after a 16-hour water soak. If rubber
insulating gloves absorb water, a
reduction in insulating properties will
result. Electrical work is sometimes
performed in the rain, and an
employee’s perspiration is often present
while the gloves are in use, so water
absorption is a critical property. The
soak test is needed to ensure that rubber
insulating gloves can withstand the
voltage involved under these
conditions.
It should be noted that the soak test
is a separate test from the initial proof
test. Gloves must be capable of passing
both tests.
Paragraph (a)(2)(ii), which is being
adopted as proposed, prohibits the 60hertz ac proof-test current from
exceeding the values specified in Table
E–1 at any time during the test period.
The currents listed in the table have
been taken from ASTM D120–09. This
provision in the final rule is important
because, when an ac proof test is used
on gloves, the resulting proof-test
current gives an indication of the
validity of the gloves’ make-up, the
dielectric constant of the type of
material used, its thickness, and the
total area under test.
Under paragraph (a)(2)(ii)(A), which
is being adopted without change from
the proposal, the maximum current for
ac voltages at frequencies other than 60
hertz is computed from the direct ratio
of the frequencies. This provision
ensures that maximum current is
equivalent for varying frequencies.
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Paragraph (a)(2)(ii)(B), which is being
adopted as proposed, specifies that
gloves to be tested be filled with and
immersed in water to the depth given in
Table E–3 and that water be added to or
removed from the glove as necessary to
ensure that the water level is the same
inside and outside the glove. Table E–
3 is derived from ASTM D120 and is
valid for the proof-test currents listed in
Table E–1. During the ac proof test, a
gloves is filled with, and immersed in,
water, and the water inside and outside
the glove forms the electrodes. The ac
proof-test current is dependent on the
length of the portion of the glove that is
out of the water. Because the proof-test
current is a function of immersion
depth, it is important to specify the
depth in the rule.22
Paragraph (a)(2)(ii)(C) requires that,
after the 16-hour water soak specified in
paragraph (a)(2)(i)(C), the 60-hertz
proof-test current not exceed the values
given in Table E–1 by more than 2
milliamperes. The allowable proof-test
current must be increased for proof tests
on gloves after a 16-hour water soak
because the gloves absorb a small
amount of water, which results in
slightly increased current during the
test. The final rule was derived from
ASTM D120, which allows an increase
in the proof-test current of 2
milliamperes. If the proof-test current
increases more than 2 milliamperes, it
indicates that the gloves absorbed too
much water. OSHA has revised this
provision in the final rule to indicate
more clearly that it is a requirement
rather than an exception.
Paragraph (a)(2)(iii), which is being
adopted without change from the
proposed rule, prohibits electrical
protective equipment that has been
subjected to a minimum breakdown
voltage test from being used to protect
employees from electrical hazards. The
relatively high voltages used in testing
electrical protective equipment for
minimum breakdown voltage can
damage the insulating material under
test (even if the equipment passes). The
intent of this rule is to prohibit the use
of equipment that has been tested for
minimum breakdown voltage under
22 Atmospheric conditions might invalidate the
test results at the clearances specified in Table E–
3. For instance, under certain atmospheric
conditions, the air between the water inside and
outside the glove, which forms the two electrodes,
might flash over, and thereby invalidate the test
results and damage the glove. As another example,
some atmospheric conditions can lead to excessive
corona and the formation of ozone that ventilation
cannot sufficiently dissipate. To account for these
atmospheric conditions, final Table E–3 contains a
note that provides that, if atmospheric conditions
make these clearances impractical, the clearances
may be increased by a maximum of 25 mm. (1 in.).
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conditions equivalent to those in the
ASTM standards, because minimum
breakdown tests are destructive. Such
tests are performed only on equipment
samples that are to be discarded.
Paragraph (a)(2)(iv), which is being
adopted as proposed, requires ozoneresistant material (Type II) to be capable
of withstanding an ozone test that can
reliably indicate that the material will
resist ozone exposure in actual use.
Standardized ozone tests are given in
the ASTM specifications listed in the
note following paragraph (a)(3)(ii)(B),
and compliance with these
specifications will be deemed
compliance with this OSHA
requirement. Around high-voltage lines
and equipment, a luminous discharge,
called electric corona, can occur due to
ionization of the surrounding air caused
by a voltage gradient that exceeds a
certain critical value. The blue corona
discharge is accompanied by a hissing
noise and by ozone, which can cause
damage to certain types of rubber
insulating materials. Therefore, when
there is a chance that ozone may be
produced at a work location, electrical
protective equipment made of ozoneresistant material is frequently used.
The final rule ensures that ozoneresistant material will, in fact, be
resistant to the deteriorating effects of
the gas. The final rule also provides that
visible signs of ozone deterioration,
such as checking, cracking, breaks, and
pitting, are evidence of failure to meet
the requirements for ozone-resistant
material.23
Paragraph (a)(3) addresses the
workmanship and finish of electrical
protective equipment. Because physical
irregularities can interfere with the
insulating properties of the equipment
and thus reduce the protection it
affords, paragraph (a)(3)(i) prohibits the
presence of physical irregularities that
can adversely affect the insulating
properties of the equipment and that
can be detected by the tests or
inspections required under other
provisions in § 1926.97. In the final rule,
OSHA has revised the language for this
provision to clarify that ‘‘harmful
physical irregularities’’ (the term used
in the proposal) means ‘‘physical
irregularities that can adversely affect
the insulating properties of the
equipment.’’
OSHA recognizes that some minor
irregularities are nearly unavoidable in
the manufacture of rubber goods, and
23 ASTM F819–10, Standard Terminology
Relating to Electrical Protective Equipment for
Workers, which is listed in the note following
paragraph (a)(3)(ii)(B), defines ‘‘ozone cutting and
checking’’ as: ‘‘Cracks produced by ozone in a
material under mechanical stress.’’
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these imperfections may be present in
the insulating materials without
significantly affecting the insulation.
Paragraph (a)(3)(ii), which is being
adopted without change from the
proposal, describes the types of
imperfections that are permitted. Even
with these imperfections, electrical
protective equipment must be capable of
passing the electrical tests specified in
paragraph (a)(2).
Since paragraph (a) of final § 1926.97
is written in performance-oriented
language, OSHA has included a note at
the end of the paragraph stating that
rubber insulating equipment meeting
the requirements of the listed ASTM
standards will be deemed in compliance
with the performance requirements of
final § 1926.97(a). This list of ASTM
standards references the latest revisions
of those documents. The Agency has
reviewed the referenced ASTM
standards and has found them to
provide suitable guidance for
compliance with the performance
criteria of § 1926.97(a).24
Paragraph (b). Paragraph (b) of final
§ 1926.97 addresses electrical protective
equipment other than the rubber
insulating equipment addressed in
paragraph (a). Equipment falling under
this paragraph includes plastic guard
equipment, insulating barriers, and
other protective equipment intended to
provide electrical protection to
employees.
Mr. Steven Theis, representing MYR
Group, requested that OSHA clarify that
equipment complying with the ASTM
and IEEE consensus standards
mentioned in the proposal would
constitute compliance with the final
rule (Ex. 0162). In the proposal, OSHA
pointed to ASTM F712. OSHA has
reviewed ASTM F712–06 (2011) and
has found that it provides suitable
guidance for plastic guard equipment
that employers can use to comply with
final § 1926.97(b). To clarify the
standard, OSHA has added a new note
to paragraph (b) to indicate that OSHA
will consider plastic guard equipment to
conform to the performance
requirements of paragraph (b) if it
meets, and is used in accordance with,
ASTM F712–06 (2011).
In the proposal, the Agency also
pointed to IEEE Std 516, Guide for
Maintenance Methods on Energized
Power Lines, as support for the electrical
criteria in proposed paragraph (b). The
Agency has not referenced this
consensus standard in the final rule.
24 See the extended discussion, earlier in this
section of the preamble, on how to address future
revisions of the listed consensus standards, as well
as earlier versions of the listed consensus standards.
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The IEEE standard does not contain
specifications or test methods for
electrical protective equipment. Instead,
that consensus standard contains work
methods for live-line work, including
criteria for evaluating insulating tools
and equipment. The Agency notes that
the criteria for evaluating insulating
tools and equipment specified in the
IEEE standard are equivalent to the
design criteria for electrical protective
equipment contained in paragraph (b) in
the final rule.
Paragraph (b)(1), which is being
adopted without substantive change
from the proposed rule, requires
electrical protective equipment to be
capable of withstanding any voltage that
might be imposed on it. The voltage that
the equipment must withstand includes
transient overvoltages, as well as the
nominal voltage that is present on an
energized part of an electric circuit.
Equipment withstands a voltage if it
maintains its integrity without flashover
or arc through.
Equipment conforming to a national
consensus standard for that type of
equipment will generally be considered
as complying with this rule if that
standard contains proof testing
requirements for the voltage involved.
In the proposal, OSHA considered
accepting electrical protective
equipment that was capable of passing
a test equivalent to that described in
ASTM F712 or IEEE Std 516 for types
of equipment not addressed by any
consensus standard. OSHA invited
comments on whether these standards
contain suitable test methods and
whether equipment passing those tests
should be acceptable under the OSHA
standard.
Rulemaking participants generally
agreed that the consensus standards
provide suitable guidance for the
equipment they addressed. (See, for
example, Exs. 0162, 0230.) For instance,
IBEW stated:
The test methods referenced in these
standards are suitable for the types of
equipment they are designed for . . . [This]
equipment [has] proven to be acceptable for
use in this industry. [Ex. 0230]
Mr. Steven Theis of MYR Group agreed
that the ‘‘specified standards contain
suitable test methods’’ (Ex. 0162).
As noted previously, OSHA has
reviewed ASTM F712–06 (2011) and
found that it provides suitable guidance
for compliance with final paragraph (b).
The Agency has included a note in the
final rule to indicate that plastic guard
equipment is deemed to conform to the
performance requirements of paragraph
(b) if the equipment conforms to that
consensus standard.
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ASTM maintained that none of the
ASTM standards listed in the proposed
standard contain an impulse test
method for transient overvoltages (Ex.
0148). The organization recommended
that the final rule reflect the current
referenced consensus standards.
ASTM misconstrues paragraph (b)(1)
of the final rule. Paragraph (b)(1) of the
final rule does not require impulse
testing as ASTM alleges. Rather, it is a
performance requirement that
equipment be capable of withstanding
both the steady-state voltages and
transient (or impulse) overvoltages, to
which it will be subjected. Both types of
voltages can appear across the
equipment during use. (See the
summary and explanation for final
§ 1926.960(c)(1), later in this section of
the preamble, for a discussion of
maximum transient overvoltages that
can appear on electric power lines and
equipment.)
The typical test method contained in
the ASTM standards for determining
minimum breakdown voltage (or
withstand voltage) requires testing at
substantially higher voltages than those
on which the equipment will be used.
(See, for example, Exs. 0048, 0053,
0071.) In addition, minimum
breakdown voltage testing is performed
using a steadily rising ac voltage, in
contrast to impulse testing, in which the
overvoltage is applied for a very short
period (id.). As noted in IEEE Std 516–
2009, the existing standards for
insulating tools and equipment do not
address whether equipment passing the
ac withstand voltage tests in those
standards will also withstand transient
voltage stresses (Ex. 0532). However, the
IEEE standard suggests the use of a 1.3
ratio to convert ac withstand voltages to
impulse, or transient, voltages (id.).
While the IEEE standard notes that
research in this area is ongoing, OSHA
concludes that, in the absence of better
information, employers may rely on this
ratio and multiply the ac minimum
breakdown voltage for protective
equipment by this value to determine if
that equipment can withstand the
expected transient overvoltages on
energized circuits. For example,
insulating equipment with a minimum
breakdown, or withstand, voltage of
20,000 volts is capable of withstanding
a maximum transient overvoltage of
26,000 volts. This equipment would be
acceptable for use to protect employees
from phase-to-ground exposures on a
circuit operating at 15-kilovolt, phase-
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to-phase, with a 3.0 per unit maximum
transient overvoltage.25
The Alabama Rural Electric
Association of Cooperatives, requested
that OSHA provide a definition of
‘‘transient overvoltage’’ and a suggested
method of calculation (Ex. 0224).
IEEE Std 516–2009 contains the
following suitable guidance (although,
as stated earlier, the standard does not
contain specifications or test methods
for electrical protective equipment).
First, the IEEE standard contains the
industry-recognized definition of
‘‘transient overvoltage,’’ which reads as
follows:
Voltage that exceeds the maximum
operating line-to-ground voltage. This voltage
may be the result of a transient or switching
surge. [Ex. 0532 26]
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Second, the IEEE consensus standard
contains methods of determining the
maximum transient overvoltage on an
electric power generation, transmission,
or distribution system and, as noted
earlier, discusses comparing the ability
of insulation equipment to withstand a
transient overvoltage based on its ability
to withstand voltages under more
typical testing conditions (Ex. 0532).
OSHA has not duplicated this
information in § 1926.97. It is
copyrighted information that is publicly
available. However, OSHA concludes
that the IEEE standard provides suitable
guidance that can assist employers in
complying with paragraph (b)(1) and
has added a reference to that consensus
standard in the note following that
paragraph in the final rule.
The proposed rule invited comments
on the need to set specific electrical
performance values in the standard and
on whether the electrical test criteria in
ASTM F968 27 (which were summarized
in Table IV–1 and Table IV–2 of the
preamble to the proposal (70 FR 34830))
could be applied to all types of
electrical protective equipment covered
by proposed paragraph (b). IBEW
commented that the test values and use
values in ASTM F968 are appropriate
for electrically insulating plastic guard
25 The maximum impulse voltage for this
equipment is 20 kilovolts times 1.3, or 26 kilovolts.
The maximum phase-to-ground use voltage for the
equipment is 26 kilovolts divided by the maximum
transient overvoltage in kilovolts, or 8.7 kilovolts.
The phase-to-phase circuit voltage for this exposure
is 8.7 kilovolts times √3, or 15 kilovolts.
26 This is the definition of ‘‘overvoltage,’’ for
which ‘‘transient overvoltage’’ is a synonym.
27 The proposal noted that there were two ASTM
standards addressing plastic guard equipment,
F712, which contained test methods, and F968,
which contained specifications (70 FR 34829–
34830, June 15, 2005). ASTM has since combined
those two standards into a single one, F712–06
(2011), which contains both test methods and
specifications for plastic guard equipment.
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equipment, but suggested that the
values are not suitable for other types of
equipment because plastic guard
equipment is designed to perform
differently than other types of electrical
protective equipment (Ex. 0230). Based
on the IBEW comment, OSHA has not
included in the final rule the values
from Table IV–1 and Table IV–2.
Moreover, since the final rule is written
in performance terms, inclusion of
values like those included in these
tables is unnecessary.
Final paragraph (b)(2) addresses the
properties of insulating equipment that
limit the amount of current to which an
employee is exposed. Paragraph
(b)(2)(i), which is being adopted without
change from the proposal, requires
electrical protective equipment used as
the primary insulation of employees
from energized parts to be capable of
passing a test for current (that is, a proof
test) when subjected to the highest
nominal voltage on which the
equipment is to be used. Paragraph
(b)(2)(ii), which is also being adopted as
proposed, provides that during the test,
the equipment current may not exceed
1 microampere per kilovolt of phase-tophase applied voltage. This requirement
will prevent dangerous electric shock to
employees by prohibiting use of both
poor insulating materials and good
insulating materials that are
contaminated with conductive
substances (for example, fiberglassreinforced plastic coated with a
conductive finish). The limit for current
has been derived from IEEE Std 516,
and OSHA believes such a limit is
reasonable and appropriate.
In the preamble to the proposed rule,
the Agency invited comments on
whether another value would better
protect employees. IBEW commented on
this issue as follows:
The IEEE Standard 516 limit of 1
microampere per kilovolt of phase-to-phase
applied voltage is appropriate for testing
equipment used for primary insulation of
employees from energized parts. This limit
has apparently worked to keep inferior
protective equipment of[f] the market. [Ex.
0230]
One commenter was concerned that
the proposed current limit might not
protect employees in the event that a
fault occurred (Ex. 0126). OSHA
believes that this concern is unfounded.
During a fault, the voltage on a circuit
typically falls, and the equipment
current would fall with it. Although it
is possible that transient overvoltages
may occur, either during a fault on an
adjacent phase or during switching
operations, such overvoltages are
extremely short in duration, and the
possible resulting increase in equipment
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current should not prove lifethreatening to employees.
ASTM stated that the only one of its
standards that includes a 1microampere per kilovolt requirement is
ASTM F712 on plastic guard equipment
(Ex. 0148). The organization
recommended that OSHA limit this
provision to this type of equipment.
OSHA is not adopting ASTM’s
recommendation. The Agency notes that
ASTM F712 is not the only ASTM
standard that limits equipment current
to values less than 1 microampere per
kilovolt of test voltage. ASTM F711,
Standard Specification for FiberglassReinforced Plastic (FRP) Rod and Tube
Used in Live Line Tools, limits
maximum current during the dielectric
testing prescribed in that standard to
values substantially less than 1
microampere per kilovolt of test voltage
(Ex. 0053).28 Further, as noted
previously, this limit has been derived
from IEEE Std 516. Thus, OSHA
concludes that the 1-microampere limit
is reasonable and appropriate.29
Note 1 to paragraph (b)(2), which is
being adopted without substantive
change from the proposal, emphasizes
that this paragraph applies to equipment
that provides primary insulation from
energized parts, which is consistent
with the plain language of paragraph
(b)(2)(i). The note also clarifies that
paragraph (b)(2) does not apply to
equipment used for secondary
insulation or equipment used for brush
contact only. OSHA considers primary
insulation to be the insulation that is
placed directly between an employee
and an energized part or, for live-line
barehand work, between an employee
and ground. Insulation that
supplements the primary insulation, for
example, a second form of insulation
placed between the employee and
ground (in addition to the primary
insulation), is secondary insulation.
Note 2 to paragraph (b)(2), which is
being adopted without change from the
proposal, provides that when equipment
is tested with ac voltage, the current
measured during the test consists of
three components: (1) Capacitive
28 Table 2 in ASTM F711–02 sets maximum
leakage current for different types of rod and tube
used in live-line tools (Ex. 0053). The highest value
in this table is 14 microamperes. A note to the table
provides that, for special applications, the
maximum acceptable leakage current is twice the
value listed in the table, so that 28 microamperes
is the highest acceptable leakage current. The
voltage applied during this test is 50 kilovolts.
Thus, the maximum current is less than 1
microampere per kilovolt.
29 It should be noted that the equipment current
requirement contained in paragraph (b)(2) does not
apply to rubber insulating equipment, which is
covered by paragraph (a).
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current caused by the dielectric
properties of the equipment being
tested, (2) conduction current through
the equipment, and (3) leakage current
passing along the surface of the
equipment. The conduction current is
negligible for materials typically used in
insulating equipment, and the leakage
current should be small for clean, dry
insulating equipment. The capacitive
component usually predominates when
insulating equipment is tested in good
condition.
OSHA expects that the tests required
under final paragraphs (b)(1) and (b)(2)
will normally be performed by the
manufacturer during the design process
and periodically during the
manufacturing process. The Agency
recognizes, however, that some
employers might want to use equipment
that is made of insulating materials but
that was not intended by the
manufacturer to be used as insulation.
For example, a barrier made of rigid
plastic may be intended for use as a
general purpose barrier. An employer
could test the barrier under paragraphs
(b)(1) and (b)(2), and, if the equipment
passes the tests, it would be acceptable
for use as insulating electrical protective
equipment.
Paragraph (c). Although existing
construction standards do not contain
provisions for the care and use of
insulating equipment, OSHA believes
provisions of this type can contribute
greatly to employee safety. Electrical
protective equipment is, in large part,
manufactured in accordance with the
latest ASTM standards. This would
probably be the case even in the absence
of OSHA regulation. However, improper
use and care of this equipment can
easily reduce, or even eliminate, the
protection afforded by this equipment.
Therefore, OSHA proposed to add new
requirements for the in-service care and
use of electrical protective equipment to
the design standards already contained
in existing § 1926.951(a)(1). These new
provisions are being adopted in the final
rule and will help ensure that these
safety products retain their insulating
properties.
Paragraph (c)(1), which is being
adopted without change from the
proposal, requires electrical protective
equipment to be maintained in a safe
and reliable condition. This general,
performance-oriented requirement,
which applies to all equipment
addressed by final § 1926.97, helps
ensure that employees are fully
protected from electric shock.
Detailed criteria for the use and care
of specific types of electrical protective
equipment are contained in the
following ASTM standards:
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ASTM F478–09, Standard Specification for
In-Service Care of Insulating Line Hose and
Covers.
ASTM F479–06 (2011), Standard
Specification for In-Service Care of
Insulating Blankets.
ASTM F496–08, Standard Specification for
In-Service Care of Insulating Gloves and
Sleeves.
The requirements in final paragraph
(c)(2) are derived from these standards.
Paragraph (c)(2) applies only to rubber
insulating blankets, covers, line hose,
gloves, and sleeves. No consensus
standards address the care and use of
other types of electrical protective
equipment. Whereas the material design
specifications for rubber insulating
matting is addressed in § 1926.97(a), the
in-service care of this matting is not
covered by any ASTM standard or by
existing § 1910.137(b)(2). This type of
equipment is generally permanently
installed to provide supplementary
protection against electric shock.
Employees stand on the matting, and
they are insulated from the floor, which
is one of the grounds present in the
work area. This provides a degree of
protection from phase-to-ground electric
shock. Because this type of equipment
is normally left in place after it is
installed, and because it is not relied on
for primary protection from electric
shock (the primary protection is
provided by other insulating equipment
or by insulating tools), it does not need
to be tested on a periodic basis and need
not be subject to the same careful
inspection before use that other
insulating equipment must receive. It
should be noted, however, that rubber
insulating matting is still required to be
maintained in a safe, reliable condition
under paragraph (c)(1).
In final paragraph (c)(2)(i) and Table
E–4, which are being adopted without
substantive change from the proposal,
OSHA is incorporating the margins of
safety recognized in the ASTM
standards by restricting the use of
insulating equipment to voltages lower
than the proof-test voltages given in
Table E–1 and Table E–2. The rubber
insulating equipment addressed in
§ 1926.97(a) is to be used at lower
voltages than the voltages the
equipment is designed to withstand. For
instance, although Class 4 equipment is
currently designed to be capable of
withstanding voltages of up to 40
kilovolts, the maximum use voltage for
such equipment is 36 kilovolts (see also,
for example, ASTM F496 on the care
and use of rubber insulating gloves and
sleeves). The use of insulating
equipment at voltages less than the
actual breakdown voltage provides a
margin of safety for the employee.
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The maximum use voltage for class 3
equipment in Table E–4 in the final rule
is being corrected to 26,500. OSHA
proposed that the maximum use voltage
for this class of equipment be 26,000.
OSHA intended this cell in the
proposed table to read 26,500, as it is in
Table I–5 in existing § 1910.137 and in
the applicable consensus standards, but
an inadvertent error in printing resulted
in the wrong number being entered in
the table.
In the proposed rule, Note 1 to Table
E–4 explained how the maximum use
voltage of electrical protective
equipment varies depending on whether
multiphase exposure exists. In the
general case, electrical protective
equipment must be rated for the full
phase-to-phase voltage of the lines or
equipment on which work is being
performed. This requirement ensures
that employees are protected against the
most severe possible exposure, that is,
contact between one phase conductor
and another. However, if the employee
is only exposed to phase-to-ground
voltage, then the electrical protective
equipment selected can be based on this
lower voltage level (nominally, the
phase-to-phase voltage divided by √3).
For example, a three-phase, solidly
grounded, Y-connected overhead
distribution system could be run as
three phase conductors with a neutral or
as three single-phase circuits with one
phase conductor and a neutral each. If
only one phase conductor is present on
a pole, there is no multiphase exposure.
If all three phase conductors are present,
the multiphase exposure can be
removed by insulating two of the phases
or by isolating two of the phases.30 After
the insulation is in place or while the
employee is isolated from the other two
phase conductors, there is no
multiphase exposure, and electrical
protective equipment rated for the
phase-to-ground voltage could be
used.31
In the proposal, the Agency requested
information about whether employees
can be insulated or isolated from
multiphase exposure to ensure safe use
of electrical protective equipment. The
30 Depending on the configuration of the system,
an employee could be isolated from two of the
phases on the pole by approaching one of the
outside phase conductors and working on it from
a position where there is no possibility of coming
too close to the other two phase conductors.
Isolation of the employee may be impossible for
some line configurations.
31 It should be noted that, until the multiphase
exposure has actually been removed, the phase-tophase voltage remains the maximum use voltage.
Thus, the maximum use voltage of any insulation
used to ‘‘remove phase-to-phase exposure’’ must be
greater than or equal to the phase-to-phase voltage
on the system.
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comments generally supported the note
to proposed Table E–4 and previously
codified in Table I–5 in existing
§ 1910.137. (See, for example, Exs. 0155,
0175, 0177, 0227.) Mr. Charles Kelly of
EEI explained:
[T]he typical practice in the industry is for
employees to cover the first phase from a
position where the other phases cannot be
reached. This practice isolates employees
from multiphase exposure. Thus, the use of
phase-to-ground voltage-rated equipment is
safe.
Many utilities use a class of equipment
which is rated for the phase to ground
voltage and rely on isolation and, to a lesser
extent, cover-up equipment, to remove the
potential for a multiphase exposure.
Multiphase exposure is always avoided
regardless of whether protective equipment
(gloves or gloves and sleeves) is rated for the
phase to phase voltage. Outside of rubber
blankets, cover-up equipment is considered
secondary protection against brush contact.
Isolation from phases different than the one
being worked on has always and will
continue to be the primary form of defense
against a phase to phase contact. The
administrative control of cover on the way in
and uncover on the way out ensures the
cover-up equipment is placed from a position
which isolates the worker. A worker will
always cover the first phase from a position
where he cannot reach the other
phases. . . .
The terminology for maximum use voltage
in ASTM F–819 has always recognized this
work practice: Thus, the ability to use phase
to ground voltage rated equipment is
considered by the industry to be both
prudent and safe. [Ex. 0227; emphasis
included in original]
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Mr. Thomas Taylor of Consumers
Energy agreed that these practices
isolate employees from multiphase
exposure so that using equipment based
on the phase-to-ground voltage is safe
(Ex. 0177). Ms. Salud Layton of the
Virginia, Maryland & Delaware
Association of Electric Cooperatives
similarly believed that using isolating
work practices can minimize employee
exposure. She stated that, while
‘‘isolation or insulation of the employee
from differing potentials in the work
zone is limited to the ability of the
insulating equipment to cover exposed
parts,’’ work practices can greatly
minimize employee exposure (Ex.
0175).
IBEW did not specifically object to the
language in the note to proposed Table
E–4, but cautioned:
To ensure a worker is isolated from contact
to an energized circuit, the isolating device
has to physically prohibit the worker from
making contact, and the device has to
maintain the electrical integrity of the
energized circuit. Although the isolating
device does not need to be permanent, the
device should have the physical strength to
ensure isolation in the case of a slip or fall,
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and other types of unintentional movements.
[Ex. 0230]
The union also maintained that ‘‘the
insulating value of the equipment
would have to be . . . rated at the
phase-to-phase voltage of the circuit
being worked’’ (id.).
Another commenter, however,
objected to the preamble statements that
permitted using phase-to-ground rated
insulation, stating: ‘‘Industry practice
has always been to use protective
equipment rated for the phase-to-phase
rms voltage’’ (Ex. 0184).
After considering the rulemaking
record on this issue, OSHA concludes
that the note to proposed Table E–4 is
necessary and appropriate and has
carried it forward into the final rule
without substantive change. The
comments broadly supported the
proposed note. In addition, the note is
identical to Note 1 to Table I–5 of
existing § 1910.137. As observed by the
commenters, when multiphase exposure
has been removed, by either isolating or
insulating the employee, the worker is
adequately protected against electric
shock from the remaining phase-toground exposure by using phase-toground rated electrical protective
equipment. The extent to which the
note was supported contradicts the
comment that industry practice is to use
phase-to-phase rated electrical
protective equipment. To address
IBEW’s concerns, OSHA emphasizes
that any insulation used to remove
multiphase exposure must adequately
protect workers carrying out their tasks
from factors that could negate the
insulation’s purpose. These factors
include, among other things, worker
movements such as reaching for tools,
adjusting clothing or personal protective
equipment, and slips and falls. Finally,
OSHA agrees with IBEW that insulation
used to protect employees from phaseto-phase exposure must be rated for the
phase-to-phase exposure. After all, until
this protective equipment is installed,
there is phase-to-phase exposure.
Paragraph (c)(2)(ii), which is being
adopted substantially as proposed,
requires insulating equipment to be
visually inspected before use each day
and immediately after any incident that
can reasonably be suspected of causing
damage. In this way, obvious defects
can be detected before an accident
occurs. Possible damage-causing
incidents include exposure to corona
and direct physical damage.
Additionally, rubber gloves must be
subjected to an air test, along with the
visual inspection. In the field, this test
usually consists of rolling the cuff
towards the palm so that air is
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entrapped within the glove. In a testing
facility, a mechanical inflater is
typically used. In either case, punctures
and cuts can easily be detected. The
note following paragraph (c)(2)(ii)
indicates that ASTM F1236–96 (2012),
Standard Guide for Visual Inspection of
Electrical Protective Rubber Products,
contains information on how to inspect
rubber insulating equipment and
descriptions and photographs of
potential irregularities in the
equipment.
Electrical protective equipment could
become damaged during use and lose
some of its insulating value. Final
paragraph (c)(2)(iii), which is being
adopted without substantive change
from the proposal, lists types of damage
that cause the insulating value of rubber
insulating equipment to drop, for
example, a hole, tear, puncture, or cut,
or an embedded foreign object. The
equipment may not be used if any of the
defects listed here or in paragraph
(c)(2)(iii), or any other defect that
damages its insulating properties, is
present.
Defects other than those listed in
paragraph (c)(2)(iii) might develop
during use of the equipment and could
also affect the insulating or mechanical
properties of the equipment. If such
defects are found, paragraph (c)(2)(iv),
which is being adopted without change
from the proposal, requires the
equipment to be removed from service
and tested in accordance with other
requirements in paragraph (c)(2). The
results of the tests will determine if it
is safe to return the items to service.
Foreign substances on the surface of
rubber insulating equipment can
degrade the material and lead to damage
to the insulation. Paragraph (c)(2)(v),
which is being adopted as proposed,
requires the equipment to be cleaned as
needed to remove any foreign
substances.
Over time, certain environmental
conditions can also cause deterioration
of rubber insulating equipment. Final
paragraph (c)(2)(vi), which is being
adopted without substantive change
from the proposal, requires insulating
equipment to be stored so that it is
protected from damaging conditions and
substances, such as light, temperature
extremes, excessive humidity, and
ozone. This requirement helps the
equipment retain its insulating
properties as it ages. OSHA has replaced
the proposed term ‘‘injurious substances
and conditions’’ with ‘‘damaging
substances and conditions’’ to make it
clear that the equipment must be
protected from substances and
conditions that might damage it rather
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than substances and conditions that
could injure workers.
In connection with this requirement,
the Agency does not believe that it is
safe to store equipment on trucks for
extended periods between use if such
storage would expose the equipment to
extremes of temperature or humidity. It
may be necessary, under some
circumstances, to store equipment
indoors during prolonged periods when
employees are not using the equipment.
Workers are dependent upon electrical
protective equipment for their safety,
and all reasonable means of protecting
it from unnecessary damage must be
employed.
Rubber insulating gloves are
particularly sensitive to physical
damage during use. Through handling
conductors and other electrical
equipment, an employee can damage
the gloves and lose the protection they
provide. For example, a sharp point on
the end of a conductor could puncture
the rubber. To protect against damage,
protector gloves (made of leather) are
worn over the rubber gloves. Paragraph
(c)(2)(vii) recognizes the extra protection
afforded by leather gloves and requires
their use over rubber gloves, except
under limited conditions.
Proposed paragraph (c)(2)(vii)(A)
provided that protector gloves are not
required with Class 0 or Class 00 gloves
under limited-use conditions, that is,
when unusually high finger dexterity is
needed for small equipment and parts
manipulation. This exception is
necessary to allow work to be performed
on small energized parts. The Agency is
adopting the proposed provision with
one revision. Under paragraph (c)(2)(i)
and Table E–4, which are being adopted
without substantive change from the
proposal, the maximum voltage on
which Class 0 and Class 00 gloves can
be used is 1,000 volts and 500 volts,
respectively. Mr. James A Thomas,
President of ASTM International,
pointed out that Section 8.7.4 of ASTM
F496 restricts the use of Class 00 rubber
insulating gloves to voltages of 250
volts, ac, or less when they are used
without protectors (Ex. 0148). Moreover,
the consensus standard also includes a
maximum dc voltage for Class 00 gloves
used without protectors. Section 8.7.4 of
ASTM F496–02a, Standard
Specification for In-Service Care of
Insulating Gloves and Sleeves, states:
Protector gloves may be omitted for Class
0 gloves, under limited use conditions, where
small equipment and parts manipulation
require unusually good finger dexterity.
Under the same conditions, Class 00 gloves
may be used without protectors, but only at
voltages up to and including 250 V a-c or 375
V d-c. Other classes of gloves may be used
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without protector gloves for similar
conditions only where the possibility of
physical damage to the gloves is unlikely and
provided the voltage class of the glove used
is one class above the voltage exposure.
Rubber insulating gloves that have been used
without protectors shall not be used with
protectors until given an inspection and
electrical retest. [Ex. 0051]
Based on Section 8.7.4 of ASTM
F496–02a, the Agency concludes that
using Class 00 gloves without protectors
on voltages above 250 volts, ac, or 375
volts, dc, is considered to be unsafe by
the experts on the consensus standards
committee.32 In the final rule, OSHA
has therefore included a new paragraph
(c)(2)(vii)(B) addressing the use of Class
00 gloves and incorporating these two
voltage restrictions on the use of Class
00 gloves without protectors.
Consequently, OSHA renumbered
proposed paragraphs (c)(2)(vii)(B) and
(c)(2)(vii)(C) as paragraphs (c)(2)(vii)(C)
and (c)(2)(vii)(D), respectively, and is
adopting them without substantive
change.
As noted earlier, if protector gloves
are not worn, there is a danger a sharp
object could puncture the rubber. The
resulting hole could endanger
employees handling live parts because
of the possibility that current could arc
through the hole to the employee’s hand
or that leakage could develop and
expose the employee to electric shock.
At 250 volts, ac, or less, or 375 volts, dc,
or less, for Class 00 gloves, and at 1,000
volts or less for Class 0 gloves, the
danger of current passing through a hole
is low, and an employee is protected
against electric shock as long as the live
part itself does not puncture the rubber
and contact the employee’s hand (59 FR
4328). Although the type of small parts,
such as small nuts and washers,
encountered in work covered by the
exception are not likely to do this, the
danger still exists (id.). OSHA, therefore,
is adopting, without substantive change
from the proposal, a note to final
paragraph (c)(2)(vii)(A) that provides
that persons inspecting rubber
insulating gloves used under these
conditions need to take extra care in
visually examining them and that
employees using the gloves under these
conditions need to take extra care to
avoid handling sharp objects.
Under paragraph (c)(2)(vii)(C), classes
of rubber insulating gloves other than
Class 0 and Class 00 may be used
without protector gloves only if: (1) The
employer can demonstrate that the
possibility for physical damage to the
glove is small, and (2) gloves at least one
32 ASTM
F496–08 contains an identical
requirement in Section 8.7.4.
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class higher than required for the
voltage are used. For example, if a Class
2 glove is used at 7,500 volts or less (the
maximum use voltage for Class 1
equipment pursuant to Table E–4) and
the employer can demonstrate that the
possibility of damage is low, then
protector gloves need not be used. The
final rule ensures that, under the
conditions imposed by the exception,
damage is unlikely, and the rule further
reduces the risk to the employee by
requiring thicker insulation as a
measure of extra physical protection
that will better resist puncture during
use.33 In addition, the consensus
standard permits these classes of rubber
insulating gloves to be used without
protectors under the same conditions
(Ex. 0051). This exception does not
apply when the possibility of damage is
significant, such as when an employee
is using a knife to trim insulation from
a conductor or when an employee has
to handle moving parts, such as
conductors being pulled into place.
Mr. Brockman with Farmers Rural
Electric Cooperative Corporation
recommended, without explanation,
that there should be no exception
permitting the use of rubber insulating
gloves above Class 0 without protectors
(Ex. 0173).
The Agency rejects this
recommendation. OSHA has explained
that it is safe to use Class 1 and higher
rubber insulating gloves without
protectors under the conditions
imposed by final paragraph
(c)(2)(vii)(C). OSHA notes, however, that
electric power generation, transmission,
and distribution work covered by
§ 1910.269 and subpart V will nearly
always pose a substantial probability of
physical damage to rubber insulating
gloves worn without protectors. Thus,
the exception contained in paragraph
(c)(2)(vii)(C) will rarely apply when
rubber insulating gloves are used for
that type of work. However, electrical
protective equipment covered by
§ 1926.97 is used outside of electric
power generation, transmission, and
distribution work, and there may be rare
cases in these other types of work, for
example, in product manufacturing or
testing laboratories, in which the
possibility of damage is slight.
To ensure that no loss of insulation
has occurred, paragraph (c)(2)(vii)(D)
prohibits any rubber insulating gloves
used without protector gloves from
being reused until the rubber gloves
have been tested in accordance with
paragraphs (c)(2)(viii) and (c)(2)(ix),
33 The thickness of the rubber increases with
increasing class of rubber insulating glove (for
example, from Class 0 to Class 1).
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which address required test voltages
and the adequacy of the test method,
respectively. It should be noted that this
testing is required regardless of whether
the glove is Class 0 or 00, as permitted
in paragraphs (c)(2)(vii)(A) and
(c)(2)(vii)(B), or is Class 1 or higher, as
permitted in paragraph (c)(2)(vii)(C).
The National Electrical Contractors
Association (NECA) and several NECA
chapters objected to the requirement to
test rubber insulating gloves after use
without protectors. (See, for example,
Exs. 0127, 0171, 0172, 0188.) They
argued that there was no safety benefit
and that the increased frequency of
testing would be a burden on
employers. For example, NECA stated:
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The preamble doesn’t include any
information on electrical injuries resulting
from the failure of insulated gloves used
without leather protectors. Thus, requiring
insulating gloves to be retested after each use
without a protector is a burden upon the
employer without offering any additional
safety to employees. When using gloves in
Classes 1–4, protectors often must be
removed for reasons of manual dexterity, but
the parts being worked on are fairly large
which minimizes the likelihood for damage.
Current techniques of inspecting and airtesting insulating gloves are sufficient to
identify damaged gloves. [Ex. 0171]
Another commenter, Mr. Tom
Chappell of the Southern Company,
argued that an accelerated testing
schedule (every 90 days instead of every
6 months) should be an acceptable
alternative to testing each time a rubber
insulating glove is used without a
protector (Ex. 0212).
OSHA disagrees with these
objections. First, the consensus standard
also contains this requirement, which
indicates that the consensus of expert
opinion considers that the requirement
provides necessary additional safety to
employees (Ex. 0051). Second, a visual
inspection and air test may not detect
minor damage that a voltage test will.
Even Mr. Chappell believes that
additional testing is required to
supplement the visual inspection.
Third, testing on an accelerated
schedule would allow such damage to
go undetected until the next test, which
could be as long as 89 days under Mr.
Chappell’s recommended testing
regimen. Fourth, OSHA believes that the
requirement to test rubber insulating
gloves used without protectors will
strongly discourage any unnecessary use
of the gloves without protectors because
of the expense of the test and because
testing gloves shortens their useful life.
Finally, any additional burden on
employers is insubstantial, as employers
are already required to do much of the
testing specified by the final rule. In
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addition, existing
§ 1910.137(b)(2)(vii)(B) already requires
gloves used without protectors to be
tested before being used at a higher
voltage.34 Therefore, OSHA has carried
forward proposed paragraph
(c)(2)(vii)(C) into the final rule without
change.
Paragraph (c)(2)(viii), which is being
adopted as proposed, requires insulating
equipment to be tested periodically at
the test voltages and testing intervals
specified in Table E–4 and Table E–5,
respectively. These tests will verify that
electrical protective equipment retains
its insulating properties over time. Table
E–4 lists the retest voltages that are
required for the various classes of
protective equipment, and Table E–5
presents the testing intervals for the
different types of equipment. These test
voltages and intervals were derived
from the relevant ASTM standards.
Mr. Thomas Frank of Ameren
Company objected to the inclusion of
rubber insulating line hose in proposed
Table E–4 and Table E–5 (Ex. 0209). He
argued that the applicable consensus
standard does not designate a test
method for this equipment.
OSHA disagrees with this objection.
Contrary to Mr. Frank’s assertion, ASTM
D1050, Standard Specification for
Rubber Insulating Line Hose, does
contain test methods for rubber
insulating line hose (Ex. 0068).35 Table
E–5, which specifies test intervals for
rubber insulating equipment, only
requires testing of line hose either when
the insulating value is suspect 36 or after
repair. In these cases, testing is the only
way of ensuring that the insulating
properties of the equipment are at an
acceptable level (id.). After all,
paragraph (a)(2)(i) requires rubber
insulating equipment to be capable of
passing electrical tests. When the
insulating value of the equipment is
suspect, or when the equipment has
been altered, as it will have been during
any repair, there is simply no way other
than testing to determine whether the
34 Existing § 1910.137(b)(2)(vii)(B) only requires
gloves to be tested before being used on a higher
voltage. The final rule adopts the proposed revision
to this requirement so that rubber insulating gloves
used without protectors must be tested before reuse
after any use without protector gloves. For the
purposes of §§ 1926.97(c)(2)(vii)(D) and
1910.137(c)(2)(vii)(D), ‘‘reuse’’ means any use after
the limited use permitted without protector gloves.
35 Both the 1990 edition of ASTM D1050
referenced in the note to existing
§ 1910.137(b)(2)(ix) and the 2005 edition referenced
in the note to final § 1926.97(c)(2)(ix) contain test
methods for rubber insulating line hose.
36 The insulating value of rubber insulating
equipment is suspect when the inspection required
by final paragraph (c)(2)(ii) leads to questions about
the quality of the insulation or uncovers any
damage to the insulating equipment.
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equipment retains the required
insulating value. Therefore, OSHA has
carried proposed Table E–4 and Table
E–5 into the final rule without
substantive change.
Paragraph (c)(2)(ix), which is being
adopted without change from the
proposal, establishes a performanceoriented requirement that the method
used for the tests required by paragraphs
(c)(2)(viii) and (c)(2)(xi) (the periodic
and postrepair tests, respectively) give a
reliable indication of whether the
electrical protective equipment can
withstand the voltages involved. As this
is a performance-oriented standard,
OSHA does not spell out detailed
procedures for the required tests, which
will obviously vary depending on the
type of equipment being tested.
Following paragraph (c)(2)(ix) is a
note stating that the electrical test
methods in various listed ASTM
standards on rubber insulating
equipment will be deemed to meet the
performance requirement. As mentioned
earlier, this note does not mean that
OSHA is adopting the listed ASTM
standards by reference. In enforcing
§ 1926.97(c)(2)(ix), the Agency will
accept any test method that meets the
performance criteria of the OSHA
standard.
Once equipment has undergone inservice inspections and tests, it is
important to ensure that any failed
equipment is not returned to service.
Final paragraph (c)(2)(x), which is being
adopted without change from the
proposal, prohibits the use of electrical
protective equipment that failed the
required inspections and tests.
Paragraph (c)(2)(x) does, however, list
the following acceptable means of
eliminating defects and rendering the
equipment fit for use again.
The final standard permits defective
portions of rubber line hose and
blankets to be removed in some cases.
The result would be a smaller blanket or
a shorter length of line hose. Under the
standard, Class 1, 2, 3, and 4 rubber
insulating blankets may only be
salvaged by severing the defective
portions of the blanket if the resulting
undamaged area is at least 560
millimeters by 560 millimeters (22
inches by 22 inches). For these classes,
smaller sizes cannot be reliably tested
using standard test methods. Although
the standard does not restrict the size of
Class 0 blankets, OSHA believes that
practical considerations in testing and
using Class 0 blankets will force
employers to similarly limit the size of
these blankets when they have been
repaired by cutting out a damaged
portion.
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Obviously, gloves and sleeves cannot
be repaired by removing a defective
portion; however, the final standard
permits patching rubber insulating
gloves and sleeves if the defects are
minor. Blankets may also be patched
under certain circumstances. Moreover,
rubber insulating gloves and sleeves
with minor surface blemishes may be
repaired with a compatible liquid
compound. In all cases (that is, whether
a patch is applied or a liquid compound
is employed), the repaired area must
have electrical and physical properties
equal to those of the material being
repaired.
Repairs performed in accordance with
the standard are unlikely to fail because
the rule requires the use of compatible
patches or compatible liquid
compounds and requires the repaired
area to have electrical and physical
properties equal to those of the
surrounding material. However, to
minimize the possibility that glove
repairs will fail, repairs to rubber
insulating gloves outside the gauntlet
area (that is, the area between the wrist
and the reinforced edge of the opening)
are not allowed. OSHA stresses that the
final rule does not permit repairs in the
working area of the glove, where the
constant flexing of the rubber during the
course of work could loosen an illformed patch. A failure of a patch or
liquid compound in this area of the
glove would likely lead to injury very
quickly. On the other hand, the gauntlet
area of rubber insulating gloves is not
usually in direct contact with energized
parts. If a patch fails in this area, a
worker is much less likely to be injured.
Farmers Rural Electric Cooperative
Corporation recommended, without
explanation, that OSHA not permit
patching of rubber insulating gloves and
sleeves (Ex. 0173). OSHA rejects this
recommendation. OSHA has explained
that it is safe only to patch insulating
gloves and sleeves under the conditions
imposed by final paragraph (c)(2)(x)(D).
Once the insulating equipment has
been repaired, it must be retested to
ensure that any patches are effective and
that there are no other defects present.
Such retests are required under
paragraph (c)(2)(xi), which is being
adopted without change from the
proposal.
Employers, employees, and OSHA
compliance staff must have a method of
determining whether the tests required
under this section have been performed.
Paragraph (c)(2)(xii) requires this
determination to be accomplished by
means of certification by the employer
that equipment has been tested in
accordance with the standard. The
certification is required to identify the
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equipment that passed the test and the
date it was tested. Typical means of
meeting this requirement include logs
and stamping test dates on the
equipment. A note following paragraph
(c)(2)(xii) explains that these means of
certification are acceptable. As
explained under the summary and
explanation for paragraph (a)(1)(ii)
earlier in this section of the preamble,
the final rule, unlike the proposal,
includes an explicit requirement that
employers make this certification
available upon request to employees
and their authorized representatives.
OSHA has also clarified the requirement
to indicate that the certification records
must be made available upon request to
the Assistant Secretary for Occupational
Safety and Health.
B. Subpart V, Electric Power
Transmission and Distribution
OSHA is revising subpart V of its
construction standards. This subpart
contains requirements designed to
prevent deaths and other injuries to
employees performing construction
work on electric power transmission
and distribution installations. OSHA
based the revision of subpart V
primarily on the general industry
standard at § 1910.269, Electric power
generation, transmission, and
distribution, which the Agency
promulgated in January 1994. The final
standard revises the title of subpart V
from ‘‘Power Transmission and
Distribution’’ to ‘‘Electric Power
Transmission and Distribution’’ to make
it clear that the subpart addresses
‘‘electric’’ power transmission and
distribution (and not mechanical power
transmission) and to match the title of
§ 1910.269 more closely.
1. Section 1926.950, General
Section 1926.950 defines the scope of
final subpart V and includes, among
other provisions, general requirements
for training and the determination of
existing workplace conditions.
Paragraph (a)(1)(i) of final § 1926.950 is
adopted without change from proposed
§ 1926.950(a)(1) and sets the scope of
revised subpart V. This paragraph has
been taken largely from existing
§ 1926.950(a) and (a)(1). Subpart V
applies to the construction of electric
power transmission and distribution
installations. In accordance with
existing § 1926.950(a)(1) and
§ 1910.12(d), paragraph (a)(1)(i) of final
§ 1926.950 provides that ‘‘construction’’
includes the erection of new electric
transmission and distribution lines and
equipment, and the alteration,
conversion, and improvement of
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20337
existing electric transmission and
distribution lines and equipment.
As noted in Section II, Background,
earlier in this preamble, rulemaking
participants generally supported
OSHA’s goal of providing consistency
between § 1910.269 and subpart V.
However, many commenters urged the
Agency to combine § 1910.269 and
subpart V into a single standard
applicable to all electric power
generation, transmission, and
distribution work. (See, for example,
Exs. 0099, 0125, 0127, 0146, 0149, 0151,
0152, 0153, 0156, 0159, 0161, 0164,
0172, 0175, 0179, 0180, 0183, 0186,
0188, 0202, 0206, 0225, 0226, 0229,
0231, 0233, 0239, 0241, 0401; Tr. 291–
294, 542–543, 1235–1236, 1282–1283,
1322, 1332.) These rulemaking
participants argued that several benefits
would result from combining § 1910.269
and subpart V into a single standard,
including:
• Lessening confusion—a single
standard would eliminate questions
about whether work is construction or
maintenance and ensure uniform
interpretations for all generation,
transmission, and distribution work
(see, for example, Exs. 0146, 0151, 0152,
0156, 0175, 0183, 0202, 0233);
• Facilitating compliance and
reducing costs—under a single standard,
employers would be able to train
workers in a single set of rules rather
than one set for construction and
another set for maintenance (Tr. 293–
294); and
• Eliminating the need to maintain
and update two standards over time
(see, for example, Exs. 0127, 0149, 0152,
0179).
OSHA is rejecting these
recommendations to combine
§ 1910.269 and subpart V into a single
standard. First, OSHA does not believe
that employers will have to maintain
separate sets of rules for construction
and maintenance. Because the final rule
largely adopts identical requirements for
construction and maintenance, OSHA
expects that employers will be able to
fashion a single set of rules, consistent
with both § 1910.269 and subpart V, that
apply regardless of the type of work
being performed. In the final standard,
OSHA is adopting different rules in a
few cases, based on fundamental
differences between the other
construction standards in part 1926 and
the general industry standards in part
1910. For example, § 1910.269 and
subpart V reference the general industry
and construction standards on medical
services and first aid in §§ 1910.151 and
1926.50, respectively. These general
industry and construction standards set
slightly different requirements for
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medical services and first aid. Similarly,
§ 1910.269 and subpart V separately
reference the general industry and
construction standards on ladders. The
differences between the construction
and general industry standards that may
apply to electric power generation,
transmission, and distribution work go
well beyond the few examples described
here. It is beyond the reach of this
rulemaking to unify all of the different
general industry and construction
standards that apply to electric power
generation, transmission, and
distribution work. Consequently, any
employer that performs both general
industry and construction work will
need to ensure compliance with
applicable provisions in both part 1910
and part 1926. Even if OSHA were to
adopt one electric power generation,
transmission, and distribution standard,
employers would still be faced with
differences between other requirements
in the general industry and construction
standards.
Second, commenters’ concerns over
differences in language and
interpretation are largely unfounded. As
noted in the preamble to the proposal,
one of the primary goals of this
rulemaking is to make the requirements
for construction and maintenance
consistent with one another. The
Agency will take steps to ensure that
interpretations of identical requirements
in the two standards are the same.
Toward this end, the Agency is
including a note to final
§ 1926.950(a)(1)(i) to indicate that an
employer that complies with § 1910.269
generally will be considered in
compliance with the requirements in
subpart V. There is a minor exception
for provisions in subpart V that
incorporate by reference requirements
from other subparts of part 1926. For
those provisions of subpart V, the
employer must comply with the
referenced construction standards;
compliance with general industry
standards referenced in comparable
provisions of § 1910.269 will not be
sufficient. The new note to
§ 1926.950(a)(1) should allay the
concerns of commenters about
potentially inconsistent interpretations
of identical requirements in § 1910.269
and subpart V. The note should also
assure employers that they can adopt
uniform work practices for the
construction, operation, and
maintenance of electric power
generation, transmission, and
distribution installations with regard to
these requirements.
Ameren Corporation was concerned
that OSHA would ‘‘make significant and
costly changes to the current 1910.269
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standard without adequately providing
the opportunity for utilities to study and
comment on the impact to these
changes’’ (Ex. 0209). The company
requested that the Agency provide the
utility industry with an opportunity to
comment on any changes to existing
§ 1910.269 that were not identified in
the proposal.
OSHA does not believe additional
notice and opportunity for comment is
necessary for any of the revisions to
§ 1910.269 being made in this final rule.
In the preamble to the proposed rule,
the Agency stated:
OSHA expects that final Subpart V will
differ from proposed Subpart V because of
changes adopted based on the rulemaking
record. When the final rule is published, the
Agency intends to make corresponding
changes to § 1910.269 to keep the two rules
the same, except to the extent that substantial
differences between construction work and
general industry work warrant different
standards. [70 FR 34892]
The Agency met this objective in this
final rule. OSHA concludes that any
revisions to existing § 1910.269 adopted
in the final rule are based on the record
considered as a whole and are a logical
outgrowth of the rulemaking record.
Mr. Anthony Ahern with Ohio Rural
Electric Cooperatives recommended that
OSHA combine §§ 1910.137 and
1926.97, or simply reference § 1910.137,
instead of creating a new section on
electrical protective equipment in the
construction standards (Ex. 0186).
OSHA rejects this request. New
§ 1926.97 applies to all of construction,
not just electric power generation,
transmission, and distribution work.
Final § 1926.97 imposes no additional
burden on employers beyond what
would apply under § 1910.137.
Duplicating the § 1910.137 requirements
in part 1926 meets the needs of
construction employers and employees
for ready access to the protective
equipment standards that are applicable
to their work.
Ms. Salud Layton of the Virginia,
Maryland & Delaware Association of
Electric Cooperatives objected to the
word ‘‘improvement’’ in proposed
§ 1926.950(a)(1) (Ex. 0175). Ms. Layton
also expressed concern about a part of
the preamble to the proposed rule in
which OSHA used the term ‘‘repair’’ to
describe construction activities (id.).
She commented:
As defined in the regulation,
‘‘construction’’ includes ‘‘erection of new
transmission and distribution lines and
equipment, and the alteration, conversion,
and improvement of existing electric
transmission and distribution lines and
equipment.[’’] While ‘‘alteration’’ and
‘‘conversion’’ can be construed as
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construction activities, the term
‘‘improvement’’ is too broad. Many
maintenance activities are considered
improvements. Additionally, the preamble
uses the term ‘‘repair’’ in describing
construction activities. Repairs are typically
considered maintenance activities in our
industry, further complicating this issue. [id.]
OSHA considered Ms. Layton’s
comments, but decided to adhere to its
longstanding practice of treating
‘‘improvements’’ and ‘‘repairs’’ as
construction. The term ‘‘improvement’’
has been a part of the definition of
construction work under Subpart V for
decades. Furthermore, as noted earlier,
this definition is codified in 29 CFR
1910.12(d). In addition, removing the
term would have no practical effect on
the definition, as all improvements are
‘‘alterations,’’ a term to which she did
not object. OSHA has consistently
treated ‘‘repairs’’ as construction work
as well. See § 1910.12(b) (‘‘Construction
work means work for construction,
alteration, and/or repair. . . .’’). OSHA
recognizes that there may not always be
a clear distinction between construction
repair and general industry maintenance
and has provided clarification in
numerous letters of interpretation,
including the Agency’s Memorandum
for Regional Administrators dated
August 11, 1994.37 That memorandum
explains construction work as follows:
[C]onstruction work is not limited to new
construction. It includes the repair of existing
facilities. The replacement of structures and
their components is also considered
construction work.
*
*
*
*
*
There is no specified definition for
‘‘maintenance’’, nor a clear distinction
between terms such as ‘‘maintenance’’,
‘‘repair’’, or ‘‘refurbishment.’’ ‘‘Maintenance
activities’’ can be defined as making or
keeping a structure, fixture or foundation
(substrates) in proper condition in a routine,
scheduled, or anticipated fashion. This
definition implies ‘‘keeping equipment
working in its existing state, i.e., preventing
its failure or decline.’’ However, this
definition, (taken from the directive on
confined spaces) is not dispositive; and,
consequently, determinations of whether a
contractor is engaged in maintenance
operations rather than construction activities
must be made on a case-by-case basis, taking
into account all information available at a
particular site. [Emphasis included in
original.]
(See also, for example, letter to
Raymond Knobbs (Nov. 18, 2003) and
letter to Randall Tindell (Feb. 1,
1999).38) In addition, the Occupational
37 This document is available at https://www.osha.
gov/pls/oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=21569.
38 The Knobbs and Tindell letters are available at:
https://www.osha.gov/pls/oshaweb/owadisp.show_
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Safety and Health Review Commission
(OSHRC) has addressed this issue. (See,
for example, Gulf States Utilities Co., 12
BNA OSHC 1544 (No. 82–867, Nov. 20,
1985).) In any event, one of OSHA’s
primary objectives in this rulemaking is
to make § 1910.269 and subpart V more
consistent with each other. Therefore,
going forward, the distinction between
construction and maintenance will be of
much less significance to employers
covered by these standards. Even Ms.
Layton recognized that her concern
about the definition of construction was
only relevant ‘‘[i]f the regulations are
not the same’’ (Ex. 0175). The proposed
definition of ‘‘construction’’ in
§ 1926.950(a)(1) is, therefore, being
carried forward into the final rule
without change.
Mr. Kenneth Stoller of the American
Insurance Association inquired about
the applicability of the revised
standards to insurance industry
employees, stating:
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AIA is concerned that the new contractor
obligations contemplated by the proposal
with respect to training, reporting, recordkeeping and personal protective equipment
may unintentionally apply to insurance
industry employees, whose only obligation is
to inspect—but not work on—some of the
electrical equipment in question. While our
members are neither electrical utilities nor
electrical construction companies, some of
their commissioned inspectors are required
to visit and inspect equipment that is both
energized and open. In addition, some state
laws identify certain equipment (such as
pressure vessels) located within close
proximity to energized and open electrical
apparatus that must be inspected
periodically.
Subjecting insurers to these new
requirements would require individual
companies to spend tens of thousands of
dollars per year for additional training and
equipment, notwithstanding the fact that the
proposal’s preamble indicates that these
obligations should only apply to entities
performing maintenance and repairs, not
simply inspections. Accordingly, we
recommend that the proposal be amended to
explicitly exempt insurance industry
employees from any obligations it places on
contractors. [Ex. 0198]
OSHA considered this comment, but
will not be exempting insurance
industry employees from the final rule.
Existing § 1910.269 already covers
inspections of electric power generation,
transmission, and distribution
installations performed by insurance
company workers as work ‘‘directly
associated with’’ these installations. In
this regard, existing
document?p_table=INTERPRETATIONS&p_
id=24789 and https://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_
table=INTERPRETATIONS&p_id=22687,
respectively.
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§ 1910.269(a)(1)(i)(D) states that
‘‘[§ 1910.269 applies to:] (D) Work on or
directly associated with [electric power
generation, transmission, and
distribution and other covered]
installations. . . .’’ OSHA, therefore,
interprets existing § 1910.269(a)(1)(i)(D)
as applying to inspections conducted by
insurance company employees because
the purpose of these inspections is to
assure the safety of these installations
and employees working on or near
them. Insurance inspections are similar
to inspections conducted by electric
utilities and their contractors. The
preamble to the 1994 final rule adopting
§ 1910.269 specifically listed
‘‘inspection’’ as an activity covered by
that standard (59 FR 4333). Section
1910.269 applies to this type of work
without regard to the industry of the
employer that has employees
performing the inspections.39 Thus,
existing § 1910.269 covers this work as
it pertains to general industry and will
continue to cover this work after the
final rule becomes effective. However,
insurance inspections may fall under
subpart V, instead of § 1910.269, to the
extent the inspections are construction
work. Whether an insurance inspection
constitutes construction depends on the
characteristics of the work performed.
(See, for example, CH2M Hill, Inc. v.
Herman, 192 F.3d 711 (7th Cir. 1999).)
OSHA does not believe that the final
rule will impose substantial additional
costs on the insurance industry. Existing
§ 1910.269 currently covers the vast
majority of insurance inspections on
electric power installations. Of the new
provisions this final rule is adding to
§ 1910.269, the ones that impose the
greatest costs on all employers are
unlikely to impose significant economic
burdens on inspections conducted by
insurance industry workers. First, the
minimum approach distance and arcflash-protection requirements usually
will not apply to the insurance industry
because insurance industry inspectors
will almost never be qualified
employees (see final §§ 1910.269(l) and
1926.960).40
Second, the host-contractor
provisions in §§ 1910.269(a)(3) and
1926.950(c) should not impose
significant costs on the insurance
39 See the letter of interpretation dated June 9,
1999, to Mr. G. William Doody, which is available
at https://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_
table=INTERPRETATIONS&p_id=22749.
40 According to final § 1910.269(a)(1)(ii)(B),
§ 1910.269 does not apply to electrical safetyrelated work practices covered by Subpart S.
Subpart S applies to work performed by unqualified
persons on, near, or with electric power generation,
transmission, and distribution installations (see
§ 1910.331(b)).
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20339
industry. As explained in Section VI,
Final Economic Analysis and
Regulatory Flexibility Analysis, later in
this preamble, OSHA estimated the
costs of the host-contractor provisions
on a per-project basis; that is, employers
will incur costs once for each project.
OSHA believes that its estimate of the
number of projects fully accounts for
projects that involve inspections,
including insurance inspections, of
electric power generation, transmission,
and distribution installations, though
OSHA allocated the costs to contract
employers generally. OSHA anticipates
that the number of insurance
inspections will be a small fraction of
the number of overall projects. If 1 in
every 1,000 projects involves an
insurance inspection, then the total
costs related to employers’ complying
with the host-contractor provisions for
insurance inspections would be less
than $20,000 per year, half of which
host employers would bear. The Agency
deems such costs an inconsequential
portion of the overall costs of the final
rule and not significant for the
insurance industry.
Third, OSHA does not believe that
insurance inspections will typically
involve employees working from aerial
lifts or on poles, towers, or similar
structures covered by the personal
protective equipment requirements in
final §§ 1910.269(g)(2)(iv)(C) and
1926.954(b)(3)(iii). Mr. Stoller’s lone
example of work potentially affected by
the final rule, the inspection of pressure
vessels, is not generally covered by
those provisions, which primarily affect
work involving overhead transmission
and distribution lines. OSHA is
unaware of any other insurance
inspection work that would involve
employees working from aerial lifts or
on poles, towers, or similar structures.
Even if such inspections are taking
place, they should be rare, and the
Agency deems costs associated with
such inspections an inconsequential
portion of the overall costs of the final
rule, and inconsequential as well for the
insurance industry.
Paragraph (a)(1)(ii) of final § 1926.950
provides that subpart V does not apply
to electrical safety-related work
practices for unqualified employees.
Electrical safety-related work-practice
requirements for these employees are
contained in other subparts of part 1926,
including subparts K, N, and CC. For
example, § 1926.416(a)(1) in subpart K
prohibits employers from permitting an
employee to work in such proximity to
any part of an electric power circuit that
the employee could contact the electric
power circuit in the course of work,
unless the employee is protected against
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electric shock by deenergizing the
circuit and grounding it or by guarding
it effectively by insulation or other
means. Deenergizing circuits and
insulating them from employees
protects unqualified employees from
electric shock. By contrast, subpart V, in
final § 1926.960(b)(1)(i), permits only
qualified employees to work on or with
exposed energized lines or parts of
equipment. Final § 1926.960(c)(1)(iii)
requires the employer to ensure that no
employee approaches or takes any
conductive object closer to exposed
energized parts than the minimum
approach distances, established by the
employer under final § 1926.960(c)(1)(i),
unless the employee is insulated from
the energized part (for example, with
rubber insulating gloves and sleeves), or
the energized part is insulated from the
employee and from any other
conductive object at a different
potential, or the employee is performing
live-line barehand work in accordance
with § 1926.964(c).
Subpart CC generally requires
employers to ensure that employees
maintain minimum clearances when
operating cranes or derricks near
overhead power lines. Paragraph (a)(6)
of § 1926.600 also generally requires
minimum clearances when mechanical
equipment is operated near overhead
power lines. In part because subpart V
establishes requirements for qualified
employees operating mechanical
equipment, § 1926.959(d)(1) of this final
rule generally requires mechanical
equipment, including cranes and
derricks, to maintain minimum
approach distances that are significantly
less than the minimum clearance
distances in either § 1926.600(a)(6) or
subpart CC.
OSHA did not expressly propose to
exempt electrical safety-related work
practices used by unqualified
employees from subpart V; however, the
preamble to the proposal made it clear
that subpart V’s requirements did not
apply to electrical safety-related work
practices used by unqualified
employees. (See, for example, 70 FR
34857.) Specifically, the Agency stated:
‘‘The general approach taken in the
proposed revision of Subpart V is to
provide safety-related work practices for
qualified employees to follow when
they are performing electric power
transmission and distribution work.
Safe work practices for unqualified
employees are not addressed in
proposed Subpart V . . .’’ (70 FR
34857). Information in the record shows
that the requirements in subpart V are
not sufficiently protective for
unqualified employees. (See, for
example, Exs. 0077, 0134.) For example,
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NFPA 70E contains electrical safetyrelated work practice requirements to
protect unqualified employees from
electrical hazards posed by electric
power transmission and distribution
installations (Ex. 0134).41 The
consensus standard requires unqualified
employees to maintain minimum
approach distances that are
substantially greater than the minimum
approach distances in Subpart V.
OSHA designed subpart V to mirror
the requirements in § 1910.269. Existing
§ 1910.269(a)(1)(i)(A), which is being
adopted in the final rule without
substantive change, provides that
§ 1910.269 applies to ‘‘[p]ower
generation, transmission, and
distribution installations, including
related equipment for the purpose of
communication or metering, which are
accessible only to qualified employees.’’
Existing (and final)
§ 1910.269(a)(1)(ii)(B) explicitly
excludes ‘‘electrical safety-related work
practices . . . covered by subpart S of
this part’’ from coverage. According to
§ 1910.331(b), subpart S covers
electrical safety-related work practices
for unqualified employees working on,
near, or with installations for the
generation, transmission, or distribution
of electric energy. Thus, § 1910.269 does
not apply to electrical safety-related
work practices for unqualified
employees.
In conclusion, OSHA notes that the
electrical safety-related work practices
required by Subpart V do not provide
sufficient protection for unqualified
employees. Therefore, Subpart V does
not and should not cover such work
practices. The final rule, in
§ 1926.950(a)(1)(ii), expressly clarifies
that Subpart V does not cover electrical
safety-related work practices for
unqualified employees.
Paragraph (a)(2) of final § 1926.950,
which is being adopted without change
from the proposal, explains that subpart
V applies in addition to all other
applicable standards contained in part
1926. This paragraph also provides that
employers doing work covered by
subpart V are not exempt from
complying with other applicable
provisions in part 1926 by the operation
of § 1910.5(c). Paragraph (a)(2) also
clarifies that specific references in
subpart V to other sections of part 1926
are provided for emphasis only. In
accordance with this provision, all
construction industry standards
continue to apply to work covered by
subpart V unless there is an applicable
41 See NFPA 70E–2004, Section 110.1, which sets
the scope for Article 110, General Requirements for
Electrical Safety-Related Work Practices (Ex. 0134).
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exception in subpart V or elsewhere in
part 1926. For example, § 1926.959(a)(2)
requires the critical safety components
of mechanical elevating and rotating
equipment to be visually inspected
before each shift. This provision does
not supersede § 1926.1412(d), which
details specific requirements for the
visual inspection of cranes each shift by
a competent person. In a change that
OSHA considers nonsubstantive,
§ 1910.269(a)(1)(iii) is being amended to
include language equivalent to that in
§ 1926.950(a)(2).
Subpart V has never applied to work
on electric power generation
installations. Proposed § 1926.950(a)(3)
provided that § 1910.269 would cover
all work, including construction,
involving electric power generation
installations. In the preamble to the
proposal, the Agency explained that the
construction of an electric power
generation station normally poses only
general construction hazards, that is,
hazards not addressed by subpart V (70
FR 34833). OSHA recognized, however,
the following two exceptions to this
conclusion: (1) during the final phase of
construction of a generating station,
when electrical and other acceptance
testing of the installation is being
performed, and (2) during
‘‘reconstruction,’’ when portions of the
generating station not undergoing
construction are still in operation (id.).
In both of these scenarios, construction
work at a generation station exposes
workers to hazards akin to those posed
by the operation and maintenance of a
generation plant. Because the Agency
believed that these two operations were
more like general industry work than
construction, it deemed it appropriate
for employers to follow § 1910.269 in
those situations (id.). Rather than repeat
the relevant portions of § 1910.269 in
subpart V, OSHA proposed that
§ 1910.269 apply to all work involving
electric power generation installations.
The Agency requested comments on
whether § 1910.269 should apply to all
work involving electric power
generation installations, as proposed, or
whether instead the relevant
requirements from § 1910.269 should be
contained in final subpart V for
purposes of construction work involving
electric power generation installations.
OSHA received numerous responses to
this request. (See, for example, Exs.
0125, 0127, 0130, 0149, 0151, 0155,
0159, 0162, 0163, 0172, 0177, 0179,
0186, 0188, 0201, 0208, 0209, 0212,
0213, 0227, 0230.) Commenters largely
supported OSHA’s proposed approach
and the language making § 1910.269
applicable to all work involving electric
power generation installations. For
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example, Mason County Public Utility
District 3 commented: ‘‘We believe the
proposed language referencing 1910.269
for all work involving electric power
generation installations should be
adopted’’ (Ex. 0125). Siemens Power
Generation responded similarly,
explaining, ‘‘Subpart V should not
apply to the electric power generation
installations [because m]aintenance in
these installations is covered adequately
by 1910.269 and construction is covered
adequately by general construction
requirements’’ (Ex. 0163). In addition,
Mr. Tom Chappell of Southern
Company agreed with OSHA that
‘‘[a]pplying 1910.269 during the ‘final
phase of construction’ or ‘reconstruction
work’ would be preferable to recreating
the same requirements in Subpart V’’
(Ex. 0212).
On the other hand, NIOSH suggested
that it ‘‘would be less burdensome’’ for
employers if the relevant requirements
for construction at generation
installations were incorporated in
subpart V (Ex. 0130). In addition, MYR
Group was concerned that OSHA’s
proposed approach could lead to
confusion, explaining:
mstockstill on DSK4VPTVN1PROD with RULES2
[A]pplying part 1910 electrical standards
[to construction work involving generation
installations] would cause confusion as to
whether other applicable general industry or
construction standards would govern the
remaining aspects of such work. Thus,
OSHA’s proposal—based on an alleged
simplification—does itself create confusion.
[Ex. 0162]
OSHA considered these comments,
but does not believe that applying
§ 1910.269 to construction involving
generation installations is likely to
result in any heavy burdens or
confusion. OSHA’s construction
standards (29 CFR part 1926) apply to
general construction activities
performed at generation installation
sites. As previously explained,
§ 1910.269 generally will not apply to
the original construction of a generating
station until the final phase of
construction, when many of the
provisions in § 1910.269 become
applicable. For example, in the early
construction phases, the generation
installation would contain no energized
circuits, so the provisions for working
near energized parts in § 1910.269(l)
would not apply. Similarly, in the
construction of a coal-fired generating
station, the requirements in
§ 1910.269(v)(11) on coal handing
would have no application until coal is
present. To the extent an employer is
performing late-stage construction or
reconstruction of a generation
installation and § 1910.269 applies, the
provisions of § 1910.269 supplement,
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but do not replace, any relevant general
construction requirements. (See
§§ 1910.269(a)(1)(iii) and
1926.950(a)(2).) For example, the
training requirements in
§ 1910.269(a)(2) apply in addition to any
applicable training requirements in part
1926.42
With this additional clarification and
the support of most of the commenters
who provided feedback on this issue,
the Agency is adopting proposed
§ 1926.950(a)(3) as it relates to the
construction of electric power
generation installations.43
Another coverage issue raised in the
proposal relates to line-clearance tree
trimming, which is currently addressed
in § 1910.269.44 (See existing
§ 1910.269(a)(1)(i)(E).) As OSHA
explained in the preamble to the
proposal, line-clearance tree trimming is
not normally performed as part of the
construction of electric power
transmission or distribution
installations (70 FR 34833). One
exception occurs when trees are
trimmed along an existing overhead
power line to provide clearance for a
new transmission or distribution line
that is under construction (id.). While
this type of work by line-clearance tree
trimmers is properly classified as
construction work, it shares many
similarities with the work done by lineclearance tree trimmers that is properly
classified as general industry work.45
For this reason, as well as for ease of
compliance and enforcement, proposed
§ 1926.950(a)(3) provided that
§ 1910.269 would apply to all lineclearance tree-trimming operations,
42 Paragraph (e) of § 1910.269 contains
requirements for work in enclosed spaces. OSHA
recently proposed a standard covering confined
spaces in construction, which will cover many of
the same hazards. OSHA will consider how to
apply these new confined space provisions to the
construction of power generation installations in
the development and promulgation of that final
rule.
43 Current § 1910.269(a)(1)(ii)(A) provides that
§ 1910.269 does not apply to construction work. In
the final rule, OSHA is revising this paragraph to
indicate that § 1910.269 does not apply to
construction work, as defined in § 1910.12, except
for line-clearance tree-trimming operations and
work involving electric power generation
installations as specified in § 1926.950(a)(3). This
change makes the application of § 1910.269
consistent with the coverage of work involving
electric power generation installations in subpart V.
44 Line-clearance tree trimming is also addressed
in § 1910.268 when the lines involved are
telecommunications lines. (See 29 CFR
1910.268(q).)
45 Throughout the preamble discussion of this
final rule, OSHA generally refers to line-clearance
tree trimmers who are not qualified employees
under § 1910.269 or subpart V as ‘‘line-clearance
tree trimmers,’’ and to qualified employees who
also meet the definition of ‘‘line-clearance tree
trimmers’’ as ‘‘qualified employees.’’
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20341
even those that might be considered
construction. OSHA requested
comments on whether § 1910.269
should apply to all work involving lineclearance tree trimming, as proposed, or
whether the relevant requirements from
§ 1910.269 should be contained in
subpart V.
The Agency received a handful of
comments on this issue. (See, for
example, Exs. 0175, 0186, 0201, 0213,
0230.) These comments generally
supported OSHA’s proposed approach.
For example, Mr. Anthony Ahern of
Ohio Rural Electric Cooperatives agreed
that OSHA need not duplicate the lineclearance tree-trimming requirements
from § 1910.269 in subpart V (Ex. 0186).
Also, Mr. James Gartland of Duke
Energy commented that the
requirements for line-clearance treetrimming operations should be covered
exclusively under § 1910.269,
explaining that line-clearance treetrimming operations are the same
whether one considers the work to be
general industry or construction (Ex.
0201).
IBEW asked OSHA to clarify whether
§ 1910.269 would apply even to treetrimming operations that could be
considered ‘‘construction,’’ for example
clearing around existing energized
facilities for a new right of way (Ex.
0230). OSHA is applying § 1910.269 in
those circumstances. Given that
clarification, IBEW agreed that the
§ 1910.269 requirements for lineclearance tree-trimming operations do
not need to be repeated in subpart V
(Ex. 0230). In light of the commenters’
support, OSHA is adopting
§ 1926.950(a)(3) as proposed with
respect to line-clearance tree
trimming.46
Although the tree trimming industry
did not object to covering all lineclearance tree trimming in § 1910.269,
representatives of the industry urged the
Agency to expand the scope of covered
line-clearance tree-trimming activities
by broadening the definition of that
term. (See, for example, Exs. 0174, 0200,
0502, 0503; Tr. 620–628, 765–769.) The
proposed definition of ‘‘line-clearance
tree trimming’’ in § 1926.968, which
was based on existing § 1910.269(x),
read as follows:
46 Current § 1910.269(a)(1)(ii)(A) provides that
§ 1910.269 does not apply to construction work. In
the final rule, OSHA is revising this paragraph to
indicate that § 1910.269 does not apply to
construction work, as defined in § 1910.12, except
for line-clearance tree-trimming operations and
work involving electric power generation
installations as specified in § 1926.950(a)(3). This
change makes the application of § 1910.269
consistent with the coverage of line-clearance treetrimming operations in subpart V.
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The pruning, trimming, repairing,
maintaining, removing, or clearing of trees or
the cutting of brush that is within 3.05 m (10
feet) of electric supply lines and equipment.
The Utility Line Clearance Coalition
(ULCC) commented that the definition
of line-clearance tree trimming should
not be limited to trees within 3.05
meters (10 feet) of an electric supply
line. ULCC requested that OSHA
expand the definition of ‘‘line-clearance
tree trimming’’ to include all vegetation
management work done by lineclearance tree trimmers and trainees for
the construction or maintenance of
electric supply lines or for electric
utilities (Ex. 0502). The Tree Care
Industry Association (TCIA) proposed
the same change to the definition of
‘‘line-clearance tree trimming’’ (Ex.
0503). Both tree trimming trade
associations recommended that the
definition of ‘‘line-clearance tree
trimming’’ be revised to read as follows:
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The pruning, trimming, repairing,
maintaining, removing, treating or clearing of
trees or the cutting of brush (vegetation
management) that is within 10 feet (305 cm)
of electric supply lines and equipment, or
vegetation management work performed by
line clearance tree trimmer/trainees for the
construction or maintenance of electric
supply lines and/or for electric utilities. [Exs.
0502, 0503]
The industry provided three main
arguments in support of its
recommendation to expand the scope of
tree-trimming work covered by
§ 1910.269. For the reasons described
later, OSHA is not persuaded by the
industry’s arguments and will not be
expanding the definition of ‘‘lineclearance tree trimming’’ to include all
vegetation management work for the
construction or maintenance of electric
supply lines or for electric utilities.
However, OSHA is making some
changes to the definition of ‘‘lineclearance tree trimming’’ that will
broaden, in a limited manner, the scope
of tree-trimming operations covered by
§ 1910.269. These changes are discussed
later in this section of the preamble.
The tree trimming industry’s first
argument in support of its
recommended definition is that the ‘‘10foot rule’’ (as they described it)
contradicts other portions of § 1910.269.
Joe Tommasi of the Davey Tree Expert
Company, testifying on behalf of ULCC,
noted:
[T]he minimum separation distances tables
in the standard requires [sic] a line clearance
arborist to maintain more than ten feet from
some lines depending on the voltage
exposures, but at the same time, the
definition says that such work is not subject
to [the] line clearance tree trimming standard
because the standard [applies] only to trees
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that are within the ten feet of overhead
conductors. [Tr. 622]
Mr. Tommasi also suggested that some
requirements, such as those for spraying
herbicides and stump cutting, may
apply to work that takes place more
than 3.05 meters away from power lines
(Tr. 622–623).
OSHA does not find this argument
persuasive. This first of the tree
trimmers’ arguments reflects a basic
misunderstanding of the way the
proposed standard worked. Under the
proposed rule, tree-trimming work was
covered by § 1910.269 only to the extent
it was done on trees or brush within
3.05 meters of electric supply lines and
equipment. If it was done on trees or
brush more than 3.05 meters away from
lines and equipment, none of the
provisions in proposed § 1910.269
applied. The proposed ‘‘10-foot rule’’
did not create any internal conflicts in
§ 1910.269. For work done outside of
the 3.05-meter boundary, the proposed
provisions the industry was concerned
about, that is, minimum approach
distances and requirements for spraying
herbicides and stump cutting, did not
apply.
The tree trimmers’ second
justification for expanding the
definition of line-clearance tree
trimming in § 1910.269 is that the ‘‘10foot rule’’ undermines safety by causing
different safety requirements to apply to
line-clearance tree trimmers depending
on their distance from the line. Mr.
Tommasi testified that ‘‘experience
teaches that a single set of safety rules
applicable to the line tree arborist
achieves the highest rate of compliance
and thus the highest safety’’ (Tr. 625).
Mr. Tommasi maintained that Federal
and State OSHA compliance officials
have enforced other standards, such as
OSHA’s logging standard (29 CFR
1910.266), during arborist operations
more than 3.05 meters from power lines
(id.). Further, ULCC commented that
‘‘the foundation of worker safety in line
clearance tree trimming is adherence to
a single predictable set of safety
standards in which employees can be
trained and repeatedly drilled’’ (Ex.
0174).
OSHA appreciates the industry’s
desire for a single set of safety-related
work practices, but changing the
definition of ‘‘line-clearance tree
trimming’’ in § 1910.269 would not
necessarily achieve the industry’s goal.
As stated previously, even work covered
by § 1910.269 and subpart V must
comply with all other applicable general
industry and construction standards. In
any event, the Agency does not believe
that it is necessary to employee safety to
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address in § 1910.269 every hazard
faced by line-clearance tree trimmers.
Employers in every industry, including
line-clearance tree trimming firms, must
identify all OSHA standards applicable
to their work, along with their general
duty clause obligations, and then set,
communicate, and enforce a set of work
rules that meets all of the applicable
requirements. For example, if a lineclearance tree trimming contractor
performs work that falls under the
logging or site-clearing standards
(§§ 1910.266 and 1926.604,
respectively), the contractor will have to
ensure that its work rules meet those
standards, in addition to § 1910.269.47
The provisions on brush chippers,
sprayers and related equipment, stump
cutters, gasoline-engine power saws,
backpack units for use in pruning and
clearing, rope, and fall protection
(§ 1910.269(r)(2), (r)(3), (r)(4), (r)(5),
(r)(6), (r)(7), and (r)(8), respectively) in
existing § 1910.269 were taken, in part,
from the EEI–IBEW draft on which
§ 1910.269 was based. Those provisions
were ‘‘checked against the equivalent
ANSI standard, ANSI Z133.1–1982[,
American National Standard for Tree
Care Operations—Pruning, Trimming,
Repairing, Maintaining, and Removing
Trees, and Cutting Brush—Safety
Requirements] ([269-]Ex. 2–29), to be
sure that OSHA’s regulations would
better effectuate safety than the national
consensus standard’’ (59 FR 4322).
However, OSHA did not incorporate a
comprehensive tree-trimming standard
in § 1910.269. Thus, many important
safety provisions included in applicable
consensus standards and in other OSHA
standards were not included in
§ 1910.269, and that section does not
address some important safety hazards
faced by workers performing tree care
operations. For example, § 1910.269
does not contain any specific
requirements to protect workers felling
trees. Those requirements are in OSHA’s
logging standard. Furthermore, even
with respect to the nonelectrical hazards
that are regulated in the § 1910.269 treetrimming provisions, the OSHA
standards do not cover those hazards as
comprehensively as the current version,
47 ULCC suggested that the references in
§ 1910.269(r)(5) to specific requirements in the
logging standard ‘‘shows OSHA’s intent to not
apply [the] logging standard to line clearance unless
so-designated’’ (Ex. 0174). This is an erroneous
interpretation that overlooks existing
§ 1910.269(a)(1)(iii), which explains that ‘‘[s]pecific
references in this section to other sections of part
1910 are provided for emphasis only.’’ Other
relevant provisions in part 1910 continue to apply,
including other provisions in the logging standard,
if the work being performed falls within the scope
of those standards and within the scope of
§ 1910.269 at the same time.
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or even the 1982 version, of ANSI
Z133.1.48 For example, the new and old
consensus standards include additional
requirements for brush chippers and
provisions on hand tools such as axes,
pruners, and saws that are not contained
in § 1910.269. For these reasons,
adopting the industry’s
recommendation to have § 1910.269 be
the exclusive source of requirements for
tree-trimming work would not improve
employee safety. Instead, it would
jeopardize the workers performing those
operations. For example, an employer
may perform a logging operation near an
overhead power line under contract
with an electric utility to remove trees
along the right of way for the power
line. Applying the tree care industry’s
recommendation and logic to this work
would place that work exclusively
under § 1910.269, eliminating the
protection provided by the logging
standard’s tree-felling provisions.
The Agency has published an advance
notice of proposed rulemaking to gather
information to use in developing a
comprehensive standard on tree care
operations (73 FR 54118–54123, Sept.
18, 2008). In that rulemaking, OSHA
will consider whether, and to what
extent, any new standard on tree care
operations should cover line-clearance
tree trimming.
The tree trimmers’ third justification
for expanding the definition of lineclearance tree trimming in § 1910.269 is
that the electrical hazards regulated by
§ 1910.269 exist at distances greater
than 3.05 meters from the line. ULCC
argued that there are many
circumstances that expose lineclearance tree trimmers to electrical
hazards at distances beyond 3.05 meters
from the line, such as when a tree or
section of a tree can fall into the line
even though the tree itself is farther than
3.05 meters away (Ex. 0174). To
illustrate this point, Mr. Tommasi
provided an example of a 15.2-meter tall
oak tree located 4.6 meters from an
overhead power line (Tr. 623).
OSHA has considered this argument,
but has concluded that the 3.05-meter
rule is generally reasonable and
consistent with provisions in 29 CFR
part 1910, subpart S, OSHA’s general
industry electrical standards. An
examination of the different
requirements that apply to the electrical
48 As stated earlier, in its review of the EEI–IBEW
draft, OSHA checked provisions of that draft against
equivalent provisions in ANSI Z133.1–1982.
However, because § 1910.269 is a standard for
electric power generation, transmission, and
distribution work and not a comprehensive
standard on tree trimming, the Agency did not
examine provisions in the ANSI standard that had
no counterpart in the EEI–IBEW draft.
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hazards posed by tree-trimming
operations will illuminate the need to
set a locus within which § 1910.269
should apply.
The line-clearance tree-trimming
provisions in existing § 1910.269
contain several requirements to protect
line-clearance tree trimmers from
electrical hazards. First, to be
considered line-clearance tree trimmers
under § 1910.269, employees must,
through training or experience, be
familiar with the special techniques and
hazards involved in line-clearance tree
trimming.49 (See existing
§ 1910.269(a)(1)(i)(E)(2) and the
definition of ‘‘line-clearance tree
trimmer’’ in existing § 1910.269(x).)
Second, there must be at least two lineclearance tree trimmers present under
any of the following conditions: (1) If a
line-clearance tree trimmer is to
approach any conductor or electric
apparatus energized at more than 750
volts more closely than 3.05 meters, (2)
if branches or limbs being removed are
closer than the applicable minimum
approach distances to lines energized at
more than 750 volts, or (3) if roping is
necessary to remove branches or limbs
from such conductors or apparatus. (See
existing § 1910.269(r)(1)(ii).) Third,
when the voltage on the lines is 50 volts
or more and two or more employees are
present, generally at least two
employees must be trained in first aid,
including cardiopulmonary
resuscitation.50 (See existing
§ 1910.269(b)(1).) Fourth, employees
must maintain minimum approach
distances appropriate for qualified
employees. (See existing
§ 1910.269(r)(1)(iii) and (r)(1)(v).) Fifth,
employees must use insulating
equipment to remove branches that are
contacting exposed, energized
conductors or equipment or that are
within the applicable minimum
approach distances of energized
conductors or equipment. (See existing
§ 1910.269(r)(1)(iv).) Sixth, lineclearance tree-trimming work may not
be performed when adverse weather
conditions make the work hazardous in
49 Throughout this preamble, OSHA differentiates
between line-clearance tree trimmers (as defined in
§ 1910.269) and other workers involved in treetrimming operations. OSHA refers to employees
doing tree-related work who are not line-clearance
tree trimmers under § 1910.269 as ‘‘regular tree
trimmers’’ (that is, all other tree trimmers) or ‘‘tree
workers who are not line-clearance tree trimmers’’
(that is, all other tree trimmers and ground
workers). See also the summary and explanation for
§ 1926.950(b)(2), later in this section of the
preamble.
50 See the summary and explanation for final
§ 1926.951(b)(1), later in this section of the
preamble, for a discussion of the requirements for
first-aid training for field work, such as lineclearance tree-trimming operations.
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spite of the work practices required by
§ 1910.269. (See existing
§ 1910.269(r)(1)(vi).) Seventh,
mechanical equipment must maintain
appropriate minimum approach
distances, and certain measures must be
taken to protect employees on the
ground from hazards that might arise
from equipment contact with energized
lines. (See existing § 1910.269(p)(4).)
Requirements for tree trimmers who
are not performing line-clearance tree
trimming (as defined in final
§ 1910.269(x)), that is, ‘‘regular tree
trimmers,’’ are contained in Subpart S of
the general industry standards in part
1910. It is important to note that, for the
purposes of Subpart S, tree trimmers fall
into two categories: (1) Regular tree
trimmers, whom OSHA treats as
unqualified persons, and (2) lineclearance tree trimmers (as defined in
§ 1910.269), whom OSHA considers
qualified persons under subpart S. Lineclearance tree trimmers under
§ 1910.269 are exempt from the
electrical safety-related work practice
requirements in subpart S and must
comply with the § 1910.269
requirements described previously.51
(See § 1910.331(c)(1).) In contrast,
regular tree trimmers are subject to the
subpart S requirements, but are not
covered by § 1910.269.52
Subpart S sets some basic
requirements for regular tree trimmers.
51 Note 2 to the definition of ‘‘line-clearance tree
trimmer’’ in existing § 1910.269(x) explains that
line-clearance tree trimmers are considered
qualified employees for purposes of the electrical
safety-related work practices in Subpart S
(§§ 1910.331 through 1910.335). Paragraph (c)(1) of
§ 1910.331 provides that §§ 1910.331 through
1910.335 do not apply to work performed by
qualified persons, including line-clearance tree
trimmers under § 1910.269, on or directly
associated with generation, transmission, and
distribution installations. In addition, Note 3 to
§ 1910.331(c)(1) clarifies that the agency considers
line-clearance tree trimming to be work directly
associated with such installations.
52 Currently, an employee must meet the
definition of ‘‘line-clearance tree trimmer’’ in
existing § 1910.269(x) and have training meeting
§ 1910.332(b)(3) to be considered a line-clearance
tree trimmer who is a qualified employee for the
purposes of subpart S. (See Note 1 to
§ 1910.332(b)(3), which states that a person must
have the training required by that paragraph to be
considered a qualified person.) As explained in the
summary and explanation for §§ 1926.950(b)(2) and
1910.269(a)(2)(iii), later in this section of the
preamble, OSHA added to § 1910.269 appropriate
training requirements for line-clearance tree
trimmers. Consequently, under this final rule, an
employee must meet the definition of ‘‘lineclearance tree trimmer’’ and have training meeting
§ 1910.269(a)(2)(iii) to be considered a lineclearance tree trimmer who is a qualified employee
for the purposes of subpart S. Under both the
existing standards and the final rule, any given tree
trimmer is either a line-clearance tree trimmer, who
is considered a qualified employee under subpart
S, or a regular tree trimmer, who is considered an
unqualified employee under subpart S.
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(Other requirements also apply, but are
not germane to this discussion.) First,
regular tree trimmers must be
appropriately trained (see
§ 1910.332(b)(1) and (b)(2)), although
the training required for regular tree
trimmers is not as extensive as that
required for line-clearance tree
trimmers. Second, regular tree trimmers
must generally maintain a minimum
separation of 3.05 meters from overhead
power lines (see § 1910.333(c)(3)(i) and
(c)(3)(iii)). Finally, regular tree trimmers
working on the ground may not contact
vehicles or mechanical equipment
capable of having parts of its structure
elevated near energized overhead lines,
except under certain conditions (see
§ 1910.333(c)(3)(iii)(B)).
As a general matter, OSHA believes
that workers performing line-clearance
tree-trimming operations under existing
§ 1910.269 are afforded more protection
than workers performing regular treetrimming operations under Subpart S.
Under existing § 1910.269, lineclearance tree-trimming operations
generally require the presence of at least
two line-clearance tree trimmers trained
in first aid, including cardiopulmonary
resuscitation. Subpart S does not have a
comparable requirement. Existing
§ 1910.269 forbids line-clearance treetrimming operations from being
performed when adverse weather
conditions make work unsafe. Subpart S
does not address weather conditions.
Furthermore, in comparison with
subpart S, existing § 1910.269 contains
additional requirements to protect
workers in case mechanical equipment
contacts a power line. OSHA believes
that these important protections in
existing § 1910.269 must be required
only when tree-trimming operations
expose employees to the most serious
electrical hazards, not any time
electrical hazards are present, as posited
by ULCC.
OSHA believes that the seriousness of
electrical hazards posed by tree
trimming depends on how close the tree
is to the power line. The closer the tree
is to the power line, the more difficulty
the worker has in maintaining minimum
approach distances. For example, roping
may be necessary to maintain the
required minimum approach distances.
(This practice is addressed in existing
§ 1910.269(r)(1)(ii)(C).) Furthermore,
when the tree is close to the power line,
a worker trimming trees from an aerial
lift has to be more concerned with the
distances between the power line and
the tree, the aerial lift, and himself or
herself. The farther the tree is from the
power line, the more room an employee
has in which to maneuver the aerial lift.
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Therefore, the Agency has only to
decide how close the tree needs to be to
a power line before the protections
required by § 1910.269 are necessary.
The Agency concludes that those
protections should start when the tree is
3.05 meters from a power line. Under
Subpart S, unqualified employees are
not permitted within that distance, but
they are permitted to work in
compliance with subpart S outside of
that distance (plus 100 millimeters (4
inches) of additional distance for every
10 kilovolts over 50 kilovolts). (See
§ 1910.333(c)(3)(i).) OSHA believes that
it would be inconsistent to expand the
definition of ‘‘line-clearance tree
trimming’’ to the point that lineclearance tree trimmers working on
trees or brush more than 3.05 meters
from the lines would be entitled to the
enhanced protections of § 1910.269,
while employees doing other types of
work closer to the lines (between 3.05
meters from the line and where the lineclearance tree trimmers are working)
would be governed by the more limited
protections afforded by subpart S. The
Agency generally believes that any
electrical hazards that are present when
a tree is more than 3.05 meters from
power lines are addressed adequately by
subpart S.
Nevertheless, changes to the existing
definition of ‘‘line-clearance tree
trimming’’ in § 1910.269 (which is
identical to the definition proposed for
subpart V) are necessary to ensure
consistency with the 3.05-meter rule
that applies to unqualified employees
under § 1910.331(c)(3)(i). As noted
previously, under
§ 1910.333(c)(3)(i)(A)(1), 3.05 meters is
the minimum distance an unqualified
employee must maintain from overhead
power lines. If the voltage is higher than
50 kilovolts, the required distance under
§ 1910.333(c)(3)(i)(A)(2) increases by
100 millimeters for every 10 kilovolts of
voltage above 50 kilovolts. OSHA
believes that this increase in distance
reasonably captures the relationship
between the severity of the electrical
hazard and voltage. Therefore, OSHA
decided that, although it is not
expanding the definition of ‘‘lineclearance tree trimming’’ to the extent
recommended by the tree trimming
industry, it will add this extra distance
to the definition of ‘‘line-clearance tree
trimming’’ to accord with
§ 1910.333(c)(3)(i)(A). The revised
definition appears in §§ 1910.269(x) and
1926.968.
Paragraph (b) of final § 1926.950
addresses training for employees.
Subpart V currently contains no general
provisions related to training employees
in the safety practices necessary to
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perform electric power transmission and
distribution work. It is widely
recognized that the types of work
covered by this standard require special
knowledge and skills. Additionally,
final subpart V contains many safetyrelated work practice requirements that
are necessary for the protection of
employees. To gain the requisite
knowledge and skills to use these work
practices, employees must be
adequately trained. Therefore, in the
proposed revision of subpart V, OSHA
included training requirements
mirroring those already in § 1910.269,
with a few changes and additions
(discussed later). OSHA notes that
editorial changes are being made
throughout paragraph (b) to clarify that
employers must ensure that ‘‘each’’
employee covered by a specific training
provision receives the training required
by that provision.53
Paragraph (b)(1) contains training
requirements applying to all employees
performing work covered by subpart V.
Siemens Power Generation and ORC
Worldwide suggested deleting the
heading ‘‘All employees’’ from proposed
paragraph (b)(1). They expressed
concern that the provision could be
construed to require training for clerical
employees or other workers doing tasks
not covered by subpart V (Exs. 0163,
0208, 0235). Siemens commented:
By adding the word ‘‘ALL’’ the Agency is
implying that training must be conducted for
any and all employees regardless of their
scope of task. It implies for example, that
even for clerical employees that have no risk,
there must be some documented training
conducted to comply with this requirement.
[Ex. 0163]
OSHA appreciates these concerns, but
has elected to retain the title in
paragraph (b)(1) as proposed. The
Agency thinks that it is important to
distinguish the training requirements in
53 Several provisions in the proposed rule and
existing § 1910.269 require employers to provide
personal protective equipment (PPE) and training
for ‘‘employees’’ or for ‘‘all employees.’’ The final
rule amends these provisions to require PPE and
training for ‘‘each employee.’’ These editorial,
nonsubstantive changes emphasize that the
standards’ training and PPE requirements impose a
compliance duty to each and every employee
covered by the standards and that noncompliance
may expose the employer to liability on a peremployee basis. This action is in accord both with
OSHA’s longstanding position and OSHA standards
addressing employers’ duties. (See §§ 1910.9 and
1926.20(f); see also 73 FR 75568 (Dec. 12, 2008)).
It should be noted that, if any provision in the final
rule continues to require training or PPE for
‘‘employees’’ or for ‘‘all employees,’’ rather than for
‘‘each employee,’’ as described above, this was an
unintentional omission on OSHA’s part and should
not be interpreted as amending OSHA’s
longstanding position, or the general standards,
addressing employers’ duties to provide training
and PPE to each employee.
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paragraph (b)(1), which is broadly
applicable to workers doing work
covered by subpart V, from the
requirements in paragraph (b)(2), which
is applicable only to ‘‘qualified
employees.’’ OSHA clarified in the
proposal, and is reiterating here, that
paragraph (b)(1) does not impose
training requirements on employees
who are not performing work covered
by subpart V. The text of paragraph
(b)(1) is self-limiting—employers need
only ensure that each employee receives
safety training that ‘‘pertain[s] to his or
her job assignments’’ and that is
‘‘related to his or her work.’’
As clerical workers do not perform
the types of hazardous work covered by
subpart V, this provision does not
require employers to train such
employees in live-line barehand or other
work techniques addressed by this final
rule. Employees performing clerical
work or other work not covered by
subpart V would not need to receive the
same electrical safety training required
for workers involved in the construction
of transmission and distribution lines
and equipment. However, employers
must train clerical workers performing
work covered by subpart V in the
hazards to which they might be
exposed.
Proposed paragraphs (b)(1)(i) and
(b)(1)(ii) were borrowed in large part
from provisions in existing § 1910.269.
Paragraph (b)(1)(i) requires each
employee to be trained in, and be
familiar with, the safety-related work
practices, safety procedures, and other
safety requirements in subpart V that
pertain to his or her job assignments.
OSHA considers this training necessary
to ensure that employees use the safetyrelated work practices outlined in
subpart V. It should be noted that this
provision requires employers to train
employees not only in the content of the
applicable requirements of the final rule
but in how to comply with those
requirements. OSHA received no
comments on proposed paragraph
(b)(1)(i) and is carrying it forward into
the final rule without substantive
change.
Proposed paragraph (b)(1)(ii)
additionally provided that employees
had to be trained in, and be familiar
with, any other safety practices related
to their work and necessary for their
safety, including applicable emergency
procedures, such as pole-top and
manhole rescue. Proposed paragraph
(b)(1)(ii) required that safety training be
provided in areas that are not directly
addressed by subpart V, but that are
related to the employee’s job. This
training fills in the gaps left when the
final rule does not specify requirements
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for every hazard the employee may
encounter in performing electric power
generation, transmission, or distribution
work. OSHA explained in the preamble
to the proposal that if more than one set
of work practices could be used to
accomplish a task safely, the employee
would only need to be trained in the
work methods to be used (70 FR 34833).
For example, an insulator on a power
line could be replaced by an employee
using live-line tools or rubber insulating
equipment or by an employee working
without electrical protective equipment
after deenergizing and grounding the
line. The employee would only need to
be trained in the method actually used
to replace that insulator.
The Agency received numerous
comments suggesting that the training
requirement proposed in paragraph
(b)(1)(ii) was too broad (Exs. 0156, 0160,
0168, 0170, 0202, 0206, 0207, 0229,
0233, 0237). Mr. Don Adkins of Davis H.
Elliot Company, an electrical contractor,
commented, for example, that this
proposed provision was ‘‘impermissibly
broad’’ and offered ‘‘no guidance as to
what safety practices are ‘related’ to the
work of those covered by the standard’’
(Ex. 0156). Mr. Robert Matuga of the
National Association of Home Builders
(NAHB) believed that paragraph
(b)(1)(ii) was ‘‘overly broad,’’ potentially
‘‘creating an obligation for employers to
provide training to workers . . . on
almost every hazard that could
conceivably be encountered on a
construction jobsite’’ (Ex. 0168). He also
argued that proposed paragraph (b)(1)(ii)
is duplicative of § 1926.21(b)(2), which
requires ‘‘[t]he employer [to] instruct
each employee in the recognition and
avoidance of unsafe conditions and the
regulations applicable to his work
environment to control or eliminate any
hazards or other exposure to illness or
injury’’ (id.). Also, the U.S. Small
Business Administration’s (SBA) Office
of Advocacy commented:
The scope of this mandatory employee
training is not limited to work practices
required by the proposed electrical
standards, but extends to any other safety
practices that are related to their work and
necessary for their safety. The SBREFA panel
was concerned that this language was overly
broad and could be viewed as covering other,
non-specified hazards on the worksite, such
as ergonomic injuries from overhead work.
*
*
*
*
*
The proposed training language remains
vague and OSHA should clarify what training
is necessary to comply with the standard (as
well as what alternative training is acceptable
for compliance) [Ex. 0207]
Despite these comments, OSHA
continues to believe that the
requirement in proposed paragraph
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20345
(b)(1)(ii) is essential to the safety and
welfare of employees and is adopting it
without significant change in this final
rule. Mr. Brian Erga of Electrical Safety
Consultants International (ESCI)
supported the proposed training
requirements and attributed an increase
in employee proficiency, and safer work
environments, to the adoption of these
provisions in existing § 1910.269. He
explained:
It has been shown time and time again that
high quality training and retraining not only
provides a safer work site, but returns
dividends in financial contributions and long
term productivity to the employer. The
proposed [1926.]950(b) and associated
verbiage in the preamble, if followed, will, in
our opinion, move the industry to a safer
work site. The current training requirements
in 1910.269 and [the] proposed training
requirements are not unduly burdensome,
and will provide a more educated and
experienced work force. [Ex. 0155]
Further, Mr. Donald Hartley with
IBEW testified at the 2006 public
hearing that ‘‘ensur[ing] that . . .
employees are trained in the safetyrelated work practices, procedures, and
requirements that pertain to their . . .
assignments . . . is necessary to ensure
that employees are equipped to deal
with potential hazards associated with
this dangerous work’’ (Tr. 876). He did
not suggest that this training be limited
only to the safety practices and other
safety requirements in subpart V.
Several rulemaking participants
recognized that subpart V does not
specifically address all hazards faced by
employees performing covered work
and suggested that training is an
important factor in employee safety. For
example, Mr. Lee Marchessault testified
about the importance of training in
substation rescue procedures, stating,
‘‘You should do rescue training from
substation structures’’ (Tr. 572). Also,
Energy United EMC commented that
‘‘proper training is necessary’’ to
prevent employees in insulated aerial
lifts from touching conductors (Ex.
0219). The record also indicates that
employers train employees to protect
them from heat-stress hazards (see, for
example, Tr. 1129–1130), to ensure
proper maintenance of protective
clothing (see, for example, Tr. 471), and
to supplement the line-clearance treetrimming requirements in existing
§ 1910.269 (see, for example, Tr. 683).
Existing § 1910.269(a)(2)(i) already
contains a requirement identical to the
one proposed in § 1926.950(b)(1)(ii), and
OSHA has successful enforcement
experience with this provision. First,
except for two questions addressing
who needs to be trained in emergency
and rescue procedures, the Agency has
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not received any letters requesting
interpretation or clarification of this
provision, leading the Agency to believe
that the requirement is not as
ambiguous as the commenters claim.
Second, OSHA has issued only a few
citations under existing
§ 1910.269(a)(2)(i) (for example, in 2008,
OSHA issued only 2 citations of
§ 1910.269(a)(2)(i) in 362 inspections of
electric utilities), which supports
OSHA’s conclusion that employees
performing work under existing
§ 1910.269 are generally being trained as
required. Third, even EEI admits that
‘‘EEI members have generally found the
training requirements of paragraph
1910.269(a)(2) to be workable for their
employees’’ (Ex. 0227). Thus, it appears
that electric utilities have not had
difficulty complying with the identical
requirement in existing
§ 1910.269(a)(2)(i).
On the other hand, the Agency agrees
with these commenters that
§ 1926.950(b)(1)(ii) of the final rule sets
a broad, general requirement to train
employees. This is not an uncommon
approach for an OSHA standard to take.
OSHA’s personal protective equipment
(PPE) standards in §§ 1910.132(a) and
1926.95(a) require the employer to
provide and ensure the use of protective
equipment wherever it is necessary by
reason of hazards of processes or
environment, chemical hazards,
radiological hazards, or mechanical
irritants encountered in a manner
capable of causing injury or impairment
in the function of any part of the body
through absorption, inhalation or
physical contact. An employer is
deemed to be in violation of the PPE
standards when it fails to provide PPE
despite having actual or constructive
knowledge of a hazard in its facility for
which protective equipment is
necessary. (See, for example, Cape &
Vineyard Div. of the New Bedford Gas
& Edison Light Co. v. OSHRC, 512 F.2d
1148, 1152 (1st Cir.1975).) The general
construction training requirement
contained in § 1926.21(b)(2) is similarly
broad, requiring employers to instruct
each employee in the recognition and
avoidance of unsafe conditions and the
regulations applicable to his or her work
environment to control or eliminate any
hazards or other exposure to illness or
injury. That standard has been
interpreted to require employers to
provide employees with ‘‘the
instructions that a reasonably prudent
employer would have given in the same
circumstances.’’ (El Paso Crane &
Rigging Co., Inc., 16 BNA OSHC 1419
(No. 90–1106, Sept. 30, 1993); see also
Pressure Concrete Constr. Co., 15 BNA
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OSHC 2011 (No. 90–2668, Dec. 7, 1992)
(‘‘Because section 1926.21(b)(2) does not
specify exactly what instruction the
employees must be given, the
Commission and the courts have held
that an employer must instruct its
employees in the recognition and
avoidance of those hazards of which a
reasonably prudent employer would
have been aware.’’).) The applicability
of § 1926.21(b)(2) turns on an
employer’s actual or constructive
knowledge of hazards, just as under the
general PPE requirements. (See, for
example, W.G. Fairfield Co. v. OSHRC,
285 F. 3d 499 (6th Cir. 2002).)
OSHA is applying final paragraph
(b)(1)(ii) in the same manner. Therefore,
if an employer has actual knowledge of
a hazard (for example, through safety
warnings from equipment
manufacturers or through injury
experience), or if the employer has
constructive knowledge of a hazard (for
example, when industry practice
recognizes particular hazards), then
each employee exposed to the hazard
must be trained. For the training to
comply with this provision, it must be
sufficient to enable the employee to
recognize the hazard and take
reasonable measures to avoid or
adequately control it.
In addition, OSHA agrees with Mr.
Matuga that, except to the extent that it
only covers Subpart V work, paragraph
(b)(1)(ii) requires the same training as
§ 1926.21(b)(2). Consequently,
employers who meet § 1926.21(b)(2)
also meet final § 1926.950(b)(1)(ii). Even
though the final rule duplicates the
general construction training provision,
the Agency is adopting paragraph
(b)(1)(ii) to maintain consistency with
existing § 1910.269.
Mr. Lee Marchessault with Workplace
Safety Solutions recommended that
paragraph (b)(1)(ii) refer to rescues at
heights generally, rather than just poletop rescue, in the parenthetical listing
examples of potentially applicable
emergency procedures (Tr. 572). He
noted that rescue procedures are
performed from wind turbines, towers,
and substation structures, as well as
utility poles (id.).
OSHA has decided not to adopt this
recommendation because no change is
necessary. The types of emergency
procedures listed in paragraph (b)(1)(ii)
in the final rule are examples only. Poletop rescue is listed because it is a
widely recognized and used emergency
procedure. The Agency notes, however,
that training in these other types of
emergency procedures is required if it is
necessary for employee safety during
the work in question.
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OSHA proposed to add a new
provision to both subpart V and
§ 1910.269 clarifying that the degree of
training required is based on the risk to
the employee for the task involved.
OSHA explained that, under this
proposed paragraph, the training
provided to an employee would need to
be commensurate with the risk he or she
faces (70 FR 34834). The two provisions,
proposed §§ 1910.269(a)(2)(i)(C) and
1926.950(b)(1)(iii), were based on
§ 1910.332(c), although § 1910.332(c)
does not contain the ‘‘for the task
involved’’ language. The purpose of
these new training paragraphs was to
ensure that an appropriate level of
training is provided to employees.
Employees who face little risk in their
job tasks need less training than those
whose jobs expose them to more danger.
OSHA believed that this provision
would ensure that employers direct
their training resources where they will
provide the greatest benefit, while still
making sure that all employees receive
adequate training to protect them
against the hazards they face in their
jobs (id.). OSHA noted in the preamble
to the proposal that training already
provided in compliance with existing
§ 1910.269 would be considered
sufficient for compliance with these
paragraphs (id.). The provisions would
not require employers to make changes
to existing training programs that
comply with § 1910.269; rather, they
would provide employers with options
to tailor their training programs and
resources to employees with
particularly high-risk jobs (id.).
OSHA received several comments
regarding paragraph (b)(1)(iii) of
proposed § 1926.950. (See, for example,
Exs. 0128, 0162, 0163, 0169, 0177, 0201,
0209, 0210, 0212, 0221, 0225, 0227,
0235; Tr. 873–874, 1316–1319, 1332–
1333.)54 Some commenters maintained
that this provision was unnecessary or
too vague. For example, Mr. Pat
McAlister of Henry County REMC
requested additional guidance to
‘‘clarify generally when and how risks
link with training and [how to assign]
the appropriate level of training to offset
those risks’’ (Ex. 0210). EEI commented
that this proposed training provision
was unnecessary, explaining:
We question the soundness of changing the
[current] requirements [in § 1910.269]
because if compliance with existing Section
1910.269 training requirements is sufficient,
there is no reason to add another regulatory
54 The remaining discussion of these provisions
refers to the proposed construction requirement.
However, the comments and OSHA’s resolution of
those comments applies equally to the
corresponding general industry provision as is
generally the case throughout this preamble.
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requirement, and the proposed provisions
demonstrably have no purpose. The stated
explanation is that the standard is intended
to ‘‘provide employers with options,’’ but
employers have those options without the
added regulation. No additional provisions
are necessary to preserve existing options.
[Ex. 0227]
EEI went on to suggest that the added
requirement would create confusion,
commenting:
EEI’s concern is that the new language will
likely create confusion among many
employers who do not have access to or
regularly consult the preambles to OSHA
standards. All but the most sophisticated
readers likely will assume that the revised
standard imposes a requirement to modify
existing training programs. Moreover, the
proposal is unclear: The meaning of the term
‘‘degree of training’’ is difficult to discern in
that it is not evident how OSHA would
classify and evaluate a ‘‘degree’’ of training.
[Id.]
Many of the comments received on
proposed paragraph (b)(1)(iii) expressed
concern only about the language tying
training to ‘‘the task involved.’’ For
example, Mr. Mark Spence with Dow
Industries generally supported the
proposed provision, but stated that the
similar requirement in § 1910.332(c),
which does not contain the ‘‘for the task
involved’’ language, ‘‘has been in effect
since 1990 without causing significant
problems for employers’’ (Ex. 0128). Mr.
Spence had concerns about the
additional language in proposed
paragraph (b)(1)(iii), explaining:
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[T]he proposal refers to training ‘‘for the
task involved’’. Training programs typically
are broad, rather than task-specific. [T]he
present wording could be interpreted to
indicate an unmanageable requirement to
train affected employees on the details of
each individual task. OSHA should consider
re-wording this provision or clarifying that it
means that, where necessary, additional
training may be required for a particular task
. . . [Id.]
Mr. Tom Chappell of Southern
Company similarly noted that ‘‘[d]ue to
the large number of different tasks that
an employee may need to perform, it
would be difficult to evaluate each task
and identify the level of training that
would be required’’ (Ex. 0212).
Consumers Energy commented that, in
its experience, ‘‘employees can safely
complete hundreds of specific tasks’’
without the need for training in each
task individually (Ex. 0177). Mr. Donald
Hartley of IBEW testified that the
requirement ‘‘to tie the degree of
training to the risk to the employee for
the task involved . . . is both an
unworkable and inappropriate
standard’’ (Tr. 873–874). Mr. William
Mattiford with Henkels & McCoy
testified:
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[I]t’s not very clear as to what by
definition, the degree of training shall be
determined by the risk to the employee for
the task involved. And that’s where we see
it’s very confusing.
And if it’s literally taken that way, then it’s
each individual task. So it’s not just setting
a pole, but it’s digging a hole, to set the pole,
to prefab the pole. Each one of those things
could be, I guess, understood as being
training for each one of those tasks.
And I feel as though, many of us feel as
though that by the design of the training
programs today that have redundancy and
overlapping in them, you do cover all of
those.
But to actually spell out perhaps a lesson
plan for each one of those tasks I think would
be just too difficult to do, if not impossible.
[Tr. 1339]
Mr. Wilson Yancey with Quanta
Services agreed with these comments:
I agree with Bill’s comments, too. I think
most of that is being covered today. If we
have to go down and copy it and put lesson
plans for everything, we will never get it
accomplished and it will be too costly to the
contractor. [Tr. 1340]
OSHA continues to believe that it is
important that the level of training
provided to employees be
commensurate with the risk they
encounter. Focusing training where the
risk is greatest maximizes the benefits to
be achieved. In addition, providing no
more training than is necessary for
hazards that pose less risk can conserve
valuable, and often limited, safety and
health resources. OSHA successfully
used this general approach in
§ 1910.332(c), allowing employers
flexibility in providing training to
employees, yet ensuring that employees
most at risk receive the most training.
This approach is recognized by the
Agency’s publication ‘‘Training
Requirements in OSHA Standards and
Training Guidelines.’’ 55
On the other hand, the Agency
understands the rulemaking
participants’ concerns. Most
commenters objected to providing a
level of training determined by ‘‘the task
involved.’’ Although employees are
trained to perform the various tasks
involved in their jobs, as noted by Mr.
Mattiford (Tr. 1339), examining each
task to determine the relative risk may
seem daunting and unworkable as
claimed by Mr. Hartley (Tr. 873–874).
Employers should, however, be capable
of determining the relative risk of the
various hazards encountered by their
55 This document can be obtained by contacting
OSHA’s Office of Publications as directed in the
ADDRESSES section of this preamble or from OSHA’s
Web page: https://www.osha.gov/pls/publications/
publication.html. See, in particular, Section III of
the voluntary guidelines, ‘‘Matching Training to
Employees,’’ on pp. 6–8.
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20347
employees. To clarify this requirement,
OSHA replaced the phrase ‘‘for the task
involved’’ from the proposal with the
phrase ‘‘for the hazard involved’’ in
paragraph (b)(1)(iii) of the final rule.
To determine the relative risk
encountered by employees, employers
are encouraged to follow the guidelines
in OSHA’s publication ‘‘Training
Requirements in OSHA Standards and
Training Guidelines,’’ Voluntary
Training Guidelines, Section III. In any
event, employers may allocate training
resources in accordance with their own
determination of relative risk, provided
that each affected employee receives the
minimum training required under
subpart V.
Paragraph (b)(2) contains additional
requirements for training qualified
employees. Because qualified
employees may work extremely close to
electric power lines and equipment and,
therefore, encounter a high risk of
electrocution, it is important that they
be specially trained. Towards this end,
the standard requires that these
employees be trained in: distinguishing
exposed live parts from other parts of
electric equipment; determining
nominal voltages of exposed live parts;
applicable minimum approach
distances and how to maintain them;
the techniques, protective equipment,
insulating and shielding materials, and
tools for working on or near exposed
live parts; and the knowledge necessary
to recognize electrical hazards and the
techniques to control or avoid these
hazards. The language in paragraph
(b)(2) generally mirrors language in
existing § 1910.269(a)(2)(ii). However,
paragraph (b)(2)(v), which requires
training in how to recognize and control
or avoid electrical hazards, has no
counterpart in existing § 1910.269. In
addition, OSHA has added language to
paragraph (b)(2)(iii) of the final rule
explicitly requiring employers to train
qualified employees in the skills and
techniques necessary to maintain
minimum approach distances. See the
summary and explanation of final
§ 1926.960(c)(1), later in this section of
the preamble, for an explanation of this
change.
NIOSH commented that qualified and
unqualified employees are exposed to
the same electrical hazards and should
receive the same training (Ex. 0130).
NIOSH suggested that ‘‘[a]ll workers
potentially exposed to electrocution
hazards should be trained in hazard
awareness and the identification and
control of these hazards, as qualified
employees are trained’’ (id.). NIOSH
specifically noted that line-clearance
tree trimmers and ground workers face
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electrical hazards comparable to those
of qualified employees (id.).
OSHA does not believe that is
appropriate to adopt requirements in
this final rule for the training of ground
workers on tree crews or other tree
workers who are neither qualified
employees under § 1910.269 nor lineclearance tree trimmers. Subpart S, not
§ 1910.269 or subpart V, applies to
electrical safety-related work practices
of ground workers on tree crews and
other tree workers who are not lineclearance tree trimmers. (See
§ 1910.331(b).) The preamble to the
1994 § 1910.269 final rule makes this
clear as follows:
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Other tree workers do not have the training
necessary for them to be either ‘‘qualified
employees’’ or ‘‘line-clearance tree
trimmers’’, as defined under § 1910.269(x).
These employees are not covered under
§ 1910.269 at all. The work practices these
employees must use are contained in Subpart
S of Part 1910. Under Subpart S, tree workers
must maintain a 10-foot minimum approach
distance from overhead lines. (In fact,
trimming any branch that is within 10 feet of
an overhead power line is prohibited by
Subpart S.) [59 FR 4410; footnotes omitted.]
Existing § 1910.269(a)(1)(ii)(B) states
that § 1910.269 does not cover
‘‘electrical safety-related work practices
. . . covered by subpart S.’’
Consequently, addressing the training of
ground workers on tree crews or other
tree workers who are neither qualified
employees nor line-clearance tree
trimmers in § 1910.269 or subpart V
would be inappropriate.
On the other hand, OSHA believes
that the final rule should address the
training of line-clearance tree trimmers.
However, not all of the training
requirements in final
§ 1910.269(a)(2)(ii), which are
applicable to qualified employees, are
appropriate for line-clearance tree
trimmers. Qualified employees are
trained to work on energized parts.
Specifically, the final rule requires
qualified employees to be trained in,
among other topics, the proper use of
the special precautionary techniques,
personal protective equipment,
insulating and shielding materials, and
insulated tools for working on or near
exposed energized parts of electric
equipment (§ 1926.950(b)(2)(iv)). This
training enables qualified employees to
work directly on energized parts of
electric circuits, which line-clearance
tree trimmers do not do.
Line-clearance tree trimmers work
close to, but not on, energized, overhead
power lines. (See, for example, Ex. 0502;
Tr. 611.) Consequently, the Agency
believes that these employees have
different training needs than qualified
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employees covered by § 1910.269.
Under existing § 1910.269, OSHA has
addressed the training for line-clearance
tree trimmers in the definition of ‘‘lineclearance tree trimmer’’ and in the notes
to that definition. The definition and
notes appear in existing § 1910.269(x).
Note 2 to that definition explains that
while line clearance tree trimmers are
not considered qualified employees for
purposes of § 1910.269, they are
considered to be qualified employees
exempt from the electrical safety-related
work practice requirements in subpart S
(§§ 1910.331 through 1910.335). The
note following § 1910.332(b)(3)
indicates that, for the purposes of
§§ 1910.331 through 1910.335, a person
must have the training required by
§ 1910.332(b)(3) for OSHA to consider
that person a qualified person.
Therefore, to be considered a lineclearance tree trimmer under § 1910.269
and, thus, a qualified person under
subpart S, a tree trimmer needs the
training specified by § 1910.332(b)(3).
Any tree trimmer who has not had such
training is considered an unqualified
person under subpart S, and the
electrical safety-related work practices
in that standard apply instead of those
in § 1910.269 as explained previously.
The training required by
§ 1910.332(b)(3) is virtually identical to
the training required by final
§ 1910.269(a)(2)(ii)(A) through
(a)(2)(ii)(C) for qualified employees,
except that § 1910.332(b)(3)(iii) requires
training in the clearance (that is,
minimum approach) distances specified
in § 1910.333(c), whereas
§ 1910.269(a)(2)(ii)(C) requires training
in the minimum approach distances in
§ 1910.269 and in the skills and
techniques necessary to maintain those
distances. Considering NIOSH’s
recommendation, OSHA believes that
putting appropriate training
requirements for line-clearance tree
trimmers directly in § 1910.269 rather
than applying them indirectly through
definitions and scope statements will
make the standards more transparent
and make the obligation to train these
workers clearer. Consequently, the
Agency is adopting a new
§ 1910.269(a)(2)(iii) requiring lineclearance tree trimmers to be trained in:
(1) The skills and techniques necessary
to distinguish exposed live parts from
other parts of electric equipment (final
§ 1910.269(a)(2)(iii)(A)), (2) the skills
and techniques necessary to determine
the nominal voltage of exposed live
parts (final § 1910.269(a)(2)(iii)(B)), and
(3) the minimum approach distances in
the final rule corresponding to the
voltages to which the line-clearance tree
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trimmer will be exposed and the skills
and techniques necessary to maintain
those distances (final
§ 1910.269(a)(2)(iii)(C)).56 The first two
training requirements, final
§ 1910.269(a)(2)(iii)(A) and (a)(2)(iii)(B),
are identical to § 1910.332(b)(3)(i) and
(b)(3)(ii). The remaining requirement,
final § 1910.269(a)(2)(iii)(C), is
comparable to § 1910.332(b)(3)(iii),
except that line-clearance tree trimmers
need to be trained in the minimum
approach distances required under
§ 1910.269 rather than those in subpart
S and need to be trained in the skills
and techniques necessary to maintain
those distances. OSHA concludes that
the minimum approach distances
required under § 1910.269 are the more
appropriate reference for final
§ 1910.269(a)(2)(iii)(C) because lineclearance tree trimmers are required to
comply with the minimum approach
distances in § 1910.269.57 The Agency
also concludes that line-clearance tree
trimmers need to be trained in the skills
and techniques necessary to maintain
the required minimum approach
distances for the same reasons that
qualified employees must be trained in
these subjects. (See the discussion of
minimum approach distances under the
summary and explanation for final
§ 1926.960(c)(1), later in this section of
the preamble.) OSHA believes that
training in these skills and techniques
are even more important for lineclearance tree trimmers, who, unlike
qualified employees, generally work
without electrical protective equipment
(see, for example, Ex. 0503).
Paragraph (b)(2)(v), which is being
adopted without change from the
proposal, requires qualified employees
to be trained in the recognition of
electrical hazards to which the
employee may be exposed and the skills
and techniques necessary to control or
avoid those hazards. Commenting on
proposed § 1910.269(a)(2)(ii)(E), which
is the general industry counterpart to
proposed § 1926.950(b)(2)(v), Mr. Kevin
Taylor of Lyondell Chemical Company
requested clarification of the training
required for workers who operate, but
do not maintain, 480-volt circuit
breakers (Ex. 0218). Workers operating
these circuit breakers need not be
56 Line-clearance tree trimming firms may need to
train their employees in the more protective of the
minimum approach distances in subpart S and
§ 1910.269 to ensure compliance both during work
that is covered by subpart S and work that is
covered by § 1910.269.
57 Even though line-clearance tree trimmers are
not generally qualified employees under § 1910.269,
paragraph (r)(1)(iii) of final § 1910.269 requires
them to maintain the minimum approach distances
specified in Table R–5, Table R–6, Table R–7, and
Table R–8.
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qualified employees unless the devices
are in areas restricted to qualified
employees (final §§ 1910.269(u)(4) and
(v)(4) and 1926.966(e)) or otherwise
expose the employees to contact with
live parts (final § 1910.269(l)(1) and
1926.960(b)(1)). Thus, assuming that
these workers are not qualified
employees, they would need to be
trained only as required by final
§§ 1910.269(a)(2)(i) and 1926.950(b)(1).
The scope of this training is described
earlier in this section of the preamble
under the discussion of final
§ 1926.950(b)(1).
OSHA proposed to supplement the
training requirements in paragraphs
(b)(1) and (b)(2) with requirements for
supervision and additional training in
paragraphs (b)(3) and (b)(4). These
requirements were taken directly from
existing § 1910.269(a)(2)(iii) and
(a)(2)(iv). The Agency explained in the
proposal that initial instruction in safe
techniques is not sufficient to ensure
that employees will use safe work
practices all of the time (70 FR 34834).
Continual reinforcement of this initial
training must be provided to ensure that
the worker uses the procedures he or
she has been taught. This reinforcement
can take the form of supervision, safety
meetings, prejob briefings or
conferences, and retraining.
Paragraph (b)(3), which is being
adopted without change from the
proposal, requires the employer to
determine, through regular supervision
(that is, supervision that takes place on
a periodic basis throughout the year)
and inspections conducted at least
annually, that each employees is
complying with the safety-related work
practices required by subpart V.
Paragraph (b)(4), also being adopted
without change from the proposal,
requires additional training (or
retraining) whenever:
• Regular supervision or an annual
inspection required by paragraph (b)(3)
indicates that the employee is not
following the safety-related work
practices required by subpart V,
• New technology, new types of
equipment, or changes in procedures
necessitate the use of safety-related
work practices that are different from
practices that the employee would
normally use, or
• The employee must use safetyrelated work practices that are not
normally used during his or her regular
job duties.
A note to paragraph (b)(4)(iii) explains
that retraining must be provided before
an employee performs a task that is
done less frequently than once a year.
Instruction provided in prejob briefings
is acceptable if it is detailed enough to
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fully inform the employee of the
procedures involved in the job and to
ensure that he or she can accomplish
them in a safe manner.
Mr. Leo Muckerheide of Safety
Consulting Services commented that the
requirements for retraining in proposed
paragraph (b)(4) were reactive rather
than proactive (Ex. 0180). He
recommended that the standard require
4 to 8 hours of retraining every 2 to 3
years, arguing that workers follow
proper safety practices immediately
after training, but drift away from those
practices as time goes on.
OSHA does not agree that the
retraining requirements in paragraph (b)
are exclusively reactive. Employees
performing work covered by the final
rule typically employ the safety-related
work practices required by the standard
on a daily or other regular basis. The
Agency believes that workers generally
will continue to follow these practices
over time and has no evidence that a
lack of regularly scheduled retraining
contributes to a failure to follow safe
work practices that are used frequently.
OSHA does recognize, however, that
retraining is important for work
practices that are employed
infrequently. Thus, paragraphs (b)(4)(ii)
and (b)(4)(iii) require employees to
receive additional training if they need
to use new or different safety-related
work practices or safety-related work
practices that are not part of their
regular job duties. For example, under
paragraph (b)(4)(iii), an employee who
is expected to administer CPR in the
event of an emergency needs retraining
if he or she has not used those
emergency practices over the course of
the previous year. Retraining would also
be required for an employee who needs
to climb a pole if it has been more than
a year since he or she has used poleclimbing practices.58 OSHA does not
believe that any changes to paragraph
(b)(4) are necessary and is adopting that
paragraph without change from the
proposal.
Under paragraph (b)(5), training
required by paragraph (b) can be
provided in a classroom or on-the-job,
or in both places. This paragraph is
taken directly from existing
§ 1910.269(a)(2)(v). The Agency has
found these types of instruction, which
provide workers an opportunity to ask
questions and have the employer
respond to them, to be most effective.
(See, for example, OSHA’s publication
58 OSHA interprets the phrase ‘‘must employ’’ in
paragraph (b)(4)(iii) to include both practices the
employer specifically assigns to the employee and
practices the employer expects the employee to be
prepared to use, such as emergency response
procedures.
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20349
‘‘Training Requirements in OSHA
Standards and Training Guidelines.’’)
OSHA received no comments on this
provision, and it is being adopted as
proposed.
Paragraph (b)(6) provides that training
given in accordance with § 1926.950(b)
has to result in employee proficiency in
required work practices and introduce
procedures necessary for subpart V
compliance. OSHA did not receive any
comments on this paragraph, which is
borrowed from existing
§ 1910.269(a)(2)(vi), and is adopting it
without change from the proposal.
Unless a training program establishes an
employee’s proficiency in safe work
practices and that employee then
demonstrates his or her ability to
perform the necessary work practices,
there will be no assurance that the
employee will work safely. An
employee who has attended a single
training class on a complex procedure,
for example lockout and tagging
procedures used in an electric
generating plant, will not generally be
deemed proficient in that procedure.
Paragraph (b)(6), and the demonstration
of proficiency requirement contained in
paragraph (b)(7) (discussed later), will
ensure that employers do not try to
comply with § 1926.950(b) by simply
distributing training manuals to
employees. These provisions require
employers to take steps to assure that
employees comprehend what they have
been taught and that they are capable of
performing the work practices mandated
by the standard. OSHA believes that this
maximizes the benefits of the training
required under the final rule.
Existing § 1910.269(a)(2)(vii) requires
employers to certify that each employee
has received required training. The
certification has to be made when the
employee demonstrates proficiency in
the relevant work practices and
maintained for the duration of the
employee’s employment. OSHA
proposed to eliminate this certification
requirement and to replace it with
paragraphs in both § 1910.269
(paragraph (a)(2)(vii)) and subpart V
(§ 1926.950(b)(7)) that simply require
the employer to determine that each
employee has demonstrated proficiency
in the necessary work practices. In
proposing this change, the Agency
aimed to reduce unnecessary paperwork
burdens on employers (70 FR 34835). In
the preamble to the proposal, OSHA
explained that, in the absence of
training certifications, compliance with
training requirements could be
determined through employee
interviews (id.). A note following this
proposed paragraph explained that,
although not required, employee
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training records could continue to be
used by employers to track when
employees demonstrate proficiency.
OSHA specifically requested comments
on whether the existing certification
requirement is necessary and whether
the proposed standard, without a
certification requirement, was
adequately protective.
OSHA received a lot of feedback on
this issue. Many rulemaking
participants supported OSHA’s
proposal. (See, for example, Exs. 0125,
0127, 0159, 0169, 0171, 0175, 0177,
0179, 0186, 0212, 0222, 0227.) For
instance, Mr. Brian Skeahan of Public
Utility District No. 1 of Cowlitz County
commented that the change from the
certification requirement to the
requirement to demonstrate proficiency
was an ‘‘acceptable modification,’’
pointing out that recording on-the-job
training can be burdensome (Ex. 0159).
Mr. Wilson Yancey of Quanta Services
provided similar comments, expressing
‘‘support [for] OSHA’s proposal to
require only that the employer ensure
that the employee is able to demonstrate
proficiency’’ (Ex. 0169). He commented
that the ‘‘certification requirement is an
unnecessary recordkeeping burden that
would be difficult to administer in
practice because of the way that crews
are spread out and would not advance
employee safety and health in any
material way’’ (id.). Mr. Brooke Stauffer
of the National Electrical Contractors
Association also supported the
proposal: ‘‘NECA supports the proposed
changes from certification of training to
demonstration of proficiency. We do not
support a requirement to keep records of
employee training, due to high turnover
in the line construction industry. Such
record-keeping also isn’t feasible to
document on-the-job training . . . .’’
(Ex. 0171). EEI commented that ‘‘in the
experience of EEI members, the existing
training certification requirement in
paragraph 1910.269(a)(2)(vii) has proven
to be of no value, and is unnecessary
and should be eliminated’’ (Ex. 0227).
Also, Southern Company told OSHA:
Since on-the-job training is recognized as
a method for training employees, it would be
difficult or impossible to maintain records for
this type of training. We agree that records
of training that are normally maintained
(classroom instruction or hands-on training
exercises) should be recognized as a method
for determining if an employee has been
trained. However, it is the employee’s ability
to demonstrate their proficiency which
should be the measure of the employee’s
ability to work safely. [Ex. 0212]
Other commenters objected to the
proposed move away from the
certification requirement, stressing the
importance of recordkeeping. (See, for
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example, Exs. 0200, 0213, 0230, 0505.)
For instance, Mr. Tommy Lucas of TVA
commented:
To ensure that employees have been
trained and demonstrated proficiency, the
training should be documented. Documented
training is necessary for managers and
supervisors to know whether or not the
employee is proficient in the skills required
for tasks being assigned. Having training
records available to managers and
supervisors will better protect employees.
[Ex. 0213]
IBEW similarly supported a
recordkeeping requirement for training,
commenting as follows:
The standard should require employers to
record employee training. The question that
needs [to be] asked is how, if training records
are not kept, can an employer comply with
requirements for initial and ongoing training?
Most training that is offered in this industry
is structured using somewhat universal
subjects and methods. Those employers that
are engaged in this type of training are most
likely recording initial training and any other
additional training that they may offer.
Recording of employee training will not
impose any unnecessary or costly
requirement on employers that they are not
currently doing. [Ex. 0230]
Mr. Donald Hartley with IBEW further
explained the union’s position in his
testimony during the 2006 public
hearing:
OSHA should require employers to certify
that employees are proficient in the tasks that
they are assigned to perform and to maintain
records documenting their demonstrated
proficiency. There is simply no way to
ensure that employers are actually certifying
employees if documentation is not required.
Moreover, the records can be used over time
to determine whether employees have
satisfied the training requirements in the past
and whether retraining or recertification is
necessary. [Tr. 874]
Mr. Steven Semler, counsel for ULCC,
asked that OSHA retain the existing
training certification requirement
because it ‘‘works well . . . and has
enhanced safety . . . by requiring the
checkoff of certification of employees in
writing’’ (Tr. 743). Mr. Scott Packard of
Wright Tree Service testified on behalf
of TCIA that the certification
requirement ‘‘has clearly raised the level
of safety in the line clearance tree
trimming industry overall’’ (Tr. 751).
The TCIA further commented:
The current and existing ‘‘shall certify’’
language has raised the level of safety in the
line clearance tree trimming industry as well
as in non-line clearance firms with exposure
to the electrical hazard and hence the need
to train and to certify. This requirement is
particularly important among smaller
employers with less sophisticated safety
programs.
Requiring ‘‘certification’’ of employees
having received the required safety training
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has imposed internally within line clearance
contractors’ and others’ training procedures
creation of failsafe mechanisms to
unambiguously assure the employee has
received the required safety training. The
newly-proposed method is a more
subjective—hence looser—requirement. [Ex.
0200; footnote omitted; emphasis included in
original.]
Mr. Peter Gerstenberger, also testifying
on behalf of TCIA, suggested that ‘‘it’s
the connotation of the word ‘certify’ that
just accords the whole process more
importance’’ (Tr. 811–812).
OSHA has carefully considered the
feedback it received on this issue and
has decided to adopt the requirement as
proposed, without a certification
requirement. OSHA believes this gives
employers maximum flexibility, while
still ensuring that employees have
demonstrated required proficiencies.
The Agency concludes that it is
particularly important to provide
flexibility for employers using less
formal (that is, on-the-job) methods to
train workers because, as noted by
Messrs. Stauffer and Yancey, it could be
challenging for these employers to
record training that occurs sporadically
and in circumstances that are not
conducive to the preparation of written
certifications. In addition, as noted in
the preamble to the proposal, the
Agency does not need training
certifications for enforcement purposes
under final § 1910.269 and subpart V
because compliance with the training
requirements can be determined
through interviews with management
and workers (70 FR 34835). Therefore,
the Agency believes that the plain
language of the final rule will be at least
as effective in protecting workers as a
requirement to certify these records; in
this regard, the plain language of the
final rule still requires employers to
determine that each employee
demonstrates necessary proficiencies.
OSHA also points out that Note 1 to
paragraph (b)(7) specifically clarifies
that the rule does not prohibit the
keeping of training records. In light of
the comments received, OSHA expects
that some employers will voluntarily
elect to prepare and maintain training
records for their own purposes in
tracking who has received training and
demonstrated the requisite level of
proficiency.
OSHA proposed a second note to
paragraph (b)(7) of § 1926.950 that
described how an employer may treat
training that an employee has received
previously (for example, through
previous employment). OSHA
explained in the preamble to the
proposal that employers relying on
training provided by others would need
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to take steps to verify that the employee
had been trained and to ensure that the
previous training was adequate for the
work practices the employee would be
performing (70 FR 34835). The proposed
note read:
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Employers may rely on an employee’s
previous training as long as the employer: (1)
Confirms that the employee has the job
experience appropriate to the work to be
performed, (2) through an examination or
interview, makes an initial determination
that the employee is proficient in the relevant
safety-related work practices before he or she
performs any work covered by this subpart,
and (3) supervises the employee closely until
that employee has demonstrated proficiency
in all the work practices he or she will
employ.
Several rulemaking participants noted
that some employees receive training
from third parties, such as unions, and
supported OSHA’s effort to recognize
the potential portability of training.
(See, for example, Exs. 0162, 0169,
0234.) For example, MYR Group stated:
‘‘MYR Group . . . supports allowing
reliance on prior training through
demonstration of proficiency—in the
circumstance of prior training not
conducted by the employer a
proficiency demonstration is a
reasonable means of avoiding
duplicative training’’ (Ex. 0162).
The line-clearance tree trimming
industry, however, claimed that the new
note would make it too difficult for an
employer to rely on training that its
employees received elsewhere. The tree
trimmers argued that closely
supervising all newly hired employees
would be unworkable. (See, for
example, Exs. 0174, 0200; Tr. 753–754.)
For instance, Mr. Steven Semler
representing ULCC argued that the note
would unnecessarily require the close
scrutiny of experienced and alreadytrained employees and suggested that
the high rate of turnover in the lineclearance tree trimming industry made
close supervision of all new hires
administratively impractical (Ex. 0174).
ULCC preferred existing
§ 1910.269(a)(2)(vii), which contained
the training certification requirement,
because, in its view, the existing
standard permitted an employer to
‘‘verify the [previous employer’s]
certification records and observe the
demonstrated proficiency of the newly
hired employee staff’’ (id.). According to
ULCC, ‘‘the current standard desirably
enable[d] continuity of operations with
trained personnel whose proficiency is
determined by verification of training
and observance of work’’ (id.). TCIA
echoed these arguments and stated that
the proposed new note ‘‘adds a new
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hardship to the employer without any
offset whatsoever in safety’’ (Ex. 0200).
OSHA did not impose any new
burdens on employers through proposed
Note 2 to paragraph (b)(7). The proposed
note simply explained one way for an
employer to comply with the
proficiency-demonstration requirement
in final paragraph (b)(7). Tree care
industry witnesses described the
process they use to determine the
proficiency of newly hired experienced
employees, and OSHA believes that
process is similar to the steps for
determining proficiency that were
described in proposed Note 2 (Tr. 715–
717, 805–806). For example, one treecare industry witness described his
company’s process for hiring an
experienced employee as follows:
[T]here would be face-to-face interviews.
There will be verification of prior
certifications and/or training. There will be
observations done and there will be field
evaluations [to verify] that . . . the
certification that they claim to possess they
do. [Tr. 805–806]
Although the tree care industry
appears to use the process that OSHA
envisioned in drafting the proposed
note, OSHA reworded the note in the
final rule to more closely match the
process described by the tree care
industry. The note in the final rule
explains that for an employee with
previous training, an employer may
determine that that employee has
demonstrated the required proficiency
using the following process: (1) Confirm
that the employee has the training
required by final § 1926.950(b), (2) use
an examination or interview to make an
initial determination that the employee
understands the relevant safety-related
work practices before he or she performs
any work covered by subpart V, and (3)
supervise the employee closely until
that employee has demonstrated the
required proficiency.
The revised note makes it clearer than
the proposed note that the process
described in the note is not mandatory.
Any process that ensures that the
employee is not treated as having
completed training until the employer
confirms that he or she has had the
training required by paragraph (b), and
has demonstrated proficiency as
required by paragraph (b)(7), is
acceptable. The revised language also
replaces the phrase ‘‘in all the work
practices he or she will employ’’ with
‘‘as required by this paragraph’’ at the
end of the note to make it clear that the
process is designed to ensure that the
employee demonstrates proficiency to
the employer as required by the final
rule.
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Since subpart V covers some transient
workers, and training is often provided
by previous employers or third parties
(for example, unions), some commenters
suggested that employers could benefit
from the development of a system for
storing and accessing training
information for all covered workers
(Exs. 0196, 0227). EEI noted the
potential value of such a system, but did
not think it should be an OSHA
requirement (Ex. 0227). Also, Mr. Lee
Marchessault with Workplace Safety
Solutions recommended that OSHA
consider recognizing a universal
training booklet, called a training
passport in some countries, that workers
would carry to prove to employers that
they have been trained and have
demonstrated their abilities (Ex. 0196;
Tr. 573–574).
OSHA understands the third-party
process by which many line workers are
trained. The Agency has adopted Note
2 to paragraph (b)(7) in the final rule
partly in recognition that this type of
training takes place. The final rule is
designed to allow employers to rely on
previous training conducted by unions,
previous employers, or other third
parties. In fact, it would be permissible
for employer groups, unions, or other
third parties to design and implement a
system such as the training passport
recommended by Mr. Marchessault,
provided that employers using the
system complied with relevant OSHA
training requirements. OSHA stresses
that it is the employer’s, not the
employee’s, obligation to determine that
the employee demonstrates proficiency
before he or she is deemed to have
completed the required training.
OSHA proposed to add provisions to
both subpart V and § 1910.269
concerning communication between
host employers (utilities) and the
contractors they hire to work on their
systems.59 As OSHA explained in the
preamble to the proposal, the work
covered by Subpart V is frequently done
by an employer working under contract
to an electric utility (70 FR 34835).
Traditionally, employers with electric
power generation, transmission, and
distribution systems have had a
workforce sufficient for the day-to-day
maintenance of their systems. These
employers usually hire contractors
when the work to be performed goes
beyond routine maintenance. Thus,
contractors typically construct new
transmission and distribution lines,
59 In this discussion, OSHA uses the term
‘‘electric utility’’ and ‘‘host employer’’
synonymously. In some cases, however, the host
employer may not be an electric utility. See the
discussion of the definition of ‘‘host employer’’
later in this section of the preamble.
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perform extensive renovations of
transmission and distribution lines
(such as replacing a large number of
utility poles or upgrading a line to a
higher voltage), do line-clearance tree
trimming, overhaul generation plants,
and repair extensive storm damage. Mr.
Donald Hartley of IBEW testified at the
2006 public hearing in this rulemaking
that ‘‘utilities are increasingly
contracting out work, both because
contractors bring expertise that the
utilities do not themselves possess and
as a cost-saving measure to reduce their
overall payroll and overhead’’ (Tr. 875).
In proposing the host-contractor
provisions, OSHA explained that, in
many (if not all) instances, sharing of
information between the electric utility
employer and the contractor is
necessary to adequately protect the
contractor’s employees from hazards
associated with work on the utility’s
facilities (70 FR 34838–34839). For
example, if the host employers and
contract employers do not coordinate
their procedures for deenergizing lines
and equipment, then contractor
employees could mistakenly believe
that a line is deenergized when it is not.
This mistake could have potentially
fatal results for contractor employees. In
a similar fashion, as OSHA also
explained in the preamble to the
proposal, the safety of electric utility
employees is affected by the contract
employer’s work (id.). For example, a
contractor’s work could cause an
overhead energized line to fall on a
deenergized line on which an electric
utility employee is working, creating
hazards for the electric utility employee.
Although electric utility employees do
not typically work with contract
employees, sometimes they do work
together. For example, it is common
practice for contract employees and
electric utility employees to work side
by side during emergency-restoration
operations, such as after a big storm (Ex.
0505; Tr. 392, 1379–1380). Additionally,
contractors in electric power generation
plants will be working near utility
employees who work in the plant (Tr.
985). The record also indicates that
utility and contract employees work
side by side in other situations,
including during outages on
transmission lines (Ex. 0505; Tr. 1380)
and while working in the same
substation (Ex. 0505; Tr. 313–314, 559).
Because in this host-contractor
relationship the work of (or information
possessed by) one affects the safety of
the other’s employees, OSHA believed
that it was necessary for host employers
and contractors to cooperate and
communicate with each other to provide
adequate protection for all employees
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maintaining or constructing electric
power generation, transmission, or
distribution facilities. Thus, OSHA
proposed requirements in § 1926.950 (as
well as in § 1910.269) to ensure the
necessary exchange of information
between host employers and contract
employers. The requirements in the
proposal were loosely based on similar
provisions in the Agency’s standard for
process safety management (PSM),
§ 1910.119(h).
IBEW agreed that there was a need for
host-contractor requirements in these
standards, explaining that it ‘‘fully
supports the basic principles underlying
OSHA’s proposals regarding the
reciprocal obligations of the host
employers and contract employers to
provide one another with information
necessary to safeguard their workforces’’
(Tr. 878).
Mr. Donald Hartley of IBEW testified
about the importance of host employers
and contract employers exchanging
‘‘critically important’’ information (Tr.
877–878). He elaborated that for
contractor employees to be ‘‘equipped to
deal with potential hazards associated
with this dangerous work, [they require]
access to information that may be in the
sole possession of the host employer’’
(Tr. 876). He continued:
[W]hile some contract employers report
that utilities routinely provide this
information with every job they contract out,
as we have heard, others have found that
utilities refuse to disclose that information
about operating conditions even when the
contract employers specifically request it.
Just as the host employer possesses
information critically important to the safety
of contract employees, the contract
employees may in the course of their work
discover conditions about which the host is
unaware, also recently testified to. This is
particularly true when contract employees
are working out in the field on equipment
that the host employer may not regularly
inspect. [Tr. 877–878]
OSHA received a number of
comments suggesting that it should not
include host-contractor provisions in
the final rule. The Agency has
considered these comments and
concluded that, although some changes
to the proposed regulatory text are
necessary (as described later in this
section of the preamble), the
information-sharing requirements in
§ 1926.950(c) of this final rule are
reasonably necessary and appropriate.
Some commenters took the position
that the extent to which host employers
and contract employers exchange
information with each other is an issue
best left to private contracts between the
parties. (See, for example, Exs. 0149,
0151, 0159, 0172, 0179, 0188.) For
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example, the Lewis County Public
Utility District commented:
We feel that any arrangement between a
contractor and host employer is best handled
by contractual language between the two
parties without OSHA involvement. This
includes how the host employer and
contractor communicate and exchange
information. [Ex. 0149].
Evidence in the record makes clear,
however, that relying on private
contracts has proven to be an ineffective
method of ensuring the adequate
exchange of information between hosts
and contractors. A number of
participants at the 2006 public hearing
explained that there are times when
contractors are unable to get the
information they need from utilities to
permit the contractors’ employees to
work safely. For example, Mr. Donald
Hartley of IBEW testified that
‘‘complying with [OSHA standards]
requires access to information that may
be in the sole possession of the host
employer’’ (Tr. 876). As noted earlier, he
also stated that some ‘‘utilities refuse to
disclose . . . information about
operating conditions even when the
contract employers specifically request
it’’ (Tr. 877). An ESCI representative
agreed, testifying: ‘‘I work with a
number of utility contractors that tell
me that [t]here are a number of things
that they are not provided that they
need’’ (Tr. 1240). Also, MYR noted that
‘‘although . . . the transfer of
information between utilities and
contractors has improved tremendously
over the last several years, issues still
exist in the industry today’’ (Tr. 1333).
In light of this evidence, OSHA
concludes that relying on the parties’
private contracts to serve this function
is unlikely to ensure that host
employers and contract employers
receive all of the information they need
to protect their workers.
Some commenters suggested that
OSHA does not have statutory authority
to adopt host-contractor provisions.
(See, for example, Exs. 0168, 0177,
0209, 0227, 0501.) For instance, EEI
commented:
The fundamental point is that the OSH Act
simply does not confer authority upon OSHA
to require one employer to be responsible for
the safety or health of another employer’s
employees. Any final rule that seeks to
impose duties on host employers and
`
contractors vis-a-vis each other will be
legally vulnerable. [Ex. 0227]
OSHA has clear authority to include
the host-contractor provisions in the
final rule. First, the plain language of
the OSH Act and its underlying purpose
support OSHA’s authority to place
requirements on employers that are
necessary to protect the employees of
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others.60 Second, congressional action
subsequent to passage of the OSH Act
recognizes this authority. Third, OSHA
has consistently interpreted its statutory
authority as permitting it to impose
obligations on employers that extend
beyond their own employees, as
evidenced by the numerous standards,
including several construction
standards, that OSHA has promulgated
with multiemployer provisions. Finally,
OSHA’s authority to place obligations
on employers that reach beyond their
own employees has been upheld by
numerous courts of appeals and the
OSHRC.
The purpose of the OSH Act is to
assure so far as possible safe and
healthful working conditions for every
working man and woman in the nation
(29 U.S.C. 651(b)). To achieve this goal,
Congress authorized the Secretary of
Labor to establish mandatory
occupational safety and health
standards. The Act broadly defines an
OSHA standard as a rule that ‘‘requires
conditions, or the adoption or use of one
or more practices, means, methods,
operations, or processes, reasonably
necessary or appropriate to provide safe
or healthful employment and places of
employment’’ (29 U.S.C. 652(8)). (See
Building & Constr. Trades Dep’t., AFL–
CIO v. Brock, 838 F.2d 1258, 1278 (D.C.
Cir. 1988).) OSHA standards must
prescribe measures that are appropriate
to protect ‘‘places of employment;’’
nothing in the statutory language
suggests that OSHA may do so only by
regulating an employer’s interactions
with its own employees. On the
contrary, the OSH Act’s broad language
gives OSHA almost ‘‘unlimited
discretion’’ to devise means to reach the
statutory goal. (See United Steelworkers
v. Marshall (Steelworkers), 647 F.2d
1189, 1230 (D.C. Cir. 1980).)
Similarly, Section 5(a)(2) of the OSH
Act provides that each employer ‘‘shall
comply with occupational safety and
health standards promulgated under’’
the OSH Act (29 U.S.C. 654(a)(2)).61
Nothing in this language suggests that
compliance is required only when
necessary to protect the employer’s own
60 As explained later in this section of the
preamble, the overall sharing of information that
will occur in accordance with the final hostcontractor provisions will help protect the
employees of both host employers and contract
employers.
61 This language is in marked contrast to the
language of Section 5(a)(1) of the OSH Act (known
as the ‘‘general duty clause’’), which requires each
employer to ‘‘furnish to each of his employees
employment and a place of employment which are
free from recognized hazards that are causing or are
likely to cause death or serious physical harm to his
employees’’ (29 U.S.C. 654(a)(1)). (See Brennan v.
OSHRC, 513 F.2d 1032, 1037–38 (2d Cir. 1975).)
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employees or that the employer is
entitled to endanger other employer’s
employees at the worksite.
Section 6(b)(7) of the OSH Act
specifically permits the Secretary to
‘‘prescribe the use of labels or other
appropriate forms of warning as are
necessary to insure that employees are
apprised of all hazards to which they
are exposed . . . and proper conditions
and precautions of safe use or exposure’’
(29 U.S.C. 655(b)(7)). (Notably, the
Agency’s authority to require warnings
is not limited to information that would
warn the employer’s own employees of
hazards.) Finally, Section 8(g)(2) of the
OSH Act generally affords the Secretary
authority to ‘‘prescribe such rules and
regulations as he may deem necessary to
carry out . . . responsibilities under’’
the OSH Act (29 U.S.C. 657(g)(2)).
In short, the statute focuses on
workplace conditions to effectuate the
OSH Act’s congressional mandate and
not on a particular employment
relationship. The OSH Act’s underlying
purpose is broad—to assure safe and
healthful working conditions for
working men and women—and
Congress made clear that it expected the
Act to protect all employees. (See H.
Rep. No. 91–1291, 91st Cong., 2d Sess.,
pp.14–16 (July 9, 1970).) Numerous
references in the legislative history of
the OSH Act discuss requiring
employers to provide a safe and
healthful ‘‘place of employment.’’ (See
for example, S. Rep. No. 91–1282, 91st
Cong., 2d Sess., p. 10 (Oct. 6, 1970).)
The OSH Act tasks OSHA with
promulgating rules that will create safe
places of employment, notwithstanding
the many varied employment
relationships that might exist at a
worksite.
Subsequent congressional action has
also recognized OSHA’s authority to
impose responsibilities on employers to
protect employees who are not their
own. For example, Congress directed
OSHA to develop a chemical process
safety standard (the PSM Standard)
requiring employers to ‘‘ensure
contractors and contract employees are
provided appropriate information and
training’’ and to ‘‘train and educate
employees and contractors in
emergency response’’ (Pub. L. 101–549,
Title III, Sec. 304, Nov. 15, 1990, 104
Stat. 2576 (reprinted at 29 U.S.C. 655
Note)). This is a clear ratification of the
Agency’s authority to require employers
to protect the employees of others.
Congress also approved of the Agency’s
authority when it relied on the
provisions of OSHA’s Hazard
Communication Standard in
promulgating the Emergency Planning
and Community Right-to-Know Act
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20353
(EPCRA), 42 U.S.C. 11001–11050. The
Hazard Communication Standard
requires, in part, that manufacturers and
importers of hazardous chemicals
provide information for the benefit of
downstream employees.62 (See 29 CFR
1910.1200; see also Martin v. American
Cyanamid Co., 5 F.3d 140, 141 (6th Cir.
1993) (noting that the Hazard
Communication Standard requires ‘‘that
a manufacturer of hazardous chemicals
inform not only its own employees of
the dangers posed by the chemicals, but
downstream employers and employees
as well’’).) Congress incorporated
provisions of the Hazard
Communication Standard in EPCRA as
a basis for triggering obligations on
owners or operators of facilities
producing hazardous chemicals to
provide local governments with
information needed for emergency
response. Had Congress not approved of
the multiemployer provisions in the
Hazard Communication Standard, it
would not have approved of it as a basis
for obligations in EPCRA.
Furthermore, OSHA has consistently
interpreted the OSH Act as authorizing
it to impose multiemployer obligations
in its standards. In addition to the
Hazard Communication Standard and
the PSM Standard already noted, OSHA
included multiemployer provisions in
its standard for powered platforms,
which requires that a building owner
inform employers that the building
installation has been inspected and is
safe to use. (See 29 CFR 1910.66(c)(3).)
OSHA also has imposed multiemployer
obligations in construction standards.
For example, OSHA exercised its OSH
Act authority to promulgate provisions
in the Asbestos Standard for the
construction industry that require
building owners to communicate the
presence of asbestos or presumed
asbestos-containing materials to certain
employers with employees who may be
exposed to such materials. (See 29 CFR
1926.1101(k).) In OSHA’s Steel-Erection
Standard, the Agency imposed duties on
controlling contractors to ensure that
site conditions are safe for steel
erection. (See 29 CFR 1926.752(c).)
More recently, OSHA promulgated rules
requiring controlling entities and
utilities to take steps to protect other
employers’ employees during crane
operations. (See 29 CFR 1926.1402(c),
1926.1402(e), 1926.1407(e),
1926.1408(c), and 1926.1424(b).)
Finally, OSHA’s authority to impose
these provisions is confirmed by the
62 As a rationale for those provisions, OSHA
explained that chemical manufacturers and
importers are in the best position to develop,
disseminate, and obtain information about their
products. (See 48 FR 53280, 53322, Nov. 25, 1983.)
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decisions of numerous courts of appeals
and the Review Commission. For
example, the Third Circuit upheld the
information-sharing requirements in the
Asbestos Standard for the construction
industry, noting: ‘‘We are not convinced
that the Secretary is powerless to
regulate in this [way], especially given
the findings she has made regarding the
importance of building owners in the
discovery and communication of
asbestos hazards.’’ Secretary of Labor v.
Trinity Indus., Inc. (Trinity), 504 F.3d
397, 402 (3d Cir. 2007). (See also
Universal Constr. Co. v. OSHRC, 182
F.3d 726, 728 (10th Cir. 1999) (following
decisions from Second, Sixth, Seventh,
Eighth, and Ninth Circuits holding that
an employer’s duties and OSHA
standards may extend beyond an
employer’s own employees).)
EEI asserted that § 1910.12(a)
precludes host-contractor requirements
in subpart V, commenting:
Section 1910.12(a), standing alone,
precludes OSHA from requiring an employer
covered by the final Part 1926 rule to take
any responsibility for the safety of another
employer’s employees, certainly insofar as
the final standard purports to regulate
‘‘construction.’’ [Ex. 0227].
OSHA disagrees with EEI. Paragraph
(a) of § 1910.12 provides:
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The standards prescribed in part 1926 of
this chapter are adopted as occupational
safety and health standards under section 6
of the Act and shall apply, according to the
provisions thereof, to every employment and
place of employment of every employee
engaged in construction work. Each employer
shall protect the employment and places of
employment of each of his employees
engaged in construction work by complying
with the appropriate standards prescribed in
this paragraph.
Paragraph (a) of § 1910.12 has no
bearing on the host-contractor
requirements in the final rule because
the Agency clearly intends to assign
specific responsibilities to host
employers and contract employers, and
the final regulatory text plainly reflects
that intent. (See Trinity, 504 F.3d at 402
(rejecting argument premised on
§ 1910.12(a) where ‘‘the regulation at
issue . . . specifically applie[d] to
building owners’’).) Moreover, the
Eighth Circuit and the Review
Commission have squarely rejected
EEI’s argument. In Solis v. Summit
Contractors, Inc. (Summit Contractors),
the Eighth Circuit concluded that
§ 1910.12(a) is ‘‘unambiguous’’ in that it
does not preclude OSHA from citing an
employer when only employees of other
employers are exposed to the hazard in
question (558 F.3d 815, 825 (8th Cir.
2009)). The Review Commission
similarly held that § 1910.12(a) does not
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prevent OSHA from citing a controlling
employer that does not have exposed
employees (Summit Contractors, Inc.,
23 BNA OSHC 1196 (No. 05–0839, Aug.
19, 2010)). Both the Eighth Circuit and
the Review Commission emphasized the
language in § 1910.12(a) establishing a
duty on the part of employers to protect
‘‘places of employment’’ as well as
employees. (See, for example, Summit
Contractors, 558 F.3d at 824.) The first
sentence in § 1910.12(a) makes the
construction standards applicable to
every employment and to every ‘‘place
of employment’’ of every construction
employee, and the second sentence, by
providing that each employer must
protect ‘‘places of employment,’’ does
not negate the broad reach of the first
sentence.
Moreover, the history of § 1910.12(a)
reveals that the purpose of this
provision is to extend, not limit, the
Agency’s authority. Indeed, § 1910.12(a)
is located in a subpart entitled
‘‘Adoption and Extension of Established
Federal Standards,’’ which was
established to extend OSHA’s authority
through adoption of the Construction
Safety Act’s standards. (See 29 CFR
1910.11(a) (‘‘The provisions of this
subpart . . . adopt[,] and extend the
applicability of, established Federal
standards . . . with respect to every
employer, employee, and employment
covered by the Act.’’).) Thus, neither the
language nor the context of § 1910.12(a)
suggest a conflict with the informationsharing requirements in this final rule.
Some commenters asserted that the
proposed host-contractor provisions
inappropriately expanded or conflicted
with OSHA’s existing Multi-Employer
Citation Policy (CPL 02–00–124 (Dec.
10, 1999)). (See, for example, Exs. 0162,
0167, 0170, 0207, 0237.)
These comments reflect a
misunderstanding of both the proposal
and the multiemployer citation policy.
The host-contractor provisions do not
rely on, or modify, the Agency’s
multiemployer enforcement policy. (See
Trinity, 504 F.3d at 402 (distinguishing
an enforcement action under the
multiemployer provisions of the
Asbestos Standard for construction from
cases in which the Agency invoked the
multiemployer citation policy).) Rather,
the multiemployer citation policy and
the host-contractor provisions represent
separate exercises of OSHA’s statutory
authority to protect places of
employment. The host-contractor
provisions and the multiemployer
enforcement policy operate in different,
yet entirely consistent, ways to permit
the Agency to fulfill its statutory
mission.
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OSHA’s multiemployer citation
policy simply recognizes the existing
responsibilities of different employers at
multiemployer worksites under the Act
and OSHA standards. For example,
employers have a duty not to create
hazardous conditions that violate OSHA
standards, regardless whether it is their
own employees or another employer’s
that they endanger. (Employers who do
so are referred to as ‘‘creating
employers.’’) And employers have a
duty to protect their own employees
from violative conditions, even if
created by another employer. Such
‘‘exposing employers’’ must take
reasonable steps to correct the hazards
or otherwise protect their workers.
Similarly, ‘‘controlling employers,’’ that
is, employers with general supervisory
authority over safety and health at a
worksite, by virtue of that authority,
have certain responsibilities to prevent
and detect violations affecting
employees at the workplace.
When OSHA promulgates new safety
and health standards, it does so against
this background principle that
employers share responsibility for
working conditions, and thus for OSHA
compliance, at multiemployer
worksites. Therefore, when the Agency
issues a new safety or health standard,
it is with the intention that creating,
exposing, and controlling employers at
multiemployer worksites will exercise
their respective responsibilities to
ensure that affected employees are
protected as required by the standard.
In some situations, however, the
general background principles reflected
in the multiemployer policy will not be
sufficient to ensure the safety of
workplaces; in those instances, OSHA
may find it necessary to impose
additional or more specific obligations
on particular employers to protect
workers. The host-contractor provisions
in this final rule, as well as similar
information-sharing provisions in the
Hazard Communication Standard, the
PSM Standard, and the Asbestos
Standard for construction, are examples
of the Agency regulating in this manner.
In this rulemaking, OSHA determined
that the final host-contractor provisions
are necessary, in addition to the general
background responsibilities employers
have, to ensure the safety of affected
employees. Not all utilities (or host
employers) will have sufficient
authority over, or relationships with,
contractor worksites to qualify as
controlling employers under the
multiemployer citation policy. In
addition, the final rule prescribes with
specificity the information-sharing
responsibilities of hosts and contractors.
The specific information-sharing
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requirements in the host-contractor
provisions are necessary to ensure that
critical information sharing and
coordination take place at all
workplaces where employees perform
work covered by the final rule.
Some commenters argued that the
host-contractor provisions could create
employer-employee relationships
between host employers and contractor
employees. (See, for example, Exs. 0173,
0178.) For instance, the Farmers Rural
Electric Cooperative Corporation
commented:
It is up to the contractor and the employees
of that firm to perform this work, under their
supervision and direction, using their work
practices and safety rules. Should we as hosts
begin to direct their work, provide
supervision of that work, oversee their safety
practices, the IRS would then say they are
our employees and are entitled to benefits.
[Ex. 0173]
Also, some commenters suggested, more
generally, that the host-contractor
provisions could expand the potential
legal liability of the respective
employers. (See, for example, Exs. 0168,
0187, 0220, 0226.) A few commenters
argued that in these ways the proposed
host-contractor provisions went so far as
to violate the OSH Act. For example, the
National Association of Home Builders
commented:
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[W]e also believe that OSHA’s multiemployer language in the proposed rule in
Subpart V impermissibly expands the
common law liability of host/general
contractors in violation [of Section 4(b)(4)] of
the OSH Act. [Ex. 0168].
OSHA concludes that, under any of
the potentially applicable legal tests for
an employment relationship, the final
host-contractor provisions are unlikely
to result in one employer exercising the
type or degree of control over the
employees of another employer that
would create an employer-employee
relationship when one otherwise would
not have existed. (See, for example,
Nationwide Mutual Ins. Co v. Darden,
503 U.S. 318 (1992) (common-law test
for determining who is an ‘‘employee’’);
Antenor v. D&S Farms, 88 F.3d 925
(11th Cir. 1996) (factors relevant to
determining whether two employers are
‘‘joint employers’’ of an individual
employee for purposes of the Fair Labor
Standards Act); Weber v. C.I.R., 60 F.3d
1104 (4th Cir. 1995) (test for
determining whether there is an
employment relationship for income tax
purposes).)
OSHA also disagrees with the
commenters’ claim about Section 4(b)(4)
of the OSH Act. That provision states:
Nothing in [the OSH] Act shall be
construed to . . . in any manner affect any
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workmen’s compensation law or to enlarge or
diminish or affect in any other manner the
common law or statutory rights, duties, or
liabilities of employers and employees under
any law with respect to injuries, diseases, or
death of employees arising out of, or in the
course of, employment. [29 U.S.C. 653(b)(4)]
This provision serves two purposes:
First, it establishes that the OSH Act
does not create a private right of action.
(See, for example, Crane v. Conoco, Inc.,
41 F.3d 547 (9th Cir. 1994).) Second, it
makes clear that the duties and
liabilities imposed under the OSH Act
do not displace the duties and liabilities
that exist under State tort and workers’
compensation schemes. (See, for
example, Frohlick Crane Serv., Inc. v.
OSHRC, 521 F.2d 628 (10th Cir. 1975).)
OSHA acknowledges that State courts
are free to permit the use of OSHA
regulations, including these final hostcontractor provisions, as evidence of a
standard of care in a negligence action.
(See, for example, Knight v. Burns,
Kirkley & Williams Constr. Co., 331
So.2d 651 (Ala. 1976).) However, it does
not follow that regulations used in that
fashion are invalid under Section 4(b)(4)
on the ground that they expand
employers’ common-law liabilities, a
result that would limit the Secretary’s
rulemaking authority to issuing
regulations that codify duties already
owed by employers at common law.
Such a result would be inconsistent
with Congressional intent in
promulgating the OSH Act, and no court
has ever invalidated an OSHA
regulation on the ground that it violates
Section 4(b)(4). Indeed, courts have
squarely rejected the argument that
Section 4(b)(4) precludes multiemployer
enforcement practices. For example, in
Summit, the Eighth Circuit concluded
that OSHA’s multiemployer citation
policy did not violate Section 4(b)(4),
explaining that even though it could
‘‘increas[e] an employer’s liability at
common law[,]’’ the policy ‘‘neither
creates a private cause of action nor
preempts state law’’ (558 F.3d at 829).
(See also Steelworkers, 647 F.2d at
1234–36.)
OSHA decided to adopt the proposed
host-contractor provisions, with some
substantial modifications (described
later in this section of the preamble), in
the final rule. Before addressing each
specific provision, however, OSHA
must first address the scope of these
requirements.
The proposal defined a ‘‘host
employer’’ as ‘‘[a]n employer who
operates and maintains an electric
power transmission or distribution
installation covered by subpart V of this
Part and who hires a contract employer
to perform work on that installation.’’
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20355
This definition included electric
utilities and other employers that
operate and maintain electric power
transmission or distribution
installations. However, it did not
include employers that own, but do not
operate and maintain, such
installations. The Agency believed that
entities that do not operate or maintain
these installations would generally not
have the expertise necessary to work
safely on transmission or distribution
lines and equipment and would have
little hazard-related knowledge to pass
on to contractors. In addition, the
employees of such entities would have
little if any exposure to hazards created
by a contract employer. The Agency
invited comments on whether excluding
such employers from the host-contractor
provisions would unduly jeopardize
employee safety and whether any of the
host-contractor provisions could
reasonably be applied to such
employers.
Some commenters, such as Energy
United EMC (Ex. 0219), supported the
proposed exclusion of owners that do
not operate or maintain installations.
Ohio Rural Electric Cooperatives
commented: ‘‘If an employer only owns
but does not actually operate its own
lines or equipment then that employer
would certainly not be able to pass on
any useful information to a contractor’’
(Ex. 0186).
IBEW took the position that
‘‘[e]xcluding such employers from any
host-contract employer provisions, in
general, should not jeopardize employee
safety,’’ but questioned whether those
entities may make ‘‘decisions on how
the system will be operated, such as
switching procedures and load transfer,
that . . . could have a direct impact on
worker safety’’ (Ex. 0230). The union
went on to suggest that ‘‘[w]hatever
entity has the responsibility and/or
decision making power as to how the
system is operated should be included
in the proposed provisions’’ (id.).
Others commented that the hostcontractor provisions should apply to
all system owners. Ms. Susan O’Connor
of Siemens Power Generation
commented, for example, that excluding
owners that do not perform operations
or maintenance could jeopardize
employee safety ‘‘in situations where
host employers might use this provision
as a loophole to avoid regulation’’ (Ex.
0163). Ms. O’Connor suggested that a
utility could ‘‘eliminate [its] qualified
maintenance department and outsource
. . . maintenance to avoid dealing with
this regulation’’ (id.). MYR Group also
‘‘believe[d] that the protections afforded
to contractors through the host
employer obligations should apply
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regardless of whether the host actually
operates the installation’’ (Ex. 0162).
MYR thought that ‘‘[s]erious and
inequitable problems could arise from
failure to apply the proposed rule
requirements on host employers that
own but do not operate their electric
utility installations’’ (id.).
OSHA considered the record and
concludes that the host employer
should be the employer that is in the
best position to have information on the
design, operation, and condition of an
electric power generation, transmission,
or distribution system. Based on this
principle, OSHA decided that an
employer that controls how the system
is operated, such as switching
procedures and load transfer, should not
be excluded from the host-contractor
provisions. Depending on the type of
work practices used, such operational
control could have a direct impact on
worker safety. For example, an
employer that controls the operation of
an electric power generation,
transmission, or distribution system
could institute new switching
procedures without informing
contractors or coordinating the new
procedures with contractors (Ex. 0230).
In addition, because an employer, to fall
within the proposed definition of ‘‘host
employer,’’ needed to operate and
maintain the installation and hire the
contractor, it would have been possible
under the proposal to have scenarios in
which there was no host employer, such
as if one employer owned the
installation (and hired the contractor)
and a different employer operated or
maintained the installation. This result
could have undermined the
information-sharing requirements
altogether.
The Agency is revising the definition
of ‘‘host employer’’ to include
employers that operate installations or
control procedures for operation of
installations without regard to whether
the employer owns the installation. In
addition, OSHA is deleting the reference
to ‘‘maintenance’’ in the final definition
of ‘‘host employer’’ because the Agency
believes that an employer that only
maintains an electric power generation,
transmission, or distribution system is
unlikely to have knowledge of the
design, operation, and condition of the
installation; employers that perform
such maintenance may be contractors
hired by an electric utility. (See, for
example, Tr. 403, 1200–1201.)
Maintenance contractors will need
information from the employer that
operates or controls the operation of the
installation, as would any other
contractor. The final rule states that an
employer that operates, or that controls
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the operating procedures for, an electric
power generation, transmission, or
distribution installation on which a
contract employer is performing work
covered by subpart V is a host employer.
A note to the definition of ‘‘host
employer’’ provides that OSHA will
treat the electric utility or the owner of
the installation as the host employer if
it operates or controls operating
procedures for the installation. If the
electric utility or installation owner
neither operates nor controls operating
procedures for the installation, OSHA
will treat the employer that the utility
or owner has contracted with to operate
or control the operating procedures for
the installation as the host employer. In
no case will there be more than one host
employer. (See the definition of ‘‘host
employer’’ in final § 1926.968.)
The revised definition incorporates
IBEW’s recommendation that the
Agency focus on the entity that has
control over the system. OSHA believes
any such entity is likely to have critical
safety-related information about the
system. In addition, the revised
language renders Ms. O’Connor’s
comment moot; the revised language
ensures that an entity that is in a
position to have information that affects
the safety of contractor employees will
be identified as a host employer under
the final rule.63 Note that OSHA has
added electric power generation
installations to the installations covered
by the definition of ‘‘host employer’’ in
subpart V for consistency with the
definition of this term in § 1910.269.
In addition, the definition in the final
rule removes the criterion that the host
employer be the entity that hires the
contractor. The record indicates that
various entities hire contractors to work
on electric power generation,
transmission, and distribution
installations. For example, utility
owners hire contractors to perform
maintenance (Ex. 0186; Tr. 403). In
addition, some contractors subcontract
some of their work (Tr. 315–316, 1380–
1381). Subcontractors will be treated as
‘‘contract employers’’ under the final
rule even though the host does not hire
them directly.64 The standard’s
information-exchange requirements
hinge on the need to exchange
information between the entity that
63 The definition of host employer in the final
rule also removes any confusion over whether a
holding company that owns a utility company’s
outstanding stock, which is a common practice, or
the electric utility itself ‘‘owns’’ the installation.
64 As explained later in this section of the
preamble, ‘‘contract employer’’ is defined as: ‘‘An
employer, other than a host employer, that performs
work covered by subpart V of this part under
contract.’’
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operates or controls operating
procedures for the system and entities
that are performing maintenance or
construction work on the system. The
type of contractual relationship that
exists between the host employer and
contract employers does not change the
need for this information exchange.
OSHA realizes that the final rule will
require some employers to exchange
information with entities with which
they have no direct contractual
relationship. These employers can
either exchange information directly
with each other or can arrange to handle
their information exchange through
contacts with entities that do have
contractual relationships with the other
employer. For example, an electric
utility transmitting information to an
employer under contract to perform
work on the installation could instruct
(or contract for) that contractor to share
the same information with any
subcontractors hired to perform work
under the contract. Ultimately, however,
it is the host employer’s responsibility
to ensure that whatever procedures it
uses are adequate to get the required
information to all ‘‘contract employers’’
working on the installation. Paragraph
(c)(3) of final § 1926.950 (discussed later
in this section of the preamble) requires
host employers and contract employers
to coordinate their work rules and
procedures; part of this coordination
involves establishing appropriate
procedures for exchanging information
in accordance with the host-contractor
provisions.
The other issue involving coverage
under the host-contractor provisions
pertains to line-clearance tree trimming.
OSHA proposed to exclude from the
host-contractor requirements work done
by line-clearance tree trimmers who are
not qualified employees. As discussed
earlier in this section of the preamble,
line-clearance tree-trimming work is
covered by § 1910.269. Paragraph
(a)(1)(i)(E)(2) of existing § 1910.269 lists
the paragraphs of that section that apply
to work performed by line-clearance tree
trimmers who are not qualified
employees, and OSHA did not propose
to add the host-contractor provisions to
that list.
By not proposing to modify existing
§ 1910.269(a)(1)(i)(E)(2), OSHA would
not have applied the host-contractor
provisions to line-clearance treetrimming operations performed by
unqualified employees. However, as
long as qualified employees are using
electrical protective equipment, these
employees would be permitted to come
much closer to energized parts than
unqualified employees. The Agency
believed that qualified employees
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performing line-clearance tree-trimming
work in proximity to energized lines
and equipment face hazards similar to
contract power line workers and should
receive similar protection.65
OSHA requested comments on
whether its proposed approach for
dealing with line-clearance treetrimming work under the hostcontractor provisions unduly
jeopardized employee safety and
whether any of the host-contactor
provisions could reasonably be applied
to tree-trimming work performed by
line-clearance tree trimmers who are
unqualified employees. Many
commenters supported OSHA’s
proposal. (See, for example, Exs. 0126,
0174, 0177, 0200, 0201, 0213, 0219,
0227.) For instance, EEI agreed ‘‘that
line clearance tree-trimming contractors
should be excluded from the
requirement,’’ explaining: ‘‘Host utilities
are usually not familiar with the hazards
associated with trimming trees and
routinely rely on the expertise of the
line clearance tree-trimming contractors
to perform that work in a manner which
ensures the safety of their employees’’
(Ex. 0227). These comments were
echoed by ULCC, which ‘‘commended’’
OSHA’s proposal to exclude work done
by line-clearance tree trimmers who ‘‘do
not work on or touch electric supply
lines’’ from the host-contractor
provisions (Ex. 0174). ULCC urged the
Agency to maintain this exclusion in the
final rule, commenting:
[T]he wisdom of the exclusion is manifest:
for, the rationale of the proposed ‘‘hostcontractor’’ provisions . . . is to apply the
utilities’ expertise to utility contractors
performing utilities’ typical work—in effect,
to force down utilities’ safety expertise onto
their electric-work contractors in order to
raise the safety experience rate of those
contractors to the better safety rate of the
utilities who employ them. Such policydriver for applying ‘‘host-contractor’’ to
utility contractors performing electric utility
(i.e. lineman) ‘‘qualified’’ work, simply is
inapplicable to line clearance work: for, the
utilities hire line clearance contractors
because line clearance contractors are
arborists who are specialists in vegetation
management—precisely skills which the
utilities contract out because they typically
do not have that expertise in tree growth, tree
trimming techniques, tree rigging, tree
removal, vegetation management, etc. In
short, utilities simply do not have the
institutional expertise of line clearance tree
knowledge to develop and direct line
clearance safety practices of line clearance
contractors via ‘‘host-contractor’’ provisions.
65 For a full discussion of why § 1910.269 applies
different requirements to line-clearance treetrimming operations depending on whether they are
performed by qualified or unqualified employees,
see the preamble to the 1994 § 1910.269 final rule
(59 FR 4336).
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. . . So, the ‘‘force-down’’ premise of ‘‘hostcontractor’’ simply does not apply to line
clearance. [Id.; emphasis included in
original.]
Duke Energy commented that ‘‘[t]here
should be no expectation that host
employers provide information on treetrimming hazards to line-clearance tree
trimming contractors,’’ suggesting that
‘‘[a]pplying the host-contract employer
provisions [in the context of lineclearance tree trimming] will be very
difficult’’ (Ex. 0201).
Some commenters, however, advised
against the proposed exclusion and
argued that all line-clearance tree
trimmers should be covered by the hostcontractor provisions. (See, for example,
Exs. 0162, 0186, 0230, 0234.) IBEW, for
instance, commented:
Line-clearance tree-trimming work could,
in some instances, be affected by the host
employer[’]s operation of the system.
Lockout/Tagout procedures during service
restoration are one example where contractor
employee safety could be jeopardized if lineclearance tree-trimming contractors are
excluded from all provisions of the proposed
host-contract employer provisions. At a
minimum, information regarding circuit
conditions, changes in conditions, and
lockout/tagout applications should be
communicated by the host employer to the
contractor employer. [Ex. 0230]
The Ohio Rural Electrical
Cooperatives agreed, also suggesting
that all line-clearance tree trimmers be
covered by the host-contractor
requirements. That organization
explained that tree trimmers ‘‘might not
need as much information as a line
contractor but they still need to know
for sure which lines are energized,
which are on single-shot protection,
etc.’’ (Ex. 0186). Mr. Wilson Yancey of
Quanta Services noted that ‘‘[w]hether
an employee is qualified or not, hazards
will exist that are unique to the host
employer’’ (Ex. 0234). He believed that
the proposal to leave some lineclearance tree trimmers out of the hostcontractor requirements was ‘‘not wellfounded and might unduly jeopardize
employee safety’’ (id.).
The Agency recognizes that lineclearance tree trimmers do not face
exactly the same hazards as line
workers. However, the record indicates
that host employers have information
that line-clearance tree trimmers need
so that they can perform their work
safely (Ex. 0505; Tr. 642–643, 686–688,
775). For example, Mr. Mark Foster of
Lucas Tree Experts testified that line
workers will generally inform tree crews
that a line is about to be reenergized (Tr.
642–643). In addition, ULCC’s
posthearing brief indicated that ‘‘line
clearance tree trimmers necessarily
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must rely upon information from utility
representatives that the line has been
deenergized, isolated and grounded
when those procedures are appropriate’’
and that the ‘‘safety of line clearance
tree trimmers would be enhanced by
. . . utilities being required, by OSHA
standard, to give [certain] information to
line clearance tree trimmers’’ (Ex. 0502).
Not only do line-clearance tree
trimmers need information from
utilities, but line-clearance tree
trimming contractors often have
important safety information for
utilities, for example, information they
discover in the course of work about
hazardous conditions that could affect
utility employees. Such conditions can
include downed power lines,
transformer problems, and insulator and
pole issues (Tr. 665, 689–690, 787–788).
Upon considering the record, it has
become apparent to OSHA that: (1)
There is a need for information
exchange between host employers and
tree-trimming contractors and (2) the
host-contractor provisions should apply
to all line-clearance tree trimming.
Therefore, the Agency added
§ 1910.269(a)(3) to the list of paragraphs
denoted in final § 1910.269(a)(1)(i)(E)(2)
to cover line-clearance tree-trimming
operations performed by line-clearance
tree trimmers who are not qualified
employees.
As noted earlier, some commenters
maintained that utilities hire contractors
for their expertise and knowledge about
particular hazards and rely on those
contractors to use that expertise to
protect their (that is, the contractors’)
own employees. (See, for example, Exs.
0127, 0172, 0173, 0177, 0200, 0207,
0227.) For instance, Mr. Frank
Brockman with Farmers Rural Electric
Cooperatives Corporation stated, ‘‘We,
as host employers, hire contractors to do
specific jobs, often that we do not have
the knowledge, expertise, equipment or
manpower to accomplish.’’ He
maintained that ‘‘[c]ontractors are
responsible for their employees’ safety’’
(Ex. 0173). SBA commented that ‘‘the
host is usually not present at these
worksites and often does not possess
expertise in the type of work being
performed’’ and noted that ‘‘many of the
SERs questioned whether the hostcontractor provisions are appropriate for
the electric power industry at all’’ (Ex.
0207).
Some comments specifically
addressed the issue of whether lineclearance tree trimming firms should be
covered by the host-contractor
provisions. For example, Consumers
Energy stated, ‘‘Host utilities are usually
not familiar with the hazards associated
with trimming trees and routinely rely
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on the expertise of the line clearance
tree-trimming contractors to perform
that work in a manner which ensures
the safety of their employees’’ (Ex.
0177). In addition, TCIA stated:
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OSHA makes the correct assertion that the
utility must have a shared expertise with the
contractor in order to specify its safety
standards for the contractor to follow. In
stark contrast, utilities typically contract line
clearance tree trimming because of their lack
of expertise in that subject. [Ex. 0200;
emphasis included in original]
OSHA recognizes that contractors
may have specific expertise that host
employers do not have. However, the
Agency does not believe that this is a
valid reason not to require the type of
information exchange required by the
final rule. As noted earlier, electric
utilities have information about their
systems that the contractors do not
have. The Agency also believes that
contractors, especially those hired for
expertise in a particular area, have
information about hazardous conditions
related to their work that host
employers do not have (for example, the
dangers posed to the host employer’s
employees from chippers and falling
tree limbs). In addition, when one
employer’s activities may endanger
another employer’s employees, the
Agency believes that it is essential for
the two employers to coordinate their
activities to ensure that all employees
are adequately protected. For example,
as noted later in this section of the
preamble, it is important for an
electrical contractor to coordinate
procedures for deenergizing and
grounding lines and equipment with the
host employer. Similarly, it is important
for line-clearance tree trimming firms to
coordinate their work with host
employers and to inform host employers
of hazardous conditions posed by the
tree-trimming work to ensure that the
host employers’ employees are not
exposed to tree-trimming hazards about
which those employees have received
no training.
OSHA proposed to define ‘‘contract
employer’’ as ‘‘[a]n employer who
performs work covered by subpart V of
this part for a host employer.’’ OSHA
did not receive any significant comment
on this definition. However, OSHA is
revising the definition to include any
‘‘work covered by subpart V of this part
under contract’’ rather than just work
‘‘for a host contractor.’’ This revision
correlates the definition of ‘‘contract
employer’’ with the revised definition of
‘‘host employer,’’ which no longer
provides that an employer must ‘‘hire’’
another employer to be a host employer.
This revision makes it clear that an
employer performing subpart V work
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under contract is covered as a ‘‘contract
employer’’ by the host-contractor
provisions in final paragraph (c)
regardless of whether the entity for
which the work is being performed is
the ‘‘host employer’’ or another
‘‘contract employer.’’ Contract
employers under the final rule may
include painting contractors, lineconstruction contractors, electrical
contractors, and any other contractors
working on the construction of electric
power transmission and distribution
lines. (For final § 1910.269, contract
employers will also include contractors
working on covered electric power
generation installations, such as boilermaintenance contractors, conveyorservicing contractors, and electrical
contractors.) The definition of ‘‘contract
employer’’ does not include contractors
that might be present at a jobsite where
some work performed is covered by
subpart V, but that are not performing
covered work.
Paragraph (c) of final § 1926.950
contains requirements for the transfer of
information between host employers
and contract employers. In the proposal,
OSHA entitled this paragraph
‘‘Contractors.’’ After considering the
comments received, the Agency
concludes that the proposed title does
not reflect the true scope of the
paragraph’s provisions. The title at final
§ 1926.950(c) is being changed to
‘‘Information transfer’’ to more
appropriately describe the requirements
contained in the paragraph.66 In
addition, the final rule does not include
proposed § 1926.950(c)(1)(ii), which
would have required host employers to
report observed contract-employerrelated violations of this section to the
contract employer. Consequently, OSHA
renumbered proposed paragraph (c)(1)(i)
(and subordinate paragraphs (c)(1)(i)(A)
and (c)(1)(i)(B)) as final paragraph (c)(1)
(and subordinate paragraphs (c)(1)(i)
through (c)(1)(iv)).
Proposed paragraph (c)(1)(i) required
host employers to provide certain
information to contract employers.
Paragraph (c)(1)(i)(A), as proposed,
required host employers to provide
contractors with information about
‘‘[k]nown hazards that are covered by
this section, that are related to the
contract employer’s work, and that
might not be recognized by the contract
66 The title of this provision is ‘‘Information
transfer.’’ However, throughout the rulemaking, the
Agency and the regulated community referred to
the provision as the ‘‘host-contractor provision,’’ as
the provision contains information-transfer
requirements for host employers and contract
employers. OSHA, therefore, uses the terms
‘‘information-transfer provision’’ and ‘‘hostcontractor provision’’ interchangeably when
referring to this provision.
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employer or its employees.’’ The
purpose of this provision was to ensure
that contractors could take measures to
protect their employees from hazards
posed by hosts’ workplaces. Although
this proposed provision would not
require hosts to inform contract
employers of hazards that contract
employees are expected to recognize,
such as hazards posed by an overhead
power line, the proposal provided that
hosts inform contract employers of
hazards known to the hosts that might
not be recognized by the contractors.
For example, if a host employer knew
that a particular manhole on its system
was subject to periodic contamination
from a nearby fuel tank, the host was to
share this information with the
contractor.
OSHA received considerable feedback
on this proposed requirement. (See, for
example, Exs. 0146, 0159, 0160, 0167,
0175, 0178, 0186, 0201, 0227, 0234,
0480, 0505; Tr. 1333–1334.) Some
commenters agreed with the proposal to
require host employers to inform
contractors of known hazards. (See, for
example, Exs. 0167, 0169, 0234; Tr.
1333–1334.) For example, the Iowa
Association of Electric Cooperatives
commented that its members supported
proposed paragraph (c)(1)(i)(A),
explaining that ‘‘[i]t is . . . common
practice for Iowa’s cooperatives to
inform their contract employers of
hazards that are related to the contract
employer’s work that might not be
recognized by the contract employer or
its employees’’ (Ex. 0167).
However, most of the comments on
this provision objected to the proposed
language. The most common complaint
was that the proposed language was too
broad or vague. (See, for example, Exs.
0146, 0175, 0178, 0201, 0227.) For
instance, EEI commented:
This proposal is impermissibly vague
because it fails to provide adequate notice of
what would constitute compliance. See, e.g.,
Ga. Pac. Corp., v. OSHRC, 25 F.3d 999 (11th
Cir. 1994). For example, what are hazards
‘‘that are covered by this section?’’
Considering that the proposed standards
incorporate the requirements of many
standards other than those addressed in the
proposal, would host employers be required
to inform contractors of known hazards
addressed by all potentially applicable
standards? Even if the term is confined to the
standards under consideration here, this is a
vastly overbroad requirement.
Next, what is the test for determining the
hazards that are ‘‘related’’ to the contractor’s
work? Further, on what objective basis is a
host employer to determine which hazards
might not be recognized by the contract
employer or its employees? Does this mean
that the host must be sufficiently familiar
with the training of a specialty contractors’
employees to allow an intelligent assessment
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of what hazards those employees ‘‘might’’ or
‘‘might not’’ recognize? What will be the
penalty for mis-evaluating these possibilities,
if made in good faith?
Indeed, what are ‘‘hazards’’ for purposes of
this rule? Are they limited to conditions and
practices that pose a significant risk of injury
to employees, and would the likelihood of
occurrence and degree of gravity make a
difference? Similarly, what are ‘‘known’’
hazards? Are they hazards that the host
employer actually knows of, or are they
hazards that a host employer should have
known through the exercise of reasonable
diligence? Does actual knowledge for this
purpose mean knowledge of any hazard that
can be discerned by searching a company’s
records—a daunting test for an electric utility
that may have decades of records related to
work on transmission and distribution
facilities that cover literally thousands of
square miles—or is a more realistic test to be
applied? If so, what is it? [Ex. 0227]
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Mr. James Shill with ElectriCities
similarly commented that the proposed
provision would ‘require ElectriCities’
members to take into account every
section of the OSHA standards, as well
as others incorporated by reference, and
make a ‘guess’ as to all of the potential
hazards a contractor may be unable or
unwilling to ‘recognize’ (Ex. 0178). Ms.
Salud Layton with the Virginia,
Maryland & Delaware Association of
Electric Cooperatives argued that ‘‘[t]he
phrase ‘might not be recognized by the
contract employer or its employees’ is
too broad’’ and suggested that the
proposed paragraph be revised to
‘‘specifically state the items that must be
provided by the host employer to the
contract employer’’ (Ex. 0175).
Some commenters proposed new
language for this provision. (See, for
example, Exs. 0201, 0227, 0505.) For
instance, EEI suggested:
[T]he final rules should be limited to
requiring that a host employer notify a
contractor of a hazard where: (1) The host
employer has actual knowledge: (a) That the
hazard is present, and (b) that the
contractors’ employees are likely to
encounter the hazard in performing the work
for which the contractor is engaged; (2) given
its known expertise, the contractor cannot
reasonably be expected to recognize the
hazard; and (3) for this purpose, the ‘‘hazard’’
is a condition or practice that poses a
significant risk of death or serious physical
harm to the contractor’s employees. The
standard should also make clear that the host
employer is not obligated to evaluate each job
assigned to a contractor to determine whether
such hazards are presented. [Ex. 0227]
IBEW, although generally supporting
this and the other proposed hostcontractor requirements, also suggested
changes to paragraph (c)(1)(i)(A). The
union proposed:
The host employer shall inform the
contract employer of . . . existing or
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reasonably anticipated hazards covered by
this subsection (i) of which the host
employer is aware, (ii) that are related to the
contract employer’s work, and (iii) that are
sufficiently unique to the host employer’s
operations or premises that the contract
employer or its employees would not,
through the exercise of reasonable care, be
expected to recognize. [Ex. 0505]
Mr. Donald Hartley with IBEW
explained:
It is important . . . to require the host
employer to disclose hazardous conditions
that it knows actually exist and that it
reasonably anticipates may exist. The point
here is to include hazards that may exist
intermittently: for example, switching surges
or environmental conditions or only under
certain circumstances that, when they occur,
affect the workplace safety.
Second, the focus of the information
disclosure should be on information that is
sufficiently unique to the host’s workplace or
operations that the contract employer cannot
be expected to know without the input from
the host employer. A contractor may be
unable to identify hazards not only because
it lacks the technical expertise, but for the
very basic reason that it is unfamiliar with
the unique features of the host’s operation or
workplace environment. Again,
environmental conditions or specific
operating procedures are examples of this.
Finally, we believe that host employers
should be required to disclose any hazards
that threaten contractor employees with any
illness or injury, not just death or the most
serious of physical harm. [Tr. 879–880]
OSHA considered the comments on
proposed paragraph (c)(1)(i)(A) and
continues to believe that the final rule
should include a requirement for host
employers to convey certain information
to contractors that will bear on the
contractor’s ability to ensure the safety
of its employees. Much of the
opposition to this provision was to the
specific language in the proposal, not to
the general principle that utilities have
safety-related information that should
be shared with contractors.
OSHA is sensitive to the concerns of
commenters who noted that the
proposed language was overbroad or
unclear. Therefore, OSHA revised the
final rule to more clearly define the
information host employers must
provide to contractors. The Agency is
linking the information-transfer
requirements, in part, to the
requirement in final § 1926.950(d) for
determining existing conditions.
(Paragraph (d), discussed later in this
section of the preamble, is essentially
the same as existing § 1910.269(a)(3).) In
the final rule, § 1926.950(d) requires a
determination of the existing
characteristics and conditions of electric
lines and equipment related to the
safety of the work. The examples of
‘‘existing conditions’’ that were listed in
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20359
proposed paragraph (d) have been
separately numbered in final paragraph
(d). The first five items of information
listed in final paragraph (d) are
‘‘characteristics’’ of the electric power
installation. The remaining three items
of information listed in final paragraph
(d) are ‘‘conditions’’ at those
installations. Therefore, paragraphs
(c)(1)(i) and (c)(1)(ii) of the hostcontractor provisions in the final rule
refer to (and require the sharing of)
information about the characteristics
and conditions specifically listed in
final paragraph (d) that are related to the
safety of the work to be performed.
Contract employers may request from
the host employer information they
need to protect their employees, in
addition to the information that host
employers must provide under final
paragraphs (c)(1)(i) through (c)(1)(iii).67
Thus, final paragraph (c)(1)(iv) requires
host employers to provide contractors
with information about the design or
operation of the host employer’s
installation that is known by the host
employer, that the contract employer
requests, and that is related to the
protection of the contract employer’s
employees.
As already noted, OSHA decided to
adopt language in paragraphs (c)(1)(i)
and (c)(1)(ii) in the final rule that more
clearly specifies the information that
host employers must provide to
contractors and does so by using
language that is familiar to employers
complying with existing § 1910.269.68
Paragraph (d), discussed later in this
section of the preamble, lists specific
characteristics and conditions of electric
lines and equipment that must be
determined before work on or near
electric lines or equipment is started
when these characteristics and
conditions are related to the safety of
the work to be performed. These
characteristics and conditions include
the nominal voltages of lines and
67 Final paragraph (c)(1)(iii), discussed later in
this section of the preamble, requires host
employers to provide contractors with information
about the design and operation of the host
employer’s installation that the contract employer
needs to make the assessments required by subpart
V.
68 It should be noted that, in revising the language
of this provision in the final rule, OSHA did not
conclude that the proposed language was overbroad
or too vague. Similar language is used in other
OSHA standards, including the standard for process
safety management of highly hazardous chemicals
(see § 1910.119(h)(2)(ii)). The Agency believes that
employers subject to that rule are successfully
complying with it. However, OSHA is revising the
language of this provision in Subpart V because it
resolves rulemaking participants’ concerns about
the proposed provision in a manner that adequately
protects employees and is more consistent with
existing requirements for electric power generation,
transmission, and distribution work in § 1910.269.
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equipment, maximum switching
transient voltages, the presence and
condition of protective grounds and
equipment grounding conductors, and
the condition of poles. Host employers
are the parties that possess much of this
information, and it would be difficult in
many cases (and impossible in others)
for contract employers to determine
these conditions and comply with
paragraph (d) without getting the
necessary information from the host
employer.
For example, an electrical contractor
might be able to make a reasonable
estimate of the nominal voltage on a line
through examination of the equipment.
However, having the host employer
provide that information to the
contractor eliminates guesswork and the
hazards associated with inaccurate
estimates.
Similarly, contractors will usually be
unable to determine the maximum
switching transient overvoltages on a
power line without information from
the host employer. The maximum perunit transient overvoltage determines
the minimum approach distance for
workers to maintain from exposed,
energized parts (see the discussion of
this issue under the summary and
explanation of final § 1926.960(c)(1)
later in this section of the preamble).
Without this information from the host,
a contractor might not adhere to the
proper minimum approach distance
and, as a result, a power line worker
might come too close to the power line
and be at risk of serious injury from
electric shock and burns.
Paragraph (c)(1)(i) of the final rule
provides that, before work begins, the
host employer must inform the
contractor of the characteristics of the
host employer’s installation that are
related to the safety of the work to be
performed and are listed in paragraphs
(d)(1) through (d)(5). These
characteristics are: the nominal voltages
of lines and equipment, the maximum
switching-transient voltages, the
presence of hazardous induced voltages,
the presence of protective grounds and
equipment grounding conductors, and
the locations of circuits and equipment,
including electric supply and
communication lines and fire-protective
signaling circuits.69 OSHA presumes
that host employers have this
information because they typically need
69 In final § 1926.950(d)(5), OSHA changed the
proposed term ‘‘power . . . lines’’ to ‘‘electric
supply . . . lines.’’ The two terms are synonymous,
and the final rule defines ‘‘electric supply lines’’ in
§ 1926.968. Note that lines that employees
encounter are either electric supply lines,
communication lines, or control lines, such as those
on fire-protective signaling circuits.
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it for the design and operation of an
electric power generation, transmission,
or distribution system. A note to final
paragraph (c)(1)(i) explains that in an
unusual case in which the host
employer does not have this information
in existing records, it must obtain the
information for purposes of complying
with paragraph (c)(1)(i).
Paragraph (c)(1)(ii) of the final rule
requires that, before work begins, the
host employer inform the contract
employer of the conditions of the host
employer’s installation that are related
to the safety of the work to be
performed, that are listed in final
paragraphs (d)(6) through (d)(8), and
that are known to the host employer.
These conditions are: the condition of
protective grounds and equipment
grounding conductors, the condition of
poles, and environmental conditions
relating to safety. Final paragraph
(c)(1)(ii) only requires host employers to
provide known information to
contractors. Host employers gain
information on the condition of their
electric power generation, transmission,
and distribution systems through
normal preventive-maintenance
inspections; and, if host employers find
conditions listed in final paragraphs
(d)(6) through (d)(8) and related to the
safety of work to be performed by a
contractor during such inspections, the
host employer must pass that
information to the contract employer
under final paragraph (c)(1)(ii). For
example, if a utility conducts a woodpole inspection program and finds
several poles that are structurally
unsound and that need replacement,
this information must be imparted to a
contractor whose work involves the
affected poles. However, this paragraph
only requires the host employer to
provide information that the host can
obtain from existing records through the
exercise of reasonable diligence; this
provision does not require host
employers to conduct inspections to
identify these conditions. To make this
clear in the final rule, OSHA included
a note following paragraph (c)(1)(ii)
clarifying that, for the purposes of that
paragraph, the host employer does not
have to inspect of worksite conditions
or otherwise get information that it
cannot obtain through a reasonably
diligent search of its existing records.
OSHA believes that the revised
language in paragraphs (c)(1)(i) and
(c)(1)(ii) of the final rule addresses the
concerns expressed by commenters,
such as ElectriCities and EEI, about the
clarity and scope of proposed paragraph
(c)(1)(i)(A). The provision no longer
requires host employers to determine
whether a hazard exists or whether
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contractors might be expected to
recognize particular hazards.
Under final paragraph (c)(1)(iv),
before work begins, a host employer
must provide additional information
about the design or operation of the
installation, but only if that information
(1) is known by the host employer, (2)
is requested by the contract employer,
and (3) is related to the protection of the
contract employer’s employees. A note
to final paragraph (c)(1)(iv) clarifies that,
for purposes of complying with that
paragraph, the host employer is not
required to make inspections or
otherwise get information that it cannot
obtain through a reasonably diligent
search of its existing records.
IBEW commented that, ‘‘[i]n addition
to the information about ‘existing
conditions’ needed to perform the
hazard analysis, there may be other
information unique to the host’s
operations or premises that the
contractor employer needs to ensure the
safety of its employees’’ (Ex. 0505). The
union identified ‘‘schedules of other
crews that may be working on the same
circuits or equipment, anticipated
operational changes, and the potential
impact of unique localized climatic,
environmental or geological conditions’’
as examples of such information (id.).
Details about the scheduling of outages
is another example of information a
contractor might need to obtain from the
host employer before employees start
work.
OSHA is not explicitly requiring host
employers to provide this other type of
information to contractors. The Agency
believes that, although information such
as the scheduling of crews may prove
useful in some situations, it is not
always essential to ensure the safety of
employees. When a contractor needs
this information to protect its
employees, the contractor may request
this type of information under final
paragraph (c)(1)(iv). In addition, OSHA
believes that host employers and
contract employers will exchange this
type of information in their efforts to
comply with other provisions in final
paragraph (c). For example, when host
and contractor crews will be working
together or on the same circuit, OSHA
intends for both employers to exchange
crew-scheduling information when
necessary to comply with final
paragraph (c)(3) (discussed later in this
section of the preamble), which requires
the contract employer and the host
employer to coordinate their work rules
and procedures to ensure that
employees are protected as required by
subpart V.
As a general matter, OSHA does not
believe that the information host
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employers must share with contract
employers under final paragraph
(c)(1)(iv) is likely to contain proprietary
information or trade secrets. OSHA
recognizes, however, that an unusual
case could arise presenting issues
related to trade secrets. In any such
case, OSHA expects that the host
employer will find a way to provide the
necessary information to the contract
employer without divulging trade
secrets or will share the information
with the contract employer pursuant to
an appropriate confidentiality
agreement.
Southern Company expressed concern
that contractors and their employees
might rely on the information provided
by the utility in lieu of doing a thorough
job briefing as required by final
§ 1926.952 (Ex. 0212). Final
§ 1926.950(c)(1)(i), which requires host
employers to provide information to
contractors, does not replace the
contract employer’s basic responsibility
to conduct the job briefing required by
final § 1926.952. The briefing will
impart information, including relevant
information a contractor obtains from a
host employer, to the employees doing
the work. The requirements in final
§§ 1926.950(c)(1) and (d) and 1926.952
work in combination to ensure that the
employees performing the work are
provided with sufficient information to
perform that work safely.
Proposed paragraph (c)(1)(i)(B)
required host employers to provide
contract employers with information
about the installation that the contract
employer would need to make the
assessments required elsewhere in
Subpart V. EEI inquired as to who (the
host or contract employer) would be
20361
responsible for deciding what
assessments the contractor must make
and whether the host would have to
survey contractor work areas to identify
hazards that need assessment (Ex. 0227).
The language in final paragraph
(c)(1)(iii) states explicitly that, before
work begins, the host employer must
provide information that the contract
employer needs to perform the
assessments. In addition, the language
from the proposal has been modified in
the final rule to limit the information
the host employer must provide to
‘‘[i]nformation about the design and
operation of the host employer’s
installation.’’ Table 2 shows the
assessments that are implicitly or
explicitly required by final subpart V
and lists information that the Agency
anticipates contractors will need to
perform the required assessments.
TABLE 2—ASSESSMENTS REQUIRED BY SUBPART V
Provision
Assessment required
Type of information to be provided under
§ 1926.950(c)(1)(iii)
§ 1926.953(a) .......................
Whether an enclosed space must be entered as a permit-required confined space.
§ 1926.953(m) ......................
§ 1926.960(c)(1)(i) ................
Whether forced air ventilation has been maintained
long enough that a safe atmosphere exists.
What is the appropriate minimum approach distance for
the work to be performed.
Whether an enclosed space contains hazards, other
than electrical and atmospheric hazards, that could
endanger the life of an entrant or could interfere with
escape from the space.
The size of the enclosed space.
§ 1926.960(g)(1) ...................
Whether employees are exposed to hazards from
flames or electric arcs.
§ 1926.960(g)(2) ...................
What is the estimated incident energy from an electric
arc.
§ 1926.960(k) .......................
Whether devices are designed to open or close circuits
under load conditions.
§§ 1926.961 and
1926.967(h).
What are the known sources of electric energy (including known sources of backfeed) supplying electric circuits.
Whether protective grounds have adequate current-carrying capacity.
Whether there is a possibility of hazardous transfer of
potential should a fault occur.
Whether overhead structures such as poles and towers
are capable of sustaining stresses imposed by the
work.
§ 1926.962(d)(1)(i) ................
§ 1926.962(g) .......................
§ 1926.964(a)(2) ...................
What the operating conditions are for the value of the
maximum transient overvoltage provided to the contract employer.1
Information on electric equipment, such as safety information provided by manufacturers, that relates to the
required hazard assessment.
The electrical parameters needed to calculate incident
energy, such as maximum fault current, bus
spacings, and clearing times.
Load current for, and the opening and closing ratings
of, devices used to open and close circuits under
load.
All known sources of electric energy, including known
sources of backfeed.
The maximum fault current and clearing time for the circuit.
Potential rise on remote grounds under fault conditions.
The design strength of the pole or structure.
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1 Includes information on conditions that must be in place for the maximum transient overvoltage to be valid, such as whether circuit reclosing
devices are disabled.
In specific cases, contractors may
need information that is somewhat
different from that described in Table 2.
OSHA expects that contractors will
inform host employers if they need
additional information, and that
information must be provided to the
extent the host employer is required to
provide it by final paragraph (c)(1)(iii).
In addition, the Agency does not expect
host employers to provide contractors
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with information in the table if the
contractor informs the host that the
information is not needed.
EEI questioned whether the proposed
provision was limited to information
actually known by the host employer
(Ex. 0227). OSHA expects that the host
employer will usually have, in existing
records, information about the design
and operation of its installation that the
contract employer will need to make
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required assessments. OSHA presumes
that host employers know their electric
power generation, transmission, or
distribution installations and know their
systems’ nominal system and operating
voltages, available fault currents, relay
protection schemes, anticipated relay
clearing times, and switching schedules.
As IBEW noted, this is information ‘‘that
the host employer should have for basic
operational purposes and that is
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generally solely in the host’s
possession’’ (Ex. 0505). In addition,
electric utilities will also need to have
this information to perform their own
required assessments when their
employees are performing work on the
utilities’ installations. However, the
record also indicates that, in some
unusual circumstances, electric utilities
do not have basic information about
their system readily available. (See Mr.
Brian Erga’s testimony regarding a
nuclear power plant that did not know
its available fault current, Tr. 1241–
1242.) In such cases, the final rule
requires the host employer to ascertain
the information and provide it to its
contractor so that the contractor can
conduct the required assessments. A
note to final paragraph (c)(1)(iii)
clarifies that, in any situation in which
the host does not have such information
in existing records, it must obtain the
information and provide it to the
contract employer to comply with
paragraph (c)(1)(iii).70
Mr. Steven Theis of MYR Group
recommended that the final rule require
hosts and contractors to perform joint
hazard analyses (Tr. 1334).
The final rule neither requires nor
prohibits such joint assessments. Even if
employers do not conduct a joint hazard
analysis, the information exchange
required by final paragraph (c)(1) of the
final rule will be part of a two-way
conversation between host employers
and contract employers. As discussed
later in this section of the preamble,
final paragraph (c)(3) requires hosts and
contractors to coordinate their work
rules and procedures to ensure that
employees are protected as required by
subpart V. To comply with the final
rule, the contractor, as part of this effort,
must communicate with the host about
the information the contractor needs
about the host’s installation.
OSHA notes that final paragraph (c)(1)
does not require the host employer to
report any information to the contract
employer in writing; the Agency will
deem it sufficient for the host employer
to provide the necessary information,
through any appropriate mechanism (for
example, a phone call or an email), to
an authorized agent of the contractor.
70 The preamble to the proposal indicated that
proposed paragraph (c)(1)(i) would not require host
employers to provide ‘‘unknown information’’ to
contractors (70 FR 34840). It should be noted,
however, that OSHA presumes that host employers
‘‘know’’ the information that must be shared under
final paragraphs (c)(1)(i) and (c)(1)(iii) because it
relates to the design and operation of the
installation, which are aspects of an electric power
generation, transmission, or distribution system that
are under the exclusive purview of the host
employer.
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Proposed paragraph (c)(1)(ii) would
have required the host employer to
report observed contract-employerrelated violations of subpart V to
contract employers. OSHA included this
provision in the proposal because the
Agency believed that host employers
occasionally observe contractor
employees performing work under the
contract and that it was important for
the host employer to inform the contract
employer of observed violations so that
the contractor could correct them and
prevent them from occurring in the
future.
OSHA received many comments on
this proposed requirement. (See, for
example, Exs. 0128, 0152, 0160, 0167,
0169, 0170, 0171, 0178, 0183, 0186,
0201, 0222, 0227, 0235, 0505; Tr. 880–
882.) IBEW supported the need for a
reporting requirement, explaining:
[T]he point is that if in performing its usual
functions the host observes contract
employees exposed to hazards, it must report
those observations to their contract employer.
This requirement is particularly important in
the electrical industry where contract
employees are potentially exposed to
extremely serious hazards.
If the host employer who knows the
worksite’s hazards and the potential for harm
sees a contract employee exposed to those
conditions the host knows to be hazardous,
it is unconscionable for the host to walk
away. The host must report that information
to the contract employer so the contract
employer can take the steps necessary to
eliminate the unsafe condition, and the
contract employer must report back what
action it actually took . . . [Tr. 881].
Many commenters objected to the
proposed reporting requirement,
however. (See, for example, Exs. 0128,
0152, 0167, 0170, 0178, 0183, 0186,
0222, 0227.) Some expressed concerns
about putting host employers in an
enforcement role and requiring them to
make determinations about whether an
OSHA violation exists. (See, for
example, Exs. 0128, 0152, 0170, 0178,
0183, 0222, 0227.) For instance, EEI
commented:
The proposal would require a host
employer to report observed contractemployer-related violations of the standard
to the contract employer.
*
*
*
*
*
Typically, utility employees and managers
are not trained ‘‘in the requirements of’’
OSHA standards.’’ [sic] Rather . . . they are
trained in the requirements of their own
employer’s safety rules. . . . There simply
are no requirements that any employee know
what OSHA standards require—only that
behavior and work practices be in
compliance with standards. Employees are
entitled, however, to assume that if they
comply with their employer’s safety rules,
they will comply with OSHA standards. . . .
Indeed, among EEI members, the
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requirements of safety rules often exceed the
minimum requirements of OSHA standards.
Clearly, the proposed requirement would
create confusion. Utility representatives may
believe they are seeing OSHA violations, but
in fact may observe that contractors are not
performing as the utility’s internal safety
rules require. [T]he proposal would
effectively place utility personnel in the role
of surrogate Compliance Officers. They are
not trained or qualified to perform such a
function. [Ex. 0227; emphasis included in
original]
Mr. Alan Blackmon with the Blue
Ridge Electric Cooperative suggested
that, ‘‘[b]y requiring the [host] employer
to report on the violation of a federal
rule, the proposal in a sense deputizes
the employer as an OSHA inspector, a
role for which employers have no
training and no experience’’ (Ex. 0183).
Mr. Chris Tampio of the National
Association of Manufacturers argued
that, by requiring hosts to report
observed violations, OSHA ‘‘would
inappropriately force a host employer to
make a legal determination as to
whether the contractor has committed a
violation of the OSH Act’’ (Ex. 0222).
EEI was also concerned that host
employers would be cited for failing to
report violations that were present, but
not recognized by, the host’s employees,
commenting:
The proposal provides no guidance as to
the kinds of observation that would trigger a
notification requirement. For example,
[utilities commonly] engage inspectors . . .
to observe contractors’ performance. In other
situations, this is performed by a utility’s
own foremen or supervisors. Such
inspections often are aimed at assuring that
the work is performed accurately and in
timely fashion, and observation of safety
performance, while important, may not be
the main or only focus. If a utility inspector
is found to have had the opportunity to
observe a contractor’s violative behavior but
did not understand or appreciate what he
saw and failed to report it, would the host
be cited? [Ex. 0227]
Similarly, Duke Energy commented:
‘‘Host employers may have a variety of
employees observing contract
operations for reasons unrelated to
safety. They may be observing contract
operations for quality, schedule,
productivity, or cost purposes. A host
employee may ‘observe’ a condition, but
not recognize it as a violation of this
OSHA regulation’’ (Ex. 0201).
Some commenters presumed that the
proposal required host employers to
either actively monitor contractors or
take measures to ensure that reported
hazards were abated. (See, for example,
Exs. 0187, 0225, 0235, 0238, 0504.) For
instance, Mr. James Strange with
American Public Power Association
(APPA) commented that municipal
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utilities ‘‘do not have the personnel to
shadow contractors on each utility job
site to assure that they are working
according to OSHA rules’’ (Ex. 0238). In
addition, several commenters argued
that the proposal would create an
adversarial relationship between hosts
and contractors. (See, for example, Exs.
0169, 0171, 0183.) Mr. Wilson Yancey
expressed this argument as follows:
[T]he proposed requirements might create
an unduly adversarial relationship between
the parties. For instance, the host employer
seeking to fulfill its perceived duties under
the regulations would thrust the host
employer into the role of an investigator and
rule-enforcer, rather than a business partner
seeking to achieve a common goal of
employee safety. [Ex. 0169]
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After considering the comments
received on this issue, OSHA decided
not to include proposed paragraph
(c)(1)(ii) in the final rule. First, the host
employer, as defined in the final rule,
may not be in position to recognize, or
even observe, hazardous conditions
created by contract employers. OSHA
based the proposed rule on the premise
that the host employer would hire the
contract employer and would perform
some maintenance on the system. As
noted earlier, in the final rule, the
Agency adopted a definition of ‘‘host
employer’’ that is designed to capture
the employer in the best position to
provide information about the electric
power generation, transmission, or
distribution installation on which the
contract employer is working. The
definition of ‘‘host employer’’ in the
final rule does not require the host
employer to maintain the installation or
to be the entity that hired the contractor.
A host employer that does not perform
maintenance work on the system would
be unlikely to recognize hazardous
conditions created by contractors. In
addition, a host employer that does not
hire the contract employer usually
would not find itself in a position to
observe the contractor’s employees
working.71
Second, in some circumstances, the
host employer will also be a controlling
employer under OSHA’s multiemployer
citation policy. A controlling employer
71 For example, a generation plant owner could
contract with a company to operate, but not
maintain, the plant. If the plant owner neither
operates nor controls operating procedures for the
installation, the company it contracts with to
operate the plant is the host employer under the
final rule. The plant owner could hire a different
company to perform maintenance in the substation
in the generation plant. Because the host employer
in this scenario does not perform maintenance, it
is likely that the host employer will not have any
employees qualified to enter the substation, and,
thus, will not observe the maintenance contractor’s
employees.
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has an underlying duty to exercise
reasonable care to prevent and detect
violations endangering contractor
employees at the worksite. (See CPL 02–
00–124; see also OSHA’s discussion of
the multiemployer citation policy
earlier in this section of the preamble.)
This is a broader obligation than the one
OSHA proposed for host employers in
proposed paragraph (c)(1)(ii); therefore,
the proposed requirement is not
necessary with respect to hosts that are
controlling employers. (Whether a host
employer is a controlling employer
depends on whether it has general
supervisory authority over the worksite,
including the power to correct, or
require others to correct, safety and
health violations.72) Indeed, the Agency
is concerned that including the
proposed reporting requirement in the
final rule would lead host employers to
believe they could fulfill their
obligations as controlling employers just
by complying with the more limited
requirement in the standard.
Although OSHA is not including
proposed paragraph (c)(1)(ii) in the final
rule, the Agency expects that, in many
situations, liability and practical
considerations will drive host
employers that are not controlling
employers to notify the contractor if
they observe hazardous conditions
involving the contractor’s employees.
Unsafe conditions created by
contractors can pose hazards to
employees of the host employer and to
the public and can create additional
obligations for host employers to protect
their employees (for example, through
OSHA standards and the general duty
clause) and the public (for example,
through liability concerns) from those
hazards. For instance, a host employer
that observes a contractor bypassing
safety rules when installing a new line
will likely have concerns about the
quality of the contractor’s work and
about the effect of the contractor’s
unsafe practices on the installation and
on public safety. These concerns will
form a strong incentive for the host
employer to report the hazardous
conditions to the contractor.
Although the Agency concluded,
based on the current rulemaking record,
that the reporting requirement in
proposed paragraph (c)(1)(ii) is neither
necessary nor appropriate for this final
rule, the Agency will continue to
monitor this issue and evaluate whether
regulatory requirements like the one in
proposed paragraph (c)(1)(ii) are
necessary to ensure the safety of
72 Such control can be established by contract or
by the exercise of control in practice.
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20363
employees under subpart V or other
OSHA standards.
Proposed paragraph (c)(2)(iii)(C)
would have required the contract
employer to advise the host employer of
measures taken to correct, and prevent
from recurring, violations reported by
the host employer under proposed
paragraph (c)(1)(ii). In light of the
Agency’s decision not to adopt
proposed paragraph (c)(1)(ii), proposed
paragraph (c)(2)(iii)(C) is no longer
meaningful and is not incorporated in
the final rule.
In addition to proposing the
requirement for hosts to report observed
contract-employer-related violations,
OSHA requested comments on the
related, but distinct, issue of whether it
should require host employers to take
appropriate measures to enforce
contractual safety requirements or
review the contracts of contractors who
fail to correct violations.73
IBEW was the only commenter that
supported such requirements,
explaining:
The host employer should regularly review
the safety performance of a contractor while
operating on its site. The host employer
should take necessary action to ensure
contractual obligations are being met. The
rule should require the host employer to
initiate further action if the review finds non
compliance. [Ex. 0230]
Rulemaking participants agreed that
host employers regularly adopt
contracts that specify safety standards to
which contractors must adhere and that
include provisions for enforcing those
requirements. (See, for example, Exs.
0163, 0175, 0213, 0405; Tr. 1386–1387.)
Also, some commenters recognized a
general need for hosts to evaluate the
safety performance of contractors. (See,
for example, Exs. 0167, 0175, 0184,
0213, 0219.) However, none of these
rulemaking participants supported the
adoption of OSHA requirements related
to the enforcement, review, or awarding
of contracts.
For example, Ms. Susan O’Connor
with Siemens Power Generation
explained:
While host employers often [require and
enforce compliance with OSHA standards],
in practice it would be burdensome [on] the
host employer to require them, at the risk of
OSHA sanctions, to enforce contract
provisions as a regulatory matter. Indeed,
establishing this as a regulatory standard
could operate as a disincentive for host
employers to establish sound health and
safety contractual terms with contractors,
73 Contracts between electric utilities and their
contractors often contain provisions requiring
contractors to meet OSHA standards and other
provisions addressing noncompliance with the
terms of the contract. (See, for example, Ex. 0175.)
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particularly terms which go beyond
regulatory requirements. . . . In addition,
OSHA regulations are promulgated and
undergo public review; Host Employer
requirements do not go through such a
regulatory review process and therefore must
not be held on par with OSHA regulations.
Host employers have a right to establish site
safety requirements that are more stringent
than the law requires; however, they should
have the right to deal with contractors who
do not comply individually and in their own
manner. But they must currently do this
against the backdrop of specific OSHA
standards, and the OSHA Multi-employer
Workplace policy. Siemens sees no reason to
change this.
*
*
*
*
*
OSHA should not prescribe how
contractors are selected or prescribe how
contractors must be evaluated for purposes of
contracting work or terminating work. It is up
to the discretion of the party contracting for
the services to make those determinations.
Host employers should have the discretion to
choose, to dismiss, or continue utilizing
contractors. Given the already
comprehensive and pervasive nature of
health and safety regulation through OSHA
and the states, as well as considerations of
tort law, the effects of the marketplace will
weed out contractors that are repeatedly
substandard from a safety standpoint, as well
as those that are chronically poor
perform[ers] from a quality, delivery, or other
standpoint. Contractors should be answerable
to the host employe[r] for business matters,
and the agency for regulatory matters. These
lines should not be blurred by attempting to
make the host employer responsible for both.
As a practical matter, it would be impossible
for OSHA . . . to come up with minimum
requirements for every contract activity, to
establish an ‘‘acceptable’’ versus
‘‘unacceptable’’ contractor. [Ex. 0163]
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Duke Energy commented:
The only safety performance that OSHA
has authority to regulate is compliance with
OSHA rules. Worker Compensation
Insurance Carriers and others review safety
performance. There is no need for OSHA to
impose additional requirements. Each host
employer is faced with a unique set of
available contractors, each with its own
safety record. Some may excel in one area
and perform poorly in another. Some host
employers may have such a limited pool of
available contractors that requiring some predetermined level of contractor safety
performance would eliminate all contractors.
Other goals, such as employing minority
firms may cause hosts to work with poor
performers to improve their performance,
rather than eliminating the minority
contractor with the poor record. OSHA
should not interfere in decisions such as
these. [Ex. 0201]
In light of the comments received,
OSHA decided not to adopt provisions
requiring host employers to enforce
contractual safety requirements, to
review the contracts of contractors who
fail to correct violations or hazards, or
to evaluate the safety performance of
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contractors. As discussed previously,
the host employer might not be the
entity that hired the contract employer,
in which case the host employer would
not be in position to enforce contract
requirements or be involved in
awarding contracts to the contract
employer. In addition, as Ms. O’Connor
pointed out, and as noted earlier in this
section of the preamble, host employers
that have supervisory authority over a
contractor’s worksite are subject to a
background statutory obligation, as set
forth in OSHA’s multiemployer citation
policy, to exercise reasonable care to
detect and prevent violations affecting
contractor employees. Moreover, for the
reasons stated previously, OSHA
believes that, even in the absence of a
specific requirement in subpart V, host
employers that are not controlling
employers have strong incentives to take
measures to ensure safe contractor
performance. In addition, the Agency
believes that contractors with poor
safety performance are likely to have
similarly poor records with respect to
the quality of their work, making it less
likely that host employers will hire
them. Therefore, the final rule does not
contain provisions related to the
enforcement, review, or awarding of
contracts.
Paragraph (c)(2) of final § 1926.950
addresses the responsibilities of the
contract employer. Final paragraph
(c)(2)(i) requires the contract employer
to ensure that each of its employees is
instructed in any hazardous conditions
relevant to the employee’s work of
which the contractor is aware as a result
of information communicated to the
contractor by the host employer as
required by final paragraph (c)(1). This
paragraph ensures that information on
hazards the employees might face is
conveyed to those employees. The
information provided by the host
employer under paragraph (c)(1) is
essential to the safety of employees
performing the work, especially because
it may include information related to
hazardous conditions that the contract
employees might not identify or
recognize.
Proposed paragraph (c)(2)(i) was
worded differently from the final rule;
the proposed paragraph required
contractors to instruct their employees
in hazards communicated by the host
employer. OSHA received no comments
on this proposed provision. However,
changes were made to this paragraph in
the final rule to mirror the changes
made to paragraph (c)(1) (described
earlier). In the final rule, the Agency did
not include the note to proposed
paragraph (c)(2)(i) because OSHA
believes that the note was confusing.
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The proposed note suggested that the
instruction required under paragraph
(c)(2)(i) was not part of the training
required under § 1926.950(b). The
contractors’ employees will already be
trained in many of the hazards that are
related to the information the contractor
receives from the host, and the final rule
does not require employers to duplicate
this training. Contractors will need to
supplement an employee’s training only
when that employee will be exposed to
a hazard or will follow safety-related
work practices with respect to which he
or she has not already been trained.
Paragraph (c)(2)(ii), as proposed,
required the contract employer to
ensure that its employees followed the
work practices required by subpart V, as
well as safety-related work rules
imposed by the host employer. In
proposing this provision, OSHA
explained that a host employer’s safetyrelated work rules are almost certain to
impact the safety and health of the
contractor’s employees (70 FR 34840).
For example, electric utilities typically
require contractors to follow the
utilities’ procedures for deenergizing
electric circuits. If the contract
employer’s employees do not follow
these procedures, a circuit the
contractor’s employees are working on
might not be properly deenergized,
endangering the contractor’s employees,
or a circuit the contractor was not
working on might become reenergized,
endangering any host employer’s
employees that might be working on
that circuit.
OSHA invited comments on whether
requiring a contractor to follow a host
employer’s safety-related work rules
could make work more hazardous. A
few commenters supported proposed
paragraph (c)(2)(ii). (See, for example,
Exs. 0164, 0213.) For instance, Mr.
Tommy Lucas of TVA commented:
The proposed requirement is supported.
Regardless whether this requirement is
carried forward, we will require contractors
to follow certain host-employer safety rules
contractually, such as the lockout/tagout
(LOTO) procedure. Failure to follow the
LOTO procedure could result in host or
contractor employees being seriously injured.
[Ex. 0213]
In contrast, the vast majority of
rulemaking participants opposed the
proposed provision. (See, for example,
Exs. 0156, 0161, 0162, 0168, 0183, 0201,
0202, 0212, 0220, 0222, 0227, 0233,
0237, 0501; Tr. 1323, 1333.) These
commenters gave several reasons for
objecting to this proposed requirement:
• It could result in the
implementation of inadequately safe
work rules, such as when the contractor
has more protective work rules than the
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host (see, for example, Ex. 0161) or
when the host’s work rules may be
based on its own employees’ working
conditions that are less hazardous than
the working conditions to which
contractor employees will be exposed
(see, for example, Ex. 0233).
• It could cause contract employees
to be confused about proper work
methods if rules change from contract to
contract (see, for example, Ex. 0227).
• It would result in contractual
requirements becoming enforceable
OSHA standards in a way that
constitutes an illegal delegation of
OSHA’s rulemaking authority, thereby
circumventing proper rulemaking
procedures (see, for example, Ex. 0237).
• It would place OSHA in the
position of having to interpret and
enforce third-party contracts (see, for
example, Ex. 0233).
• It could increase disaster-response
time (Ex. 0233).
• It would increase costs and
administrative burdens on contract
employers (see, for example, Ex. 0162).
• It could result in contractors having
to follow host employer work rules that
are not directly linked to employee
safety, for example, in a situation in
which the host’s rules approve only one
vendor for safety equipment when
equivalent, equally protective,
equipment is available from other
vendors (Ex. 0162).
For instance, Mr. Steven Theis with
MYR Group commented:
MYR Group believes that requiring a
contractor to follow a host’s safety rules
would create hazards. Contractors are
required by the standard to have appropriate
work rules and policies for compliance.
Requiring them to follow another employer’s
policies—which they are unfamiliar with and
untrained on—would either result in
accidents or add undue and unnecessary
time for retraining and familiarization with
the policies when the contractor has its own
policy . . . Indeed, MYR Group has
experienced situations where host employers
impose work rules that do not significantly
affect employee safety and may even create
an unsafe situation. [H]ost work rules can
specify chain of command requirements that
do not align with contractor management
structure or responsibility and thus following
host requirements could result in loss or
miscommunication of safety information or
safe work directives. Accordingly, MYR
Group respectfully submits that the
requirement to follow host employer work
rules should be deleted. [Ex. 0162]
Mr. Terry Williams with the Electric
Cooperatives of South Carolina agreed
and provided an example of how
following a host employer’s safety rules
could jeopardize worker safety:
The proposal ignores the fact that
contractors have developed their own rules
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that are appropriate for the work they do.
They train on these rules and operate
according to them all the time. Requiring
contractors . . . to work to the rules of others
could easily result in the contractor working
less safely.
Consider the following actual situation: an
electric utility that is primarily a 12kV
system, with some 34.5kV. The utility uses
its own crews for the 12kV work, and uses
a qualified contractor for the 34.5kV work, as
the need arises. The utility’s safety rules
specify use of Class 2 gloves, sleeves and
cover up for all work, as that is all their line
crews need. For the 34.5 kV work, the
contractor should use Class 4 equipment, yet
OSHA’s proposal could justify use of Class 2,
with unsafe results.
OSHA should retract this proposal and
allow host employers to require contractors
to work to appropriate safety rules. [Ex. 0202]
EEI made similar comments in its
posthearing brief:
[T]he standard would require contractors
to utilize different safe procedures depending
upon the owner involved. For example, an
electric line contractor could be required to
observe a ‘‘ground-to-ground’’ rubber glove
requirement while working for one electric
utility, but not while working for another
utility nearby (Tr. 110–11). The confusion
and consequent increased risk to employees
from such requirements is obvious, not to
mention the cost of training for employees
and supervisors alike. [Ex. 0501]
As to the legal arguments, Susan
Howe with the Society of the Plastics
Industry suggested that ‘‘OSHA’s
incorporation’’ of the host employer’s
rules ‘‘into the OSHA standards which
are the subject of this rulemaking would
violate the rulemaking provisions of the
Occupational Safety and Health Act, the
Administrative Procedures Act, and the
Federal Register Act’’ (Ex. 0170). The
National Association of Manufacturers
similarly stated, with reference to this
provision: ‘‘OSHA has never had the
authority to incorporate the provisions
of millions of private contracts into
OSHA standards, nor to delegate its
rulemaking authority to private entities’’
(Ex. 0222). EEI also commented that the
proposed requirement ‘‘effectively
would place each host employer in the
position of promulgating safety and
health standards for contractors’
employees, and therefore would
constitute an unconstitutional
delegation of legislative power’’ (Ex.
0227).
OSHA does not believe that the
proposed provision would cause the
practical problems identified by
rulemaking participants. There is
evidence in the record that, as IBEW
stated, ‘‘contractors . . . routinely adapt
their work rules and safety practices to
accommodate the demands of particular
jobs and the requirements of specific
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20365
hosts’’ (Ex. 0505). The union explained
this statement as follows:
There are circumstances related to
contractors performing work on utility
properties that would require the contractors
to work under the host employer’s safety
related work rules to ensure both the
contractor employees and the host employer
employees are provided a safe work
environment. In fact, many collective
bargaining agreements require this. [Ex. 0230]
Mr. Brian Erga with ESCI noted that
some utilities have such unique systems
that contractors have no choice but to
follow the host’s rules (Tr. 1271–1272).
Several witnesses stated that contractors
routinely follow a host employer’s
lockout-tagout requirements (Tr. 314,
984, 1299–1301). There is evidence that
some host employers require contractors
to follow NFPA 70E (Ex. 0460), to
follow the host’s fall protection
requirement for working from aerial lifts
(Tr. 391), and to use particular types of
flame-resistant clothing (Tr. 1346). In
addition, the proposal did not require
contractors to follow all of the host
employer’s safety rules, only rules the
host imposes on contractors, which the
contractors are required to follow
anyway. The Agency also does not
believe that proposed paragraph
(c)(2)(ii) would result in undue
confusion from work rules that vary
from one employer to another. The
record indicates that contractors are
already required to institute different
work rules because of contractual or
other requirements imposed by host
employers, such as following the host
employers’ lockout-tagout procedures
(Tr. 314), using particular live-line work
methods (Tr. 320), and using particular
forms of fall protection (Tr. 643–644).
On the other hand, the record
establishes that hosts sometimes impose
rules that do not meet OSHA
requirements (Tr. 1366 74) or that may
be less safe than the contractor’s rules
(Tr. 1365–1366 75). These are outcomes
that OSHA did not envision in
proposing paragraph (c)(2)(ii).
Considering these potential risks, and
the commenters’ overwhelming
opposition to this proposed provision,
the Agency decided not to include
proposed paragraph (c)(2)(ii) in the final
rule.
OSHA concludes, however, that some
coordination of work rules between
74 Some host employers ‘‘don’t believe in
equipotential work zone,’’ which is required by
existing § 1910.269(n)(3), or want trucks barricaded,
instead of having them grounded, as required by
existing § 1910.269(p)(4)(iii)(C).
75 One host employer requires contractor
employees to wear rubber insulating gloves while
working with live-line tools on transmission lines,
which may cause the gloves to fail.
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hosts and contractors is necessary,
particularly with respect to deenergizing
lines and equipment (Ex. 0505) and
grounding procedures (Tr. 1271–1272).
According to IBEW:
[What is important] is not that one party’s
rules take precedence over the others.
Instead, what is important is that the parties
operating on an electrical system coordinate
procedures to ensure that all of the
employees can perform safely. There are two
sets of circumstances in which this kind of
coordination is an issue: Where employees
actually work together and when the manner
in which one group of employees performs
has an impact on the safety of another group
of employees. [Ex. 0505]
Other rulemaking participants
similarly supported a requirement for
coordination between host employers
and contract employers to assure the
protection of host employees and
contract employees. (See, for example,
Exs. 0128, 0235, 0237.) Therefore, the
Agency is adopting a new paragraph in
the final rule, § 1926.950(c)(3), entitled
‘‘Joint host- and contract-employer
responsibilities,’’ which reads as
follows:
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The contract employer and the host
employer shall coordinate their work rules
and procedures so that each employee of the
contract employer and the host employer is
protected as required by this subpart.
This new provision provides host
employers and contract employers more
flexibility than the proposal to select
appropriate work rules and procedures
for each task or project, while ensuring
that workers are not at risk of harm due
to a lack of coordination between
employers.
Under the new provision, each
employer has independent
responsibility for complying with the
final rule. In addition, the Agency
stresses that a contract employer must
comply with the final rule even though
a host employer may try to impose work
rules that would cause the contract
employer to violate OSHA’s rules.
Accordingly, a contract employer is not
relieved of its duty to comply with the
final rule by following a work rule
imposed by the host employer. For
example, a contract employer must
comply with final § 1926.962(c), which
prescribes rules for equipotential
grounding, even if the host employer
has its own noncompliant grounding
procedures. Paragraph (c)(3) of final
§ 1926.950 requires host employers and
contract employers to confer in an effort
to select work rules and procedures that
comply with final § 1926.962(c).
Final paragraphs (c)(2)(ii) and
(c)(2)(iii) (proposed as part of paragraph
(c)(2)(iii)) require the contract employer
to advise the host employer of unique
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hazardous conditions posed by the
contract employer’s work 76 and any
unanticipated hazardous conditions
found, while the contractor’s employees
were working, that the host employer
did not mention. Final paragraphs
(c)(2)(ii) and (c)(2)(iii) enable the host
employer to take necessary measures to
protect its employees from hazards of
which the host employer would not be
aware. These requirements will protect
the host employer’s employees: when
they are working near the contractor’s
employees (for example, during storm
situations (Tr. 315, 392, 1379–1380);
during outages on transmission lines
(Tr. 1380) and in plants (Tr. 985); while
working in the same substation (Tr.
313–314, 559); and when the host
employer’s employees work on the same
equipment after the contract employer
departs (such as, when contractors are
working on equipment in the field that
the host employer does not regularly
inspect) (Tr. 877–878)). The Utility
Workers Union supported these
proposed requirements, commenting:
‘‘Requiring the sharing of information of
hazards found or created by the
contractor is . . . insurance that all
employees, host and contractor, are in a
safer working environment’’ (Ex. 0197).
OSHA notes that proposed paragraph
(c)(2)(iii)(B) (now paragraph (c)(2)(iii))
required contractors to report any
unanticipated ‘‘hazards’’ not mentioned
by the host; however, in the final rule,
the phrase ‘‘hazardous conditions’’
replaces the word ‘‘hazards’’ throughout
paragraph (c). In addition, the Agency
anticipates that contract employers will
inform host employers of any
information provided by the host that is
at odds with actual conditions at the
worksite, consistent with paragraph
(c)(3), which specifies that host
employers and contract employers
coordinate their work rules and
procedures so that each employee is
protected as required by subpart V.
Some commenters believed that
proposed paragraph (c)(2)(iii) (now
paragraphs (c)(2)(ii) and (c)(2)(iii))
needed clarification. For example, the
Associated General Contractors of
America (AGC) commented that
proposed paragraph (c)(2)(iii) was vague
and did not provide guidance on the
timeframes or format of required
information transfers (Ex. 0160).
OSHA does not agree that final
paragraphs (c)(2)(ii) or (c)(2)(iii) are
vague or unclear. These provisions
simply require that contractors provide
76 For the purposes of final paragraph (c)(2)(ii),
‘‘unique hazardous conditions presented by the
contract employer’s work’’ means hazardous
conditions that the work poses to which employees
at the worksite are not already exposed.
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information to host employers, which
reciprocates the requirements under
final paragraph (c)(1) that host
employers provide contractors with
information. The Agency deliberately
omitted, in the proposed and final rules,
any requirement for a formal or written
report; the final rule simply requires
contractors to advise the host employer,
which allows contract employers
maximum flexibility in complying with
the final requirements. The Agency will
deem it sufficient for the contract
employer to provide the necessary
information, through any appropriate
mechanism (for example, a phone call
or an email), to an authorized agent of
the host employer.
The purpose of final paragraph
(c)(2)(ii) is to enable host employers to
protect their own employees from
hazardous conditions presented by the
contractor’s work. Thus, the information
addressed by paragraph (c)(2)(ii) needs
to be provided to the host employer
soon enough so that the host employer
can take any necessary action before its
employees are exposed to a hazardous
condition. To address AGC’s concern
that the proposed paragraph did not
provide guidance on the timeframe of
the required information transfer, OSHA
added language to paragraph (c)(2)(ii) in
the final rule to indicate that this
information must be provided ‘‘[b]efore
work begins.’’
The final rule also includes, in
paragraph (c)(2)(iii), a 2-working day
timeframe in which the contractor must
advise the host employer of information
described in that paragraph. OSHA
believes that this timeframe will give
the contract employer sufficient time to
provide the required information. The
final rule does not specifically require
hosts to take any direct action in
response to information provided by
contractors, although the Agency
anticipates that host employers will use
this information to protect their
employees and comply with the OSH
Act.
Frequently, the conditions present at
a jobsite can expose workers to
unexpected hazards. For example, the
grounding system available at an
outdoor site may be damaged by
weather or vehicular traffic, or
communications cables in the vicinity
could reduce the approach distance to
an unacceptable level. To protect
employees from such adverse situations,
conditions affecting safety that are
present in the work area should be
known so that appropriate action can be
taken. Paragraph (d) of § 1926.950
addresses this problem by requiring
safety-related characteristics and
conditions existing in the work area to
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be determined before employees start
working in the area. The language for
proposed paragraph (d) was based on
language in current § 1926.950(b)(1) and
was the same as existing
§ 1910.269(a)(3). A similar requirement
can be found in ANSI/IEEE C2–2002,
Rule 420D.77 As noted earlier, OSHA
revised the language in the final rule to
clarify that the paragraph addresses
installation characteristics, as well as
work-area conditions, and to separately
number the examples listed in the
provision.
OSHA received only a few of
comments on proposed paragraph (d).
EEI objected to this provision,
commenting:
EEI recognizes that the regulatory text of
proposed paragraph 1926.950(d) is the same
as in existing 1910.269(a)(3). Also, the
preamble accompanying the current proposal
is essentially the same as in the final
1910.269. There are certain aspects of the
current proposal, however, that are
troublesome. . . .
*
*
*
*
*
It is susceptible of being applied in a
manner that effectively requires an employer
to examine every imaginable condition on a
jobsite, lest it be held accountable if some
obscure, unexpected condition later is
involved in causing an accident.
*
*
*
*
*
[I]f the standard is not applied reasonably,
the result could be a significant burden for
line crews, as time is taken not to miss a
single detail, however obscure, lest the crew
be second-guessed for having missed
observing some condition if something later
goes wrong. In the final rule, OSHA needs to
address this issue. Rather than state that
there is an unqualified obligation to
‘‘determine’’ existing conditions relating to
the safety of the work, the obligation should
be modified to require a ‘‘reasonable effort to
determine’’ the reasonably anticipated
hazards. [Ex. 0227]
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EEI noted, as an example of ‘‘some
obscure, unexpected condition . . .
involved in causing an accident,’’ an
energized static line that caused the
electrocution of an apprentice line
worker (id.):
In that case, the contractor was performing
maintenance work on a high-voltage
transmission tower. The host utility was
shown to have been aware that what
appeared to be a grounded static line atop
one side of the tower was in fact energized
at 4,000 volts. The utility did not inform the
contractor of this information, however, and
the contractor’s foremen on the ground and
on the tower did not notice that there was an
insulator separating the line and tower, thus
indicating that the line could be energized.
[Id.]
77 The 2012 NESC contains an equivalent
requirement in Rule 420D.
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EEI stated that the contractor was cited,
under existing § 1910.269(a)(3), ‘‘for
failing to ascertain existing conditions,
i.e., the energized condition of the static
line, before beginning work’’ (id.).
OSHA considered this comment and
decided not to adopt EEI’s
recommended change to proposed
§ 1926.950(d). First, OSHA does not
believe that obscure and unexpected
conditions often lead to accidents, as
EEI seems to argue. EEI’s example, in
which an apprentice power line worker
was electrocuted by an energized static
line, is a case in point (id.). An
employer exercising reasonable
diligence can be expected to determine
that a static line is energized. In the case
described by EEI, the electric utility that
owned the line was aware that the line
was energized, and the line itself was
installed on insulators (id.). Thus, the
energized condition of the static wire
was neither obscure nor unexpected.
Second, EEI appears confused about
the purpose of this provision. Paragraph
(d) of final § 1926.950 requires
employers to determine, before work is
started on or near electric lines or
equipment, existing installation
characteristics and work-area conditions
related to the safety of the work to be
performed. The requirement also
includes examples of such
characteristics and conditions.
Characteristics of the installation,
such as the nominal voltage on lines,
maximum switching transient
overvoltages, and the presence of
grounds and equipment grounding
conductors, are parameters of the
system. This is information the
employer already has, either through
direct knowledge or by the transfer of
information from the host employer to
the contract employer.78 Thus, this
aspect of final paragraph (d) does not
place any burden, much less an
unreasonable one, on line crews.
Conditions of the installation,
including the condition of protective
grounds and equipment grounding
conductors, the condition of poles, and
environmental conditions relating to
safety, are worksite conditions. In some
cases, the employer already will have
information on the condition of the
installation, such as information on the
condition of poles from pole-inspection
programs or on the condition of electric
equipment from equipment
manufacturers. In the usual case,
78 The employer may not have knowledge of the
exact locations of customer-owned backup
generators; however, the location of possible
sources of backfeed from such customer-owned
equipment can readily be determined by looking for
connections to customers’ wiring in circuit
diagrams or during an inspection at the worksite.
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20367
however, the conditions addressed by
paragraph (d) of the final rule will be
determined by employees through an
inspection at the worksite. This
inspection need not be overly detailed,
but it does need to be thorough rather
than cursory. The standard does not
require crews to determine ‘‘every
imaginable condition,’’ as EEI suggests.
Rather, the inspection must be designed
to uncover the conditions specifically
noted in this paragraph as well as any
other conditions of electric lines and
equipment that are related to the safety
of the work to be performed and that
can be discovered through the exercise
of reasonable diligence by employees
with the training required by
§ 1926.950(b) of the final rule.
Employers are required by
§ 1926.952(a)(1) of the final rule to
provide information on such worksitespecific conditions and the
characteristics of the installation to the
employee-in-charge. With this
information, the employer then will
determine the current conditions of the
installation through an examination by
employees at the worksite. Employersupplied information, as well as
information gathered at the worksite,
must be used in the job briefing required
by § 1926.952 of the final rule. (See the
discussion of § 1926.952 later in this
section of the preamble.) The
characteristics and conditions found as
a result of compliance with final
§ 1926.950(d) could affect the
application of various Subpart V
requirements. For example, the voltage
on equipment will determine the
minimum approach distances required
under final § 1926.960(c)(1). Similarly,
the presence or absence of an equipment
grounding conductor will affect the
work practices required under final
§ 1926.960(j). If conditions are found to
which no specific subpart V provision
applies, then the employee would need
to be trained, as required by final
§ 1926.950(b)(1)(ii), to use appropriate
safe work practices.
Employers need not take
measurements on a routine basis to
make the determinations required by
final § 1926.950(d). For example,
knowledge of the maximum transient
voltage level is necessary to perform
many routine transmission and
distribution line jobs safely. However,
no measurement of this maximum level
is necessary to make the requisite
determination. Employers can make the
determination by conducting an
analysis of the electric circuit, or they
can assume the default maximum
transient overvoltages discussed under
the summary and explanation of final
§ 1926.960(c)(1), later in this section of
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the preamble. Similarly, employers can
make determinations about the presence
of hazardous induced voltages, as well
as the presence and condition of
grounds, without taking measurements.
It may be necessary for employers to
make measurements when there is
doubt about the condition of a ground
or the level of induced or transient
voltage if the employer is relying on one
of these conditions to meet other
requirements in the standard. For
example, an engineering analysis of a
particular installation might
demonstrate that the voltage induced on
a deenergized line is considerable, but
should not be dangerous. However, a
measurement of the voltage may be
required if the employer is using this
analysis as a basis for claiming that the
provisions of final § 1926.964(b)(4) on
hazardous induced voltage do not
apply. In another example, further
investigation is required when an
equipment ground is found to be of
questionable reliability, unless the
equipment is treated as energized under
final § 1926.960(j).
EEI was concerned about this
discussion of engineering analysis in the
preamble to the proposed rule (70 FR
34841), commenting:
This [discussion] is unrealistic:
engineering analyses are not made in the
field in transmission and distribution work.
[Ex. 0227]
OSHA agrees with EEI that
engineering analyses are not made in
the field. Under this provision of the
final rule, employers would conduct
any engineering analyses required by
this provision off site and supply the
requisite information to the employees
performing the work.
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Section 1926.951, Medical services and
first aid
Section 1926.951 sets requirements
for medical services and first aid.
Paragraph (a) of § 1926.951 emphasizes
that the requirements of § 1926.50
apply. (See § 1926.950(a)(2).) Existing
§ 1926.50 includes provisions for
available medical personnel, first-aid
training and supplies, and facilities for
drenching or flushing of the eyes and
body in the event of exposure to
corrosive materials.
Mr. Daniel Shipp with the
International Safety Equipment
Association (ISEA) recommended that
the reference in § 1926.50, Appendix A,
to ANSI Z308.1–1978, Minimum
Requirements for Industrial Unit-Type
First-aid Kits, be updated to the 2003
edition (Ex. 0211). OSHA did not
propose any changes to § 1926.50, nor
was that section a subject of this
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rulemaking. Thus, the Agency is not
adopting Mr. Shipp’s suggestion. It
should be noted, however, that
Appendix A to § 1926.50 is not
mandatory. The Agency encourages
employers to examine the
recommendations in the latest edition of
the consensus standard, which is ANSI/
ISEA Z308.1–2009, when reviewing the
guidance in Appendix A to § 1926.50.
Mr. Stephen Sandherr with AGC was
concerned that the requirements
proposed in § 1926.951 conflicted with
the requirements in § 1926.50 and
maintained that such a conflict would
hinder a contractor’s ability to
implement safety (Ex. 0160).
OSHA reexamined the requirements
in proposed § 1926.951 and found that
the requirements for first-aid supplies in
proposed paragraphs (b)(2) and (b)(3) in
that section conflicted with similar
requirements in § 1926.50. Proposed
paragraph (b)(2) would have required
weatherproof containers if the supplies
could be exposed to the weather,
whereas existing § 1926.50(d)(2)
requires that the contents of first-aid kits
be placed in weatherproof containers,
with individual sealed packages for
each type of item. Further, proposed
paragraph (b)(3) would have required
that first-aid kits be inspected frequently
enough to ensure that expended items
are replaced, but not less than once per
year. By contrast, existing
§ 1926.50(d)(2) requires that first-aid
kits ‘‘be checked by the employer before
being sent out on each job and at least
weekly on each job to ensure that the
expended items are replaced.’’
As noted earlier, final § 1926.951(a),
which requires that employers comply
with existing § 1926.50, was adopted
without change from the proposal. The
Agency is not including proposed
paragraphs (b)(2) and (b)(3) in the final
rule because these provisions were less
restrictive than the requirements of
§ 1926.50. Including them in the final
rule would compromise OSHA’s efforts
to enforce § 1926.50 on jobsites covered
by Subpart V. OSHA notes that the
remaining provisions in § 1926.951
apply in addition to those in § 1926.50.
Final § 1926.951(b) supplements
§ 1926.50 by requiring cardiopulmonary
resuscitation (CPR) to help resuscitate
electric shock victims.79 OSHA
79 In discussing these remaining provisions in this
preamble, OSHA generally uses the term ‘‘CPR
training’’ to describe the first-aid training required
by the provisions. OSHA does not mean to imply
by this language that the final provisions do not
require first-aid training other than CPR. In fact, as
explained later in the preamble, the final rule
defines ‘‘first-aid training’’ as training in the initial
care, including CPR, performed by a person who is
not a medical practitioner, of a sick or injured
person until definitive medical treatment can be
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concludes that the requirements for CPR
training in the final rule are supported
by the record. This training is required
by existing § 1910.269(b)(1), and work
under subpart V poses the same electricshock hazards and requires the same
protection against those hazards. As
discussed in the summary and
explanation for § 1926.953(h), the final
rule defines ‘‘first-aid training’’ to
include CPR training. Therefore, in final
§ 1926.951(b), OSHA replaced the
proposed phrase ‘‘persons trained in
first aid including cardiopulmonary
resuscitation (CPR)’’ with ‘‘persons with
first-aid training.’’ The Agency stresses
that CPR training is required by this and
other provisions in the final rule for
first-aid training.
Electric shock is a serious and everpresent hazard to electric power
transmission and distribution workers
because of the work they perform on or
with energized lines and equipment.
CPR is necessary to revive an employee
rendered unconscious by an electric
shock. As OSHA concluded in the 1994
§ 1910.269 rulemaking, CPR must be
started within 4 minutes to be effective
in reviving an employee whose heart
has gone into fibrillation (59 FR 4344–
4347; see also 269–Ex. 3–21).
To protect employees performing
work on, or associated with, exposed
lines or equipment energized at 50 volts
or more, OSHA proposed to require that
employees with training in first aid
including CPR be available to render
assistance in an emergency.
OSHA chose 50 volts as a widely
recognized threshold for hazardous
electric shock.80 In this regard, several
OSHA and national consensus
standards recognize this 50-volt
threshold. For example, OSHA’s general
industry and construction electrical
standards require guarding live parts
energized at 50 volts or more
(§§ 1910.303(g)(2)(i) and
1926.403(i)(2)(i)); the general industry
electrical standard also requires that
electric circuits be deenergized
generally starting at 50 volts
(§ 1910.333(a)(1)). Similarly, NFPA’s
Standard for Electrical Safety in the
Workplace (NFPA 70E–2004) and the
National Electrical Safety Code (ANSI/
IEEE C2–2002) impose electrical safety
requirements starting at 50 volts (Exs.
0134, 0077, respectively). (See, for
example, Section 400.16 of NFPA 70E–
administered. OSHA is emphasizing ‘‘CPR training’’
in its preamble discussion because that type of first
aid is particularly beneficial to workers who are
injured by an electric shock.
80 Although it is theoretically possible to sustain
a life-threatening shock below this voltage, it is
considered extremely unlikely. (See, for example,
Ex. 0428.)
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2004, which requires guarding of live
parts of electric equipment operating at
more than 50 volts, and Rule 441A2 of
ANSI/IEEE C2–2002,81 which prohibits
employees from contacting live parts
energized at 51 to 300 volts unless
certain precautions are taken.)
Many electric shock victims suffer
ventricular fibrillation (59 FR 4344–
4347; 269–Ex. 3–21). Ventricular
fibrillation is an abnormal, chaotic heart
rhythm that prevents the heart from
pumping blood and, if unchecked, leads
to death (id.). Someone must defibrillate
a victim of ventricular fibrillation
quickly to allow a normal heart rhythm
to resume (id.). The sooner defibrillation
is started, the better the victim’s chances
of survival (id.). If defibrillation is
provided within the first 5 minutes of
the onset of ventricular fibrillation, the
odds are about 50 percent that the
victim will recover (id.). However, with
each passing minute, the chance of
successful resuscitation is reduced by 7
to 10 percent (id.). After 10 minutes,
there is very little chance of successful
rescue (id.). Paragraph (b) of the final
rule requires CPR training to ensure that
electric shock victims survive long
enough for defibrillation to be
efficacious. The employer may rely on
emergency responders to provide
defibrillation.
In the preamble to the proposal,
OSHA requested public comment on
whether the standard should require the
employer to provide automated external
defibrillators (AEDs) and, if so, where
they should be required. AEDs are
widely available devices that enable
CPR-trained individuals to perform
defibrillation.
Many rulemaking participants
recommended that OSHA not adopt a
requirement for AEDs. (See, for
example, Exs. 0125, 0162, 0167, 0169,
0171, 0173, 0174, 0177, 0200, 0225,
0227; Tr. 635–636, 762–763.) Some
commenters argued that there were no
injuries for which AEDs would prove
beneficial. (See, for example, Exs. 0174,
0200; Tr. 635–636, 762–763.) In this
regard, Mr. Steven Semler, commenting
on behalf of ULCC, stated:
[W]hen tragic electric contact accidents do,
albeit rarely, occur with respect to line
clearance tree trimmers, they tend to involve
catastrophic accidental direct contract with
high voltage electric supply lines which
inherently pass massive amounts of
electricity through the victim which
irreversibly damages cardiac conductivity
altogether—as to which AED’s cannot, nor
even purport to, rectify . . . . It is, of course,
a misnomer that AED’s can restart a heart
which is stopped from electrical contact or
81 The 2012 NESC contains a similar requirement
in Rule 441A2.
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any other reason. The stoppage is known as
‘‘asystole’’ for which an AED is programmed
to not shock the patient because AED’s
cannot start a stopped heart—for instance,
one whose stoppage is due to destruction of
the heart’s electrical path, or due to
irreversible brain damage, respiratory muscle
paralysis, tissue burn, or due to electrical
contact which serves to destroy the ability to
breathe.
Rather, AED’s use is limited solely to cases
of cardiac fibrillation—cases of the heart
beating in quivering fashion so as to cease
effective pumping capacity (and also to rarer
situations of ventricular tachycardia where
the heart beats very fast). But, as a trauma
specialist physician has observed, ventricular
fibrillation is a rare occurrence in high
voltage electrical contacts, as to which rescue
breathing and CPR (currently required) are
remedial pending arrival of medical help.
[Footnote: Richard F. Edlict, MD, ‘‘Burns,
Electrical, www.emedicine.com/plastic/
topic491.htm (7/12/05) . . .]
Given that the unfortunate nature of line
clearance tree trimmers cardiac events due to
electric contact tend to be catastrophic
because of accidental non compliance with
the OSHA minimum distance separation
from electric supply lines separation
requirement, the cardiac events which
unfortunately have happened to line
clearance tree trimmers have tended to
catastrophic, tending to involve cardiac and
brain damage of such severity that AED’s are
not designed to, and cannot, perform a useful
purpose. [Ex. 0174; emphasis included in
original]
Furthermore, TCIA presented polling
data to show that their members have
not experienced any occupational
incidents for which AED use would
have been appropriate to treat the victim
(Exs. 0200, 0419).
On the other hand, several rulemaking
participants pointed out that AEDs have
saved lives (Exs. 0213, 0230). TVA,
which has deployed AEDs in both fixed
work locations, such as generation
plants, and in field service-centers,
reported two successful uses of AEDs in
a 17-month period (Ex. 0213). IBEW
commented that ‘‘AED units have
proven to be effective in the utility
industry. More than one ‘save’ has
occurred’’ (Ex. 0230). Testifying on
behalf of IBEW, Mr. James Tomaseski
stated, ‘‘[B]ased on what the experts tell
you about the need to have AEDs in
certain environments, [electric utility
work] is [at the] top of the list. We have
an aging workforce. The possibilities of
sudden cardiac arrest to occur to people
in this industry is very high’’ (Tr. 964).
The Agency concludes that employees
performing work covered by subpart V
and § 1910.269 are exposed to electric
shocks for which defibrillation is
needed as part of the emergency
medical response to such injuries. The
Agency bases this conclusion on the
evidence in both this record, as well as
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the record supporting its decision in the
1994 § 1910.269 rulemaking to require
first-aid training, including CPR
training, for work covered by that
standard. OSHA found in its 1994
§ 1910.269 rulemaking that lineclearance tree trimmers were exposed to
electric-shock hazards for which CPR
would be efficacious (59 FR 4344–4347),
and the National Arborist Association
(TCIA’s predecessor) pointed out that
low-voltage electric shock can result
from indirect contact with higher
voltage sources (269-Ex. 58, 59 FR
4345). OSHA’s inspection data amply
demonstrate that indirect contacts, such
as contacting a power line through a tree
branch, do occur in work covered by
§ 1910.269 and Subpart V (Ex. 0400).
Half of the ten line-clearance treetrimmer electrocutions described in
these data resulted from indirect
contacts. The experience of TVA and
IBEW reinforces the Agency’s
conclusion that employees performing
work covered by Subpart V and
§ 1910.269 are exposed to electric
shocks for which defibrillation is
needed as part of the emergency
medical response.
Many rulemaking participants argued
that work covered by Subpart V would
subject AEDs to environmental and
other conditions for which the devices
are not, or may not be, designed,
including:
• Extreme heat (see, for example, Exs.
0169, 0171, 0173, 0177, 0227),
• Extreme cold (see, for example, Exs.
0169, 0171, 0173, 0177, 0227),
• Vibration or jarring (see, for
example, Exs. 0169, 0173, 0175),
• Dust (see, for example, Exs. 0169,
0171, 0173, 0175), and
• Humidity and moisture (see, for
example, Exs. 0169, 0171, 0173).
For instance, Mr. Wilson Yancey with
Quanta Services commented that the
conditions to which AEDs would be
exposed could ‘‘quickly degrade the
performance of the equipment and
require frequent inspection and
maintenance’’ (Ex. 0169). Ms. Salud
Layton with the Virginia, Maryland &
Delaware Association of Electric
Cooperatives commented, ‘‘Most field
experience with AED’s has been at
either fixed sites or carried by
ambulances in padded bins/cases inside
of heated and cooled ambulance bodies.
This is not what the AED’s would be
exposed to on a utility vehicle’’ (Ex.
0175). Mr. Thomas Taylor with
Consumers Energy noted that
manufacturers’ instructions tightly
control AEDs’ storage requirements,
explaining:
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[L]ine truck storage conditions would
prohibit the AED from functioning properly
and therefore provide no tangible safety
benefit to employees. In this regard, the
manufacturer instructions for preventing
electrode damage states: ‘‘Store electrodes in
a cool, dry location (15 to 35 degree Celsius
or 59 to 95 degrees Fahrenheit’’. The
instruction also states: [‘‘]It is important that
when the AED is stored with the battery
installed, temperature exposure should not
fall below 0 degrees Celsius (32 degrees
Fahrenheit) or exceed 50 degrees Celsius (122
degrees Fahrenheit). If the AED is stored
outside this temperature range, the auto tests
may erroneously detect a problem and the
AED may not operate properly.[’’] [Ex. 0177]
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OSHA decided not to include a
requirement for AEDs in the final rule
because the Agency believes that there
is insufficient evidence in the record
that AEDs exposed to the environmental
extremes typical of work covered by
Subpart V and § 1910.269 would
function properly when an incident
occurs. There is no evidence in the
record that AEDs are adversely affected
by dust, vibration, or humidity;
however, it is clear that line work in
many areas of the country would subject
AEDs to temperatures above and below
their designed operating range of 0 to 50
degrees Celsius. For example, Mr. Frank
Owen Brockman with the Farmers Rural
Electric Cooperatives testified that
temperatures in Kentucky can get as
cold as ¥34 degrees Celsius and as high
as 44 degrees Celsius (Tr. 1283).
Although the record indicates that the
highest of these temperatures is within
the operating range of AEDs, OSHA
believes that it is likely that the interior
of trucks would be significantly hotter
than the 50-degree Celsius
recommended maximum. Accordingly,
there is insufficient evidence in the
record for the Agency to determine
whether AEDs will work properly in
these temperature extremes during use,
even if they are stored in temperaturecontrolled environments as mentioned
by some rulemaking participants (see,
for example, Ex. 0186; Tr. 965–966).82
As explained previously, the Agency
stresses that defibrillation is a necessary
part of the response to electric shock
82 Some rulemaking participants gave other
reasons why OSHA should not require AEDs,
including: Costs of acquiring the devices (see, for
example, Exs. 0162, 0169, 0173, 0174, 0200, 0227),
varying State requirements related to AEDs, such as
requirements that they be prescribed by a physician
(see, for example, Exs. 0125, 0149, 0227), conflicts
with requirements of other Federal agencies, such
as the Food and Drug Administration (see, for
example, Exs. 0177, 0227), and OSHA’s failure to
meet all its regulatory burdens, such as burdens
imposed by the Small Business Regulatory
Enforcement Fairness Act (Ex. 0170). Because
OSHA decided not to require AEDs for the reason
given in this section of the preamble, it need not
consider these other issues.
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incidents that occur during work
covered by the final rule. OSHA is not
adopting a rule requiring AEDs because
the record is insufficient for the Agency
to conclude that these devices will be
effective in the conditions under which
they would be used. OSHA encourages
employers to purchase and deploy AEDs
in areas where they could be useful and
efficacious. This action likely will save
lives and provide the Agency with
useful information on the use of AEDs
under a wide range of conditions.
Proposed paragraph (b)(1) would have
required CPR training for field crews of
two or more employees, in which case
a minimum of two trained persons
would generally have been required
(proposed paragraph (b)(1)(i)), and for
fixed worksites, in which case enough
trained persons to provide assistance
within 4 minutes would generally have
been required (proposed paragraph
(b)(1)(ii)). Proposed paragraph (b)(1)(i)
provided that employers could train all
employees in first aid including CPR
within 3 months of being hired as an
alternative to having two trained
persons on every field crew. If the
employer chose this alternative for field
work, then only one trained person
would have been required for each
crew. In practice, crews with more than
one employee would normally have two
or more CPR-trained employees on the
crew, since all employees who worked
for an employer more than 3 months
would receive CPR training. However,
employers who rely on seasonal labor
(for example, employees hired only in
the summer months), or those with
heavy turnover, might have some twoperson crews with only one CPR-trained
employee. Because the Agency was
concerned that those new employees
might be most at risk of injury, OSHA
requested comment on whether
allowing employers the option of
training all their employees in CPR if
they are trained within 3 months of
being hired is sufficiently protective.
The Agency also requested comment on
how this provision could be revised to
minimize the burden on employers,
while providing adequate protection for
employees.
Several commenters shared OSHA’s
concern with the 3-month delay in CPR
training. (See, for example, Exs. 0126,
0187, 0213, 0230) Mr. Rob Land with
the Association of Missouri Electric
Cooperatives commented that this
option was too hazardous because of
‘‘the hazards that linemen face and the
distinct possibility that [emergency
medical services] may be delayed due to
remoteness and distances involved’’ (Ex.
0187). TVA opposed the option because
the ‘‘3[ ]months when a two-person
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crew would have only one CPR trained
member . . . reduce[s] the level of
safety provided’’ (Ex. 0213). IBEW
presented its reasons for opposing the 3month option, and its recommendation
for revising the rule, as follows:
Allowing employers the option of training
all their employees in CPR if they are trained
within 3 months of being hired may not work
in all situations. Many utilities engaged in
field work have implemented the use of 2person crews. It is not uncommon for the 2person crew to perform rubber gloving work
on all distribution voltage ranges. It is also
not uncommon for a utility to assign a newhire (less than 3 months of service) as the
second person on the 2-person crew. In these
work scenarios, the second person would
have to be trained in CPR. Waiting 3 months
to complete this training would not [be]
proper.
*
*
*
*
*
The only revision that is necessary is to
make it clear that under certain
circumstances, new-hires may need to be
trained in CPR well before the 3 month
window. Manning of crews, especially in the
construction industry, cannot always be
accomplished using CPR certification as a
factor. All employees need to receive the
training and the 3 months gives enough
flexibility when appropriate[.] [Ex. 0230;
emphasis included in original]
Other rulemaking participants
supported the provision as proposed.
(See, for example, Exs. 0155, 0162,
0174, 0200; Tr. 633–635, 764–765.)
Some of them argued that the provision,
which was taken from existing
§ 1910.269(b)(1)(i), has worked well.
(See, for example, Exs. 0155, 0200; Tr.
764.) The tree care industry stated that
the line-clearance tree trimming
industry did not use seasonal labor and
argued that the 3-month delay in
training new employees in CPR was
justified on the basis of high turnover in
that industry (Exs. 0174, 0200; Tr. 633–
635, 764–765). For example, testifying
on behalf of ULCC, Mr. Mark Foster
stated:
[T]he current standard reflects a clearly
considered balance made by OSHA at the
time of adoption of the current standard to
allow a three-month phase-in period for CPR
compliance for new hires. That policy
judgment rests on the fact that there was then
an 81 percent turnover rate among line
clearance tree trimming employees such that
many would not last in employment beyond
the initial training period and that that would
be very difficult to field crews if new hires
had first had to be sent for CPR training.
While the turnover ratio has improved
somewhat, it is still staggering[ly] high,
[presenting] the same considerations that led
to the adoption of the phase-in period in the
initial standard. [Tr. 633–634]
In its comment, ULCC indicated that the
annual turnover rate in the line-
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clearance tree trimming industry is 53 to
75 percent (Ex. 0174).
OSHA decided to restrict the
exception permitting a 3-month delay in
training employees in first aid,
including CPR, to line-clearance tree
trimming. The Agency agrees that
turnover in the line-clearance tree
trimming industry remains high, which
was the underlying reason for OSHA’s
original adoption of the 3-month delay
in training for newly hired employees in
the 1994 § 1910.269 rulemaking (59 FR
4346–4347). However, as noted by Mr.
Land, the provision as proposed leaves
employees exposed to hazards when a
new employee who has not yet been
trained in CPR is the second person in
a two-worker crew (Ex. 0187). IBEW
also recognized the need to have both
employees trained in CPR in many
circumstances (Ex. 0230). Finally,
turnover rates for the electric utility and
power line contractor industries are not
nearly as high as that for the tree
trimming industry. OSHA estimates that
the turnover rates among employees
performing electric power generation,
transmission, and distribution work
ranges from 11 to 16 percent in the
construction industries and 3 percent in
the generation and utility industries (see
Section VI, Final Economic Analysis
and Regulatory Flexibility Analysis,
later in the preamble). These turnover
rates are significantly lower than the
turnover rate indicated by ULCC for the
line-clearance tree trimming industry.
Because this exception in the final
rule applies only to line-clearance tree
trimming, which is addressed only in
§ 1910.269, the Agency is not adopting
it in final § 1926.951(b)(1).83 The
corresponding provision in
§ 1910.269(b)(1)(i) retains the exception
providing for a 3-month delay in firstaid training, including CPR, but only for
line-clearance tree-trimming work.
These changes will continue to permit
employers in the line-clearance tree
trimming industry to delay training in
first aid, including CPR, to new
employees for a reasonable time.
Finally, OSHA notes that it remains
concerned that some employees in the
line-clearance tree trimming industry
might encounter an unnecessary delay
in being treated in an emergency. The
Agency does not believe that it is
reasonable to unnecessarily staff crews
so that some crews had only one CPRtrained worker, while other crews had
83 Final § 1926.951(b) uses the term ‘‘trained
persons,’’ rather than ‘‘trained employees,’’ because
the individuals with the training do not necessarily
need to be employees. For instance, the ‘‘trained
persons’’ required by the rule could be selfemployed individuals working with a crew of
employees.
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three or four. Although the Agency is
not addressing this concern in the final
rule, OSHA expects employers to staff
each tree trimming crew with as many
employees trained in first aid as
possible, including CPR, to assist in
emergencies.
Mr. Steven Theis of MYR Group
requested that OSHA provide a similar
3-month grace period for refresher
training (Ex. 0162).84
OSHA rejects this request. As stated,
OSHA is adopting the 3-month delay in
CPR training because of the high
turnover in the tree trimming industry.
There is no evidence in the record that
this rationale also applies to refresher
training. The Agency expects employers
to plan for their employees’ training
needs and to schedule training in
accordance with the standard.
Mr. Paul Hamer, a member of the
NFPA 70E Technical Committee on
Electrical Safety in the Workplace,
recommended that OSHA require firstaid training, including CPR training, for
all qualified employees who work on
electric circuits of 50 volts or more. He
also recommended deleting the 4minute maximum response time for
fixed work locations (Ex. 0228). He
argued that the sooner a victim receives
CPR, the less cell damage will occur. On
the other hand, the American Forest &
Paper Association recommended that
the 4-minute requirement should be
deleted because ‘‘no one could ensure
([that is], guarantee) survival of the
victim for any particular length of time
or that defibrillation would be
successful’’ (Ex. 0237).
OSHA rejects these recommendations.
OSHA considered requiring all
employees to receive first-aid training,
including CPR training, when the
Agency developed existing § 1910.269.
In lieu of such a requirement, OSHA
decided that the best approach was to
require a 4-minute maximum response
time for fixed work locations and to
require at least two trained persons for
field work involving crews of two or
more employees (existing
§ 1910.269(b)). OSHA supplemented
these provisions with a requirement that
two employees be present for work
exposing an employee to contact with
exposed live parts energized at more
84 Although paragraph (b)(1) in the final rule does
not address refresher first-aid training, final
§ 1926.950(b)(4)(iii) contains a general requirement
that employees receive additional training when
they must employ safety-related work practices
(such as administering first aid) that are not
normally used during their regular work duties. A
note following § 1926.950(b)(4)(iii) indicates that
the Agency would consider tasks performed less
often than once per year to require retraining. See
the discussion of that requirement earlier in this
section of the preamble.
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than 600 volts (existing
§ 1910.269(l)(1)).85 This approach
continues to be the best one, as it
ensures that persons trained in first aid,
including CPR, will be available to
employees most at risk of electrocution.
The Agency further notes that Mr.
Hamer’s approach does not address
employees working alone in fixed work
locations. In these cases, it would still
take time for someone to discover the
injury, which also would delay first-aid
treatment, including CPR.
Two rulemaking participants
commented that proposed paragraphs
(b)(1)(i) and (b)(1)(ii) were vague (Exs.
0175, 0180). They did not understand
the difference between ‘‘field work’’ and
‘‘fixed work locations’’ (id.). For
example, Ms. Salud Layton with the
Virginia, Maryland & Delaware
Association of Electric Cooperatives
questioned whether the requirements
for fixed work locations applied to work
at unmanned substations (Ex. 0175).
OSHA does not consider an unmanned
location to be a fixed work location, as
there are normally no employees
present. In determining whether to
apply paragraph (b)(1) or (b)(2), the
Agency would treat an unmanned
substation no differently than a manhole
or utility pole in the field.
As explained previously in this
section of the preamble, OSHA decided
not to include proposed paragraphs
(b)(2) or (b)(3) in the final rule. The
corresponding provisions in existing
§ 1910.269(b)(2) and (b)(3) are being
retained, however. The Agency did not
propose to revise these existing
requirements and received no comments
alleging inconsistencies between
existing § 1910.269(b) and § 1910.151,
OSHA’s general industry standard
addressing medical services and first
aid.
Section 1926.952, Job Briefing
In § 1926.952, OSHA is requiring that
employers ensure that employees
conduct a job briefing before each job.
This section, which has no counterpart
in existing subpart V, is based largely on
existing § 1910.269(c).
Most of the work covered by this final
rule requires planning to ensure
employee safety (as well as to protect
equipment and the general public).
Typically, electric power transmission
and distribution work exposes
employees to the hazards of exposed
conductors energized at thousands of
volts. If the work is not thoroughly
85 The issue of whether the requirement for two
employees should apply to voltages of 600 volts or
less is discussed under the summary and
explanation of final § 1926.960(b)(3), later in this
section of the preamble.
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planned ahead of time, the possibility of
human error that could harm employees
increases greatly. To avoid problems,
the task sequence is prescribed before
work is started. For example, before
climbing a pole, the employee must
determine if the pole is capable of
remaining in place and if minimum
approach distances are sufficient, and
he or she must determine what tools
will be needed and what procedure
should be used for performing the job.
Without job planning, the worker may
not know or recognize the minimum
approach-distance requirements or may
have to reclimb the pole to retrieve a
forgotten tool or perform an overlooked
task, thereby increasing employee
exposure to the hazards of falling and
contact with energized lines.
Employers performing electric power
generation, transmission, and
distribution work use job briefings to
plan the work and communicate the job
plan to employees. If the job is planned,
but the plan is not discussed with the
workers, an employee may perform his
or her duties out of order or may not
coordinate activities with the rest of the
crew, thereby endangering the entire
crew. Therefore, OSHA is requiring a
job briefing before work is started.
Commenters agreed that job briefings
are an important part of electric power
work. (See, for example, Exs. 0162,
0173, 0184, 0213, 0241; Tr. 1335.) For
instance, Mr. John Masarick of the
Independent Electrical Contractors
considered job briefings to be ‘‘one of
the most critical steps for safety on any
task’’ (Ex. 0241). Also, Mr. Stephen
Frost of the Mid-Columbia Utilities
Safety Alliance voiced his
organization’s support for job briefings:
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We strongly agree that the job briefing
requirement should be written into
§ 1926.952. Good communications on the job
is paramount to safety, and too often workers
either choose not to communicate or don’t
have the skills to communicate their ideas.
The job briefing requirement makes it the
personal responsibility of every crew member
to understand all aspects of the job. The time
it takes to do a thorough job briefing is
usually 5 to 15 minutes. This is time wellspent to eliminate the possibility of an
accident due to workers not knowing or
controlling hazards in the work area. [Ex.
0184]
OSHA’s experience in enforcing
§ 1910.269(c), however, shows that
some employers are placing the entire
burden of compliance with the job
briefing requirement on the employee in
charge of the work. Therefore, OSHA
proposed to include a provision in
Subpart V requiring the employer to
provide the employee in charge of a job
with available information necessary to
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perform the job safely. This
requirement, which is not in existing
§ 1910.269(c), was in proposed
§ 1926.952(a)(1). OSHA proposed to add
the same requirement to § 1910.269(c).
A note following the proposed
paragraph indicated that the
information provided by the employer
was intended to supplement the training
requirements proposed in § 1926.950(b)
and was likely to be more general than
the job briefing provided by the
employee in charge. This note also
clarified that information covering all
jobs for a day could be disseminated at
the beginning of the day.
Many commenters recognized the
need for the employer to provide certain
information to the employee in charge
about conditions to which an employee
would be exposed. (See, for example,
Exs. 0125, 0127, 0186, 0197, 0200, 0219,
0230.) For instance, Mr. Anthony Ahern
with Ohio Rural Electric Cooperatives
commented:
The person in charge does need to be given
more information than is usually given him/
her. They need to know things like the status
of the system where they will be working.
What are the breaker configurations/settings.
Is reclosing enabled or disabled. What is the
available fault current at their work site. Are
there any other crews working in the area
whose work could impact them. For the most
part most of this information is of a general
type and a company could probably develop
a simple form that would be fairly easy to fill
out and attach to the usual work orders. This
could also be used to document that this
information was given and could be used to
document the job briefing (tailgate) that the
person in charge is required to give the rest
of the crew. [Ex. 0186]
Mr. James Junga, the Safety Director of
Local 223 of the Utility Workers Union
of America (UWUA), also commented
on the need for the employer to supply
information about the work:
Requiring the employer to provide
adequate information to the employee in
charge of a crew is the best way of ensuring
that all available information is given to the
crew leader. Then and only then the crew
leader will be able to brief the crew. Without
this requirement a crew leader will be left on
his/her own to figure out what the crew is
to do. [Ex. 0197]
Some rulemaking participants
described the types of information that
should be provided to employees. (See,
for example, Exs. 0186, 0219; Tr. 402–
403, 1373.) Commenters stated that
employees in charge need to be
provided with the available fault current
(Ex. 0186; Tr. 1373), circuit breaker
settings, including whether reclosing is
enabled (Ex. 0186), whether there are
other crews that could affect their work
(Ex. 0186), detailed maps and staking
sheets (Ex. 0219), and relevant
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information from outage reports by
customers (Tr. 402–403).
Other rulemaking participants
addressed when there was a need for the
employer to provide information about
a job. Mr. Allan Oracion with
EnergyUnited EMC maintained: ‘‘When
a job is not routine, special or largescale, the employer needs to share any
special information with the employee
in charge. When the employee in charge
is working at a distant location, radio or
telephone can be used to communicate
information’’ (Ex. 0219). Mr. Donald
Hartley with IBEW stated that the
employer needs to provide information
‘‘when a contractor’s crew performs its
first tasks on a host employer’s worksite
or when the job assignment involves
hazards or conditions the crew has not
yet encountered’’ (Tr. 887).
However, many commenters argued
that the provision as proposed was
inappropriate. (See, for example, Exs.
0125, 0127, 0128, 0163, 0177, 0178,
0200, 0201 0226.) Many argued that the
proposed provision was too broad. (See,
for example, Exs. 0125, 0127, 0200,
0226.) For instance, Ms. Cynthia Mills
of TCIA stated, ‘‘We are uncomfortable
with the open-ended and subjective
nature of the [proposed language], even
though we believe it is intended to
convey anything ‘known to the
employer, but unusual,’ associated with
the work assignment’’ (Ex. 0200).
Some commenters argued that it was
the responsibility of the employee in
charge to survey the site and determine
all hazards associated with the work.
(See, for example, Exs. 0163, 0177,
0178, 0201.) Consumers Energy’s
submission typified these comments:
The computer-generated job assignment
will contain information related to the
location, circuit, and task to be accomplished
but no information related to unique hazards
of the assignment. It is critical that the
employees on the job site survey the site and
identify all hazards upon arrival at the site.
Removing that responsibility from them
would create a false sense of security and a
less than desirable knowledge of the hazards
present. Safety manuals and written
procedures provide general information on
hazards that are typically expected in
transmission and distribution work. It is the
responsibility of the employee in charge to
survey the site and identify all hazards upon
arrival at the site. [Ex. 0177]
After carefully considering the
evidence in the record, OSHA
concludes that job briefings are
important for ensuring the safety of
employees performing work covered by
the final rule and that the employer
needs to provide adequate information
to employees in charge so that a
complete job briefing can be conducted.
However, OSHA also decided to address
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the concerns of commenters that the
proposed rule was overly broad or open
ended. To this end, OSHA decided to
require the employer to provide the
employee in charge of the job with all
available information that relates to the
determination of existing characteristics
and conditions required by
§ 1926.950(d). Thus, final
§ 1926.952(a)(1) requires the employer,
in assigning an employee or a group of
employees to perform a job, to provide
the employee in charge of the job with
all available information that relates to
the determination of existing
characteristics and conditions required
by § 1926.950(d).
The Agency notes that final paragraph
(a)(1) requires the employer to provide
the employee in charge with two types
of available information, as noted in
§ 1926.950(d): (1) Available information
on the characteristics of electric lines
and equipment, and (2) available
information on the conditions of the
installation. The Agency also notes that,
because § 1926.950(d) limits the
determination of characteristics and
conditions only to characteristics and
conditions that relate to the safety of the
work to be performed, this same
limitation extends to information that
must be provided under final
§ 1926.952(a)(1). As such, information
on the characteristics of electric lines
and equipment that must be provided
under the final rule (including, for
instance, the nominal voltage of lines
and equipment, the maximum switching
transient voltages, and the presence of
hazardous induced voltage) is critical to
the selection of proper safety-related
work practices and protective
equipment.86 For example, for an
employee to select the minimum
approach distance required by final
§ 1926.960(c)(1), he or she needs to
know, at a minimum, the nominal
voltage on the energized parts.
Depending on the employer’s
established minimum approach
distances, the employee also may need
to know the maximum transient
overvoltage at the worksite. Similarly,
an employee needs to know the
employer’s estimate of incident energy
for electric equipment so that he or she
can select protective equipment with an
appropriate arc rating as required by
final § 1926.960(g)(5).
Information on the conditions of the
installation that must be provided under
the final rule (including, for instance,
the condition of protective grounds and
86 In fact, these are the types of information that
commenters argued employers should provide.
(See, for example, Exs. 0186, 0219; Tr. 402–403,
1373.)
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equipment grounding conductors, the
condition of poles, and environmental
conditions relative to safety) also is
critical because that information can
facilitate the employees’ assessment of
conditions at the worksite and enable
the employees to take appropriate
protective measures. For example, an
employer may know of defects in a
wood pole on which employees are to
work because it has a pole-inspection
program or has received reports that the
pole had defects. Information on such
defects can help employees ascertain
whether the pole is safe to climb as
required by § 1926.964(a)(2). Likewise,
information from an employee or a
customer that electric equipment is
making arcing noises periodically can
affect the assessment of whether the
employee is exposed to hazards from
flames or electric arcs as required by
§ 1926.960(g)(1).
Thus, the type of information that the
employer must provide under the final
rule ensures that employees in charge
are provided with information relevant
to selecting appropriate work practices
and protective equipment as required by
the final rule. Moreover, because final
§ 1926.952(a)(1) links the information
that the employer must provide the
employee in charge to the determination
required by § 1926.950(d), final
§ 1926.952(a)(1) is neither overly broad
nor open ended.
The final rule also is narrowly
tailored because it limits the
information the employer must provide
to information that is available to the
employer. Under the rule, the question
of whether information is available to
the employer varies depending on the
type of information at issue. First,
OSHA presumes that information
related to the characteristics of electric
lines and equipment is available to the
employer. Second, OSHA will deem
information on the condition of the
installation to be available to the
employer only when the information is
known by the employer or can be
obtained by the employer from existing
records through the exercise of
reasonable diligence. OSHA does not
expect employers to make inspections of
worksite conditions to determine the
conditions of the installation. The
Agency believes that, in most instances,
employees will gather additional
information about worksite conditions
after they reach the worksite. It is
nevertheless important that employers
provide employees with available
information to aid the employees’
assessment of worksite conditions and
as a secondary precaution in case
employees at the site fail to observe a
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20373
particular condition related to their
safety.
Paragraph (a)(1) of 1926.952 applies
fully to contractors. Contractors will
obtain much or all of the information
that they need to comply with
§ 1926.952(a)(1)—especially information
about the characteristics of electric lines
and equipment—through the operation
of the host-contractor provision in
§ 1926.950(c).
Several commenters maintained that,
in proposing this provision, OSHA did
not account for the way work is
currently assigned to employees. (See,
for example, Exs. 0128, 0163, 0177,
0178, 0201.) For instance, Mr. James
Shill of ElectriCities noted that small
towns often assign work through a town
manager who has insufficient
knowledge of the electrical system to
provide the required information (Ex.
0178). Further, Mr. James Gartland of
Duke Energy described how the process
commonly used to assign work to
employees at many utilities was at odds
with the proposal:
Requiring a representative of the employer
(a manager or supervisor) to provide
employees with information necessary to
perform a job safely for every job is
inconsistent with the use of technology in
work management and scheduling. Today’s
utility workers drive vehicles equipped with
computers with wireless communications.
They receive job assignments throughout the
day from the computer. There frequently is
no direct supervisor-employee interface to
discuss specific work assignments. The
computer-generated job assignment will
contain information related to the location,
circuit, and task to be accomplished but no
information related to unique hazards of this
assignment. . . .
It is also inconsistent with industry
practices to expect a supervisor/manager to
conduct a pre-job briefing at the beginning of
the day as mentioned in the Note [to
proposed § 1926.952(a)(1)]. Many utilities
have employees who report directly to work
locations where their supervisor/manager is
not present. They are expected to do a prejob briefing and to assess hazards on their
own. There is no company manager/
supervisor at the work location to do that
assessment. [Ex. 0201]
Some of these commenters also
recommended that the Agency make it
clear (1) that the rule does not require
a face-to-face exchange of information
and (2) that the exchange can be
provided through work orders or in
conjunction with training, safety
manuals, and written procedures. (See,
for example, Exs. 0177, 0201.)
OSHA appreciates these commenters’
concerns and therefore changed the
heading for paragraph (a)(1) to read
‘‘Information provided by the
employer’’ to help clarify that a separate
briefing or face-to-face discussion
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between the employer and the employee
in charge is not required. The Agency
recognizes that assignments are made
through a wide range of mechanisms
that do not always provide for face-toface contact between the employer and
the employees performing the work. The
rule does not require such contact. The
employer is free to use any mechanism
that provides the required information
before the employees begin their
assignment. For example, information
could be provided through radio
communication with the employee in
charge, through a written work order, or
through a computer-generated
assignment conveyed electronically.
Some of this information may be
provided through training, in a safety
manual, or through written work
procedures. However, the Agency will
deem such information as meeting
paragraph (a)(1) only if it effectively
communicates the information about the
particular job in question to the
employee in charge and if employers
respond to these employees’ questions
about this information as it relates to the
particular job in question.
Some commenters suggested that
OSHA add certain explicit language to
the requirement. (See, for example, Exs.
0125, 0127, 0149, 0169, 0171.) For
instance, several commenters
recommended revising the rule to read:
‘‘In assigning an employee or group of
employees to perform a job, the
employer shall provide the employee in
charge of the job with any additional
information known by the employee’s
supervisor that could affect the safety of
the job before the start of the work’’
(Exs. 0125, 0127, 0149). Other
commenters recommended that OSHA
clarify that the employer need only
provide the information once for work
lasting long periods of time (Exs. 0169,
0171).
OSHA rejects these recommended
approaches. First, the key issue is
whether the information is available to
the employer, not whether the
supervisor has knowledge of the
required information. Second, the final
rule requires the employer to provide
required information in connection with
each job. As stated, the information
must be communicated to the employee
in charge in an effective manner.
Whether a prior communication
constitutes an effective communication
depends on several factors, such as, but
not limited to: The time between the
prior communication and the job at
hand; the manner in which the prior
communication was made; the extent to
which the prior job and the present job
are similar; and whether any additional
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or different information needs to be
provided with respect to the present job.
OSHA is not including in the final
rule the note following proposed
paragraph (a)(1). This note was to clarify
the meaning of the phrase ‘‘available
information necessary to perform the job
safely.’’ The final rule does not contain
that phrase, and OSHA concludes that
the note is no longer necessary.
Paragraph (a)(2), which is being
adopted without substantive change
from the proposal, requires the
employee in charge of the job to conduct
a job briefing. This provision comes
from existing § 1910.269(c).
In the 2005 notice extending the
comment period on the proposal, OSHA
requested comments on whether the
standard should include a requirement
to document the job briefing. Comments
addressing this issue recommended that
the Agency not include such a
requirement in the final rule because it
would add to employers’ paperwork
burden without a significant increase in
safety. (See, for example, Exs. 0201,
0212.) Considering the lack of record
support for such a provision, OSHA is
not adopting a requirement to document
job briefings in the final rule.
Paragraph (b), which is being adopted
without substantive change from the
proposal, requires the briefing by the
employee in charge to cover: Hazards
and work procedures involved, special
precautions, energy-source controls, and
requirements for personal protective
equipment. This requirement also
comes from existing § 1910.269(c).
Under final paragraph (c)(1), the
employee in charge must conduct at
least one briefing before the start of each
shift. Only one briefing in a shift is
needed if all the jobs to be performed
are repetitive or similar. Additional
briefings must be conducted pursuant to
final paragraph (c)(2) for work involving
significant changes in routine that might
affect the safety of the employees. For
example, if the first two jobs of the day
involve working on a deenergized line
and the third job involves working on
energized lines with live-line tools,
separate briefings must be conducted for
each type of job. It should be noted that
additional job briefings provided under
paragraph (c)(2) are separate from the
job briefing provided at the start of the
shift; these briefings may not be
combined. Paragraphs (c)(1) and (c)(2),
which duplicate existing
§ 1910.269(c)(1), have been adopted
without substantive change from the
proposal.
For routine work, under final
paragraph (d)(1), the required briefing
need only consist of a concise
discussion outlining the tasks to be
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performed and how to perform them
safely. However, if the work is
complicated or particularly hazardous
or if the employees may not be able to
recognize and avoid the hazards
involved, then a more thorough
discussion is required by paragraph
(d)(2). OSHA included a note following
this paragraph to clarify that, regardless
of how short the discussion is, the
briefing must still address all the topics
listed in paragraph (b).
OSHA received several comments on
proposed paragraphs (d)(1) and (d)(2).
These commenters expressed concern
that the proposed provisions were vague
and provided insufficient guidance on
the conditions requiring more detailed
job briefings. (See, for example, Exs.
0162, 0175, 0213.) For instance, MYR
Group maintained that the proposal did
not sufficiently distinguish between
work that is ‘‘routine’’ and work that is
‘‘complicated’’ (Ex. 0162; Tr. 1335), and
TVA asked the Agency to define
‘‘complicated or particularly hazardous’’
(Ex. 0213).
With final paragraphs (d)(1) and
(d)(2), which were taken from existing
§ 1910.269(c)(2), OSHA recognizes that
employees are familiar with the tasks
and hazards involved in routine work.
However, it is important to take the time
to carefully discuss unusual work
situations that may pose additional or
different hazards to workers. (See also
the discussion of § 1926.950(b)(4) earlier
in this section of the preamble.) The
Agency believes that it is important for
the briefing to be as detailed as
necessary for the hazards and work
practices involved. MYR Group noted
that ‘‘the general requirement for short
discussions could . . . be applied
differently depending on the skill and
qualification of the employees involved
in the work rather than the work itself’’
(Ex. 0162). This comment interprets the
requirement correctly, and the Agency
believes that the language in final
§ 1926.952(d)(1) and (d)(2), which
duplicates existing § 1910.269(c)(2),
appropriately conveys this meaning.
Accordingly, a more detailed discussion
is required ‘‘[i]f the employee cannot be
expected to recognize and avoid the
hazards involved in the job.’’ In
addition, the Agency has received no
formal interpretation requests related to
existing § 1910.269(c)(2). Thus, OSHA
concludes that the vast majority of
employers understand this provision,
and the Agency is adopting
§ 1926.952(d) without change from the
proposal.
OSHA recognizes the importance of
job planning for all employees.
Although employees working alone
cannot participate in formal job
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briefings, the Agency believes that an
employee who works alone needs to
plan his or her tasks as carefully and
extensively as an employee who works
as part of a team. OSHA is aware of
several fatalities involving lone
employees who could have benefited
from better job planning, or perhaps a
briefing with the supervisor, before the
job started (Ex. 0400). In one such
incident, a power line worker working
alone was repairing a broken guy.
Standing on the ground, the employee
had the anchor in place and grabbed the
dangling guy to attach it to the anchor.
The guy contacted a 7200-volt overhead
power line that had not been guarded or
insulated. Had the employee properly
planned the job, he would have seen
that the guy was close to the power line
and could have avoided the contact
(id.).87 Therefore, paragraph (e), which
OSHA took from existing
§ 1910.269(c)(3), provides that
employees working alone do not need to
conduct job briefings, but the employer
must ensure that that the tasks are
planned as if a briefing were required.
This provision is being adopted in the
final rule without change from the
proposal.
4. Section 1926.953, Enclosed Spaces
Section 1926.953 contains
requirements for entry into, and work
in, enclosed spaces. An ‘‘enclosed
space’’ is defined in final § 1926.968 as
a working space, such as a manhole,
vault, tunnel, or shaft, that has a limited
means of egress or entry, that is
designed for periodic employee entry
under normal operating conditions, and
that, under normal conditions, does not
contain a hazardous atmosphere, but
may contain a hazardous atmosphere
under abnormal conditions. The hazards
posed by enclosed spaces consist of (1)
limited access and egress, (2) possible
lack of oxygen, (3) possible presence of
flammable gases, and (4) possible
presence of limited amounts of toxic
chemicals. The potential atmospheric
hazards are caused by an enclosed
space’s lack of adequate ventilation and
can normally be controlled through the
use of continuous forced-air ventilation
alone. Practices to control these hazards
are widely recognized and are currently
in use in electric, telecommunications,
and other underground utility
industries. Such practices include
testing for the presence of flammable
gases and vapors, testing for oxygen
deficiency, ventilation of the enclosed
space, controls on the use of open
87 This accident can be viewed at: https://
www.osha.gov/pls/imis/accidentsearch.accident_
detail?id=909119.
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flames, and the use of an attendant
outside the space. These practices
already are required by existing
§ 1910.269(e) for the maintenance of
electric power generation, transmission,
and distribution installations, and
OSHA took the requirements adopted in
final § 1926.953 from existing
§ 1910.269(e).
Paragraph (a) of final § 1926.953,
which is being adopted without
substantive change from the proposal,
sets the scope of the section’s
provisions. Accordingly, this section
applies only to the types of enclosed
spaces that are routinely entered by
employees engaged in electric power
transmission and distribution work and
that are unique to underground utility
work. Work in these spaces is part of the
day-to-day activities performed by some
of the employees protected by this final
rule. Enclosed spaces covered by this
section include, but are not limited to,
manholes and vaults that provide
employees access to electric power
transmission and distribution
equipment.
There are several types of spaces that
are not covered by final § 1926.953 (or
the corresponding general industry
provisions in final § 1910.269(e)). If
maintenance work is being performed in
confined spaces, it may be covered by
OSHA’s general industry permitrequired confined space (permit-space)
standard at § 1910.146; this standard
applies to all of general industry,
including industries engaged in electric
power generation, transmission, and
distribution work.
In § 1910.146(b), the permit-space
standard defines ‘‘confined space’’ and
‘‘permit-required confined space.’’ A
confined space is a space that: (1) Is
large enough and so configured that an
employee can bodily enter and perform
assigned work; and (2) Has limited or
restricted means for entry or exit (for
example, tanks, vessels, silos, storage
bins, hoppers, vaults, and pits are
spaces that may have limited means of
entry); and (3) Is not designed for
continuous employee occupancy. A
permit-required confined space (permit
space) is a confined space that has one
or more of the following characteristics:
(1) Contains or has a potential to contain
a hazardous atmosphere; (2) Contains a
material that has the potential for
engulfing an entrant; (3) Has an internal
configuration such that an entrant could
be trapped or asphyxiated by inwardly
converging walls or by a floor which
slopes downward and tapers to a
smaller cross-section; or (4) Contains
any other recognized serious safety or
health hazard.
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Section 1926.953 of the final rule
applies to ‘‘enclosed spaces.’’ By
definition, an enclosed space is a
permit-required confined space under
§ 1926.146. An enclosed space meets the
definition of a confined space—it is
large enough for an employee to enter;
it has a limited means of access or
egress; and it is designed for periodic,
rather than continuous, employee
occupancy under normal operating
conditions. An enclosed space also
meets the definition of a permit space—
while it is not expected to contain a
hazardous atmosphere, it has the
potential to contain one. OSHA also
notes that the definition of permit space
in the general industry permit-space
standard is broader than the definition
of enclosed space in § 1926.968. For
instance, if a space contains a hazardous
atmosphere under normal conditions,
that space is a permit space under
§ 1910.146, but it is not an enclosed
space under final § 1910.269 or Subpart
V.
Paragraph (b)(6) of § 1926.21 specifies
training requirements for employees
who enter ‘‘confined or enclosed
spaces’’ as defined in § 1926.21(b)(6)(ii).
When § 1926.21(b)(6) applies, it
requires employers to: (1) Instruct their
employees about confined-space
hazards, the necessary precautions to be
taken, and protective and emergency
equipment required; and (2) comply
with any specific regulations that apply
to work in dangerous or potentially
dangerous areas. An enclosed space
under § 1926.953 also is a confined or
enclosed space under § 1926.21(b)(6).
However, the definition of confined or
enclosed space in § 1926.21(b)(6) (like
the definition of permit space in the
general industry permit-space standard)
is broader than the definition of
enclosed space in § 1926.968.88
Paragraph (b)(6) of § 1926.21 applies
to enclosed spaces covered by final
§ 1926.953 because employers covered
under subpart V are not exempt from
complying with other applicable
provisions in Part 1926 (see
§ 1926.950(a)(2)). Section 1926.953 is,
therefore, different from final
§ 1910.269(e), which ‘‘applies to routine
entry into enclosed spaces in lieu of the
permit-space entry requirements
contained in paragraphs (d) through (k)
of § 1910.146.’’ OSHA concludes,
however, that an employer that is
compliant with § 1926.953 is considered
as being in compliance with existing
§ 1926.21(b)(6) for entry into enclosed
88 Under § 1926.21(b)(6)(ii), a confined or
enclosed space is any space having a limited means
of egress, which is subject to the accumulation of
toxic or flammable contaminants or has an oxygen
deficient atmosphere.
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spaces covered by final § 1926.953.
Therefore, for all practical purposes,
§ 1926.953 applies to routine entry into
enclosed spaces in lieu of the
requirements contained in
§ 1926.21(b)(6). OSHA is not including
the ‘‘in lieu of’’ language in final
§ 1926.953 because OSHA recently
proposed a new standard for confinedspace entry during construction work
(72 FR 67352, Nov. 28, 2007). OSHA
intends to revise § 1926.953 to include
appropriate ‘‘in lieu of’’ language when
it promulgates the new standard.
Under final § 1926.953(a), entry into
an enclosed space to perform
construction work covered by Subpart V
must meet the permit-space entry
requirements of paragraphs (d) through
(k) of the general industry permit-space
standard at § 1910.146 when the
precautions taken under §§ 1926.953
and 1926.965 are insufficient to
eliminate hazards in the enclosed space
that endanger the life of an entrant or
could interfere with escape from the
space. This requirement ensures that
employees working in enclosed spaces
will be afforded protection in
circumstances in which the Subpart V
provisions are insufficiently
protective.89
Some employers may prefer to
comply with § 1910.146 instead of
§ 1926.953 for entry into enclosed
spaces covered by Subpart V. Because
the provisions of § 1910.146 protect
employees entering enclosed spaces at
least as effectively as § 1926.953, OSHA
will accept compliance with § 1910.146
as meeting the enclosed-space entry
requirements of § 1926.953. OSHA
included a note to this effect
immediately following final
§ 1926.953(o). The Agency is adopting
the note as proposed.
MYR Group opposed applying the
general industry standard for permit
spaces to construction work. The
company argued that subpart V should
not incorporate ‘‘standard requirements
that have already been rejected for
construction work’’ and recommended
that the Agency develop requirements
specific ‘‘to electrical construction work
or through the proposed and pending
89 Section 1926.953 thus functions similarly to
corresponding provisions in § 1910.146. An
employer need not follow the permit-entry
requirements of § 1910.146 for spaces where the
hazards have been completely eliminated, or for
limited situations in which OSHA permits the use
of alternative procedures (§ 1910.146(c)(5) and
(c)(7)). The spaces for which alternative procedures
may be used are similar to ‘‘enclosed spaces,’’ as
defined in this final rule, and the alternative
procedures themselves are similar to the procedures
contained in final § 1926.953 (§ 1910.146(c)(5); 58
FR 4462, 4486–4489, Jan. 14, 1993).
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separate confined space standard for
construction’’ (Ex. 0162).
OSHA disagrees with this comment.
The Agency developed the enclosedspace provisions in existing § 1910.269
to protect employees during routine
entry into enclosed spaces. As discussed
in detail previously, OSHA concluded
that the requirements for work on
electric power generation, transmission,
and distribution installations should
generally be the same regardless of
whether the work is covered by final
§ 1910.269 or subpart V. (See the
summary and explanation for final
§ 1926.950(a)(1), earlier in this section
of the preamble.) For the purpose of
routine entry into these spaces, OSHA
concludes that it is appropriate for
employers to follow the same rules with
respect to both construction and general
industry work.
OSHA also is applying the general
industry permit-space standard to work
in enclosed spaces when the hazards
remaining in the enclosed space
endanger the life of an entrant or could
interfere with escape from the space
after an employer takes the precautions
required by §§ 1926.953 and 1926.965.
This action is necessary because, as
OSHA noted in the proposed
construction standard for confined
spaces, ‘‘the existing construction
standard for confined and enclosed
spaces at 29 CFR 1926.21(b)(6) does not
adequately protect construction
employees in confined spaces from
atmospheric, mechanical, and other
hazards’’ (72 FR 67354). OSHA notes,
however, that the references to the
general industry standard in final
§ 1926.953 are included as a placeholder
pending the promulgation of the
confined spaces in construction
standard. OSHA intends to change these
references to refer to the construction
standard when it promulgates that
standard.
Paragraph (a) in final § 1926.953
provides that § 1926.953 does not apply
to vented vaults under certain
conditions. Permanent ventilation in
vented vaults prevents a hazardous
atmosphere from accumulating.
However, the intake or exhaust of a
vented vault could be clogged, limiting
the flow of air through the vaults. The
employee in such cases would be
exposed to the same hazards presented
by unvented vaults. Additionally,
mechanical ventilation for a vault so
equipped may fail to operate. To ensure
that the employee is protected from the
hazards posed by lack of proper
ventilation, the final rule exempts
vented vaults only if the employer
determines that the ventilation is
operating to protect employees. This
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determination must ensure that
ventilation openings are clear and that
any permanently installed mechanical
ventilating equipment is in proper
working order.
Section 1926.953 also does not apply
to spaces not designed for periodic entry
by employees during normal operating
conditions, such as spaces that require
energy sources to be isolated or fluids to
be drained before an employee can
safely enter. These types of spaces
include, but are not limited to, boilers,
fuel tanks, coal bunkers, and
transformer and circuit breaker cases.
As explained in the preamble to the
1994 § 1910.269 final rule, the measures
required in existing § 1910.269(e) (and,
by implication, final § 1926.953) are not
adequate to protect employees from the
various hazards posed by these types of
permit-entry confined spaces (59 FR
4364–4367).
MYR Group commented that subpart
V’s definition of ‘‘enclosed space’’ was
‘‘overly narrow and unclear’’ because
‘‘there is no specific basis for creation of
such a broad definition solely for
electrical work’’ (Ex. 0162).
OSHA disagrees with this comment.
The Agency derived the definition from
the definition of ‘‘enclosed space’’ in
existing § 1910.269(x). As explained in
the preamble to the 1994 § 1910.269
final rule, OSHA narrowly tailored the
definition of ‘‘enclosed space’’ to the
protective measures required by existing
§ 1910.269(e) (59 FR 4364–4367). A
broader definition would involve permit
spaces presenting hazards against which
final § 1926.953 would not offer
protection. Therefore, OSHA is adopting
the definition of ‘‘enclosed space’’ as
proposed. However, OSHA is not
adopting the proposed note in final
§ 1926.968.90 The proposed note, which
appears in existing § 1910.269(x),
describes types of spaces that are
enclosed, but that do not meet the
definition of ‘‘enclosed space,’’ and
explains that such spaces meet the
definition of permit spaces in
§ 1910.146 and that entries into those
spaces must conform to that standard.
Although the types of spaces described
in the proposed note do not meet the
definition of ‘‘enclosed space’’ in either
the general industry or construction
standard, § 1910.146 does not apply to
confined-space entry during
construction work. Consequently, the
final rule does not include the note to
the definition of ‘‘enclosed space’’ in
final § 1926.968. OSHA intends to revise
§ 1926.968 to include an appropriate
note to the definition of ‘‘enclosed
90 OSHA is not removing the existing note to that
definition from final § 1910.269(x).
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space’’ when it promulgates the new
standard for confined-space entry
during construction work.
Paragraph (b), which is being adopted
without substantive change from the
proposal, contains the general
requirement that employers ensure the
use of safe work practices for entry into,
and work in, enclosed spaces and for
rescue of employees from such spaces.
These safe work practices ensure that
employees are protected against hazards
in the enclosed space and include,
among others, the practices specified in
paragraphs (e) through (o).
Paragraph (c), which is being adopted
without substantive change from the
proposal, requires each employee who
enters enclosed spaces, or who serves as
an attendant, to be trained in the
hazards associated with enclosed-space
entry and in enclosed-space entry and
rescue procedures. This training must
ensure that employees are trained to
work safely in enclosed spaces and that
they will be knowledgeable of the
rescue procedures in the event that an
emergency arises within the space.
Paragraph (d), which is being adopted
without change from the proposal,
requires that the employer provide
equipment that will assure the prompt
and safe rescue of employees from the
enclosed space. This requirement is
necessary to ensure that employees who
are injured in enclosed spaces will be
retrieved from the spaces. The
equipment must enable a rescuer to
remove an injured employee from the
enclosed space quickly and without
injury to the rescuer or further harm to
the injured employee. A harness,
lifeline, and self-supporting winch can
normally be used for this purpose.
Mr. Leo Muckerheide with Safety
Consulting Services recommended that,
because of the risk of arc hazards, OSHA
should explicitly require nonconductive
and flame-resistance-rated rescue
equipment that meets ASTM F887,
Standard Specifications for Personal
Climbing Equipment (Ex. 0180). He
argued that the general industry
confined space standard does not
protect against arc-flash and electricshock hazards and contrasted proposed
paragraph (d) with provisions in
proposed § 1926.960 that do require
protection from these hazards (id.).
OSHA rejects this recommendation.
First, work in enclosed spaces does not
always pose arc-flash or electric-shock
hazards. Sometimes, employees enter
spaces to take readings or perform
inspections; during these activities these
hazards are unlikely to be present,91 or
91 It is possible under certain circumstances that
employees taking readings or performing inspection
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there may be no energized electric
equipment present.
Second, addressing arc-flash and
electric-shock hazards in § 1926.953
would be unnecessarily duplicative, as
these hazards are more appropriately
addressed in § 1926.960, which applies
to work on or near exposed live parts.
When work is performed within
reaching distance of exposed energized
parts of equipment, final § 1926.960(f)
requires the employer to ensure that
each employee removes, or renders
nonconductive, all exposed conductive
articles, unless such articles do not
increase the hazards associated with
contact with the energized parts. This
provision covers conductive articles on
harnesses. Paragraph (c)(1)(iii) of final
§ 1926.960 requires the employer to
ensure that employees do not take
conductive objects, such as conductive
lifelines, closer to energized parts than
the employer’s established minimum
approach distances, unless the live parts
or conductive objects are insulated.92
Because, in a rescue situation, the
attendant would not have control over
how close the lifeline got to exposed
energized parts, any lifeline would have
to be insulated, or the live parts would
have to be insulated, to protect the
attendant and the entrant against
electric shock. Paragraph (g)(1) of final
§ 1926.960 requires the employer to
assess the workplace to determine if
each employee is exposed to hazards
from flames or electric arcs. This
assessment can guide the selection of
rescue equipment that can effect safe
rescue when employees are exposed to
these hazards. If there is a risk that an
electric arc could occur in an enclosed
space, then the rescue equipment must
be capable of withstanding that
hazardous condition.
Some conditions within an enclosed
space, such as high temperature and
high pressure, make it hazardous to
remove a cover from the space. For
example, if high pressure is present
within the space, the cover could be
blown off in the process of removing it.
Paragraph (e), which is being adopted
without substantive change from the
proposal, protects against these hazards
by requiring a determination of whether
it is safe to remove the cover. This
determination must include checking
for the presence of any atmospheric
pressure or temperature differences
activities could be exposed to arc-flash hazards. See
the discussion of arc-flash hazard assessment under
the summary and explanation for final
§ 1926.960(g)(1), later in this section of the
preamble.
92 There is a third exception associated with liveline barehand work, which is generally inapplicable
in enclosed spaces.
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(generally between the inside and
outside of the enclosed space) and
evaluating whether there might be a
hazardous atmosphere in the space.
Furthermore, any condition making it
unsafe for employees to remove the
cover must be eliminated (that is,
reduced to the extent that it is no longer
unsafe) before the cover is removed. A
note following paragraph (e) clarifies
that this determination may consist of
checking the conditions that might
foreseeably be inside the enclosed
space. For example, the cover could be
checked to see if it is hot and, if it is
fastened in place, it could be loosened
gradually to release any residual
pressure. The note also clarifies that, to
evaluate whether there might be a
hazardous atmosphere in the space, an
evaluation needs to be made of whether
conditions at the site could cause a
hazardous atmosphere to accumulate in
the space.
Paragraph (f), which is being adopted
without substantive change from the
proposal, requires that, when covers are
removed, openings to enclosed spaces
be promptly guarded to protect
employees from falling into the space
and to protect employees in the
enclosed space from being injured by
objects entering the space. The guard
could be a railing, a temporary cover, or
any other barrier that provides the
required protection.
Paragraph (g), which is being adopted
without substantive change from the
proposal, prohibits employees from
entering enclosed spaces that contain a
hazardous atmosphere unless the entry
conforms to the general industry permitspace standard at § 1910.146.
Accordingly, if an entry is to be made
while a hazardous atmosphere is
present in the enclosed space, the entry
must conform to the general industry
permit-required confined spaces
standard at § 1910.146.93 Once the
hazardous atmosphere is removed (for
example, by ventilating the enclosed
space), employees may enter the
enclosed space following the provisions
in § 1926.953.
The use of the term ‘‘entry’’ in this
paragraph of § 1926.953 is consistent
with the use of that term in § 1910.146,
and OSHA proposed to include the
§ 1910.146 definition of ‘‘entry’’ in
Subpart V. Two commenters objected to
the proposed definition of ‘‘entry’’ on
the basis that the definition would
93 As stated previously, the references to the
general industry standard in final § 1926.953 are
included as a placeholder pending the
promulgation of the confined spaces in construction
standard. OSHA intends to change these references
to refer to the construction standard when it
promulgates that standard.
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prevent them from hanging a tag in the
chimney of a manhole with a fault (Exs.
0157, 0227). Consolidated Edison
Company of New York (ConEd)
described their opposition to the
proposed definition of ‘‘entry’’ as
follows:
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In order to comply with § 1910.269(t)(7)(i),
Con Edison utilizes an identification system
for structures that have cable and joint
abnormalities. This system requires the
identifying crew to hang a tag (in our
nomenclature, a D-Fault tag) in the chimney
of the manhole. This red tag is a clear
indication to any other personnel who may
attempt to enter the structure that the entry
should not be made. This tagging system is
an integral part of our compliance method
and of protecting our employees. If OSHA
adds the definition as proposed, it will
prevent us from breaking the plane of the
opening and hence prevent us from hanging
the tag. This process will reduce, not increase
the safety of our employees and as such will
have the opposite effect from what OSHA is
trying to accomplish. [Ex. 0157]
EEI recommended instead that ‘‘that the
Agency grant electric utilities an
[exemption from] the definition for
[§ 1910.269](t)(7) Protection against
faults, to allow utilities to properly
comply’’ (Ex. 0227).
OSHA rejects ConEd’s
recommendation. Paragraph (g) of final
§ 1926.953 does not preclude employers
from hanging tags in the chimney of a
manhole with a fault. To the contrary,
the rule permits entry into an enclosed
space that contains a hazardous
atmosphere if entry conforms to the
general industry permit-space standard.
Moreover, if there is no hazardous
atmosphere in the space, employees
may enter when the entry conforms to
§ 1926.953. OSHA concludes that the
proposed definition is, therefore,
appropriate as it applies to final
§ 1926.953 and the corresponding
requirements in final § 1910.269(e).
OSHA also rejects EEI’s
recommendation, because it is
unnecessary. The definition of ‘‘entry,’’
as proposed and adopted, applies only
to the use of that term in final
§§ 1910.269(e) and 1926.953. The
definition does not apply to final
§ 1910.269(t)(7)(i) or § 1926.965(h)(1).
(See the summary and explanation for
final § 1926.965(h)(1) for the response to
ConEd’s and EEI’s concerns that this
provision, and its counterpart in
§ 1910.269(t)(7)(i), would preclude an
employer from hanging a tag in the
chimney of a manhole or vault to
indicate the presence of a faulted cable.)
Paragraph (h), which has been
adopted with clarifying revisions from
the proposal, requires an attendant with
first-aid training, including CPR, to be
immediately available outside the
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enclosed space to provide assistance
when a hazard exists because of traffic
patterns in the area of the opening used
for entry.94 This paragraph does not
prohibit the attendant from performing
other duties outside the enclosed space,
as long as those duties do not distract
the attendant from monitoring
employees who are in the enclosed
space (entrants) and ensuring that it is
safe to enter and exit the space. This
paragraph has two purposes: To protect
the entrant from hazards involving
traffic patterns while the entrant is
entering or exiting the space and to
provide assistance in an emergency.
Mr. Frank Brockman with Farmers
Rural Electric Cooperative Corporation
noted that attendants should never be
allowed to enter manholes or confined
spaces (Ex. 0173).
The final rule, like the proposal,
requires the attendant to remain
immediately available outside the
enclosed space during the entire entry.
If the attendant were permitted to enter
the enclosed space during entry, he or
she might not be able to assist the
entrant. For example, if traffic-pattern
hazards are present in the area of the
opening to the enclosed space and if the
attendant enters the space, then both the
attendant and the workers he or she is
protecting would be vulnerable upon
leaving the enclosed space because no
one would be present to minimize or
control the traffic-pattern hazards.
Therefore, the final rule specifies that
the attendant must remain outside the
enclosed space during the entire entry
process. It should be noted that the
rescue equipment required by paragraph
(d) will enable the entrant to rescue the
entrant from the space before
administering any necessary first aid.
Mr. Lee Marchessault of Workplace
Safety Solutions recommended that
paragraph (h) require the attendant to be
trained in CPR, in addition to first-aid
training (Ex. 0196; Tr. 575). He noted
that the electrical hazards in the space,
as well as other hazards, might present
a need for CPR (Tr. 598).
OSHA is clarifying paragraph (h) in
the final rule. The proposed rule
required training in first aid, including
CPR, so that the attendant could provide
emergency assistance in case of injury.
This is the type of training required by
§ 1926.951(b). However, the reference to
§ 1926.951(b)(1) in the proposal likely
caused Mr. Marchessault to misinterpret
94 Typically, workers direct traffic away from the
work area using traffic control devices, as required
by § 1926.967(g). When the resultant traffic patterns
(that is, the flow of traffic) could bring vehicles
close to the enclosed space entrance (for example,
when the work reduces the number of traffic lanes),
the employer must provide an attendant.
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the requirement. Therefore, the Agency
included a definition of ‘‘first-aid
training’’ in § 1926.968 in the final rule.
That definition states that first-aid
training is training in the initial care,
including cardiopulmonary
resuscitation (which includes chest
compressions, rescue breathing, and, as
appropriate, other heart and lung
resuscitation techniques), performed by
a person who is not a medical
practitioner, of a sick or injured person
until definitive medical treatment can
be administered. The definition clarifies
that, wherever first-aid training is
required by the final rule, CPR training
must be included.95 OSHA also dropped
the proposed cross-reference to
§ 1926.951(b)(1), as it is no longer
necessary.
Mr. Anthony Ahern with the Ohio
Rural Electric Cooperatives
recommended that an attendant always
be available for enclosed-space
operations, not just when traffic-pattern
hazards exist (Ex. 0186).
OSHA is not adopting this
recommendation. By definition, an
enclosed space contains a hazardous
atmosphere only under abnormal
conditions. The Agency previously
concluded that these spaces do not
present the type of atmospheric hazards
that warrant the presence of an
attendant after the employer takes
precautions such as those required by
§ 1926.953. (See, for example, 58 FR
4485–4488.) In addition, as provided in
final § 1926.953(a), when a hazardous
atmosphere is present after the
employer takes the precautions required
by this section, paragraphs (d) through
(k) of OSHA’s general industry permitspace standard, § 1910.146, which do
require attendants, apply. Therefore, the
Agency concluded that, when paragraph
(h) applies, the only hazards (other than
electrical) that necessitate the presence
of an attendant while work is being
performed in an enclosed space are
traffic-pattern hazards in the area of the
opening used for entering and exiting
the enclosed space. OSHA notes that
even if no traffic-pattern hazards are
present, an attendant is required under
§ 1926.965(d) of the final rule while
work is being performed in a manhole
or vault containing energized electric
equipment. A note to this effect follows
final § 1926.953(h).
Mr. Leo Muckerheide with Safety
Consulting Services commented that the
purpose of proposed paragraph (h) was
confusing because the purpose of the
requirement as stated in the first
95 The definition also clarifies that CPR training
includes resuscitation techniques both for the heart
and for the lungs.
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sentence—that is, protecting entrants
from traffic-pattern hazards—differs
from the attendant’s duties as noted in
the second sentence—monitoring
employees within the space. He
recommended that OSHA revise the
second sentence of that paragraph as
follows:
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That person is not precluded from
performing other duties outside the enclosed
space if these duties do not distract the
attendant from monitoring the traffic patterns
outside the enclosed space. [Ex. 0180]
OSHA rejects Mr. Muckerheide’s
recommended language. Part of the
attendant’s duty to monitor employees
in the space is to warn entrants
preparing to exit an enclosed space
about hazards involving traffic patterns.
If the attendant is watching traffic
patterns instead of monitoring the
entrant, the entrant might not receive
warnings about that traffic before exiting
the space. When the entrant is ready to
exit the space, the attendant can then
monitor or direct traffic and let the
entrant know when it is safe to exit the
space. On the other hand, OSHA agrees
with Mr. Muckerheide that the duties of
the attendant may not be clear from the
language of the provision as proposed.
Therefore, OSHA revised the language
in final paragraph (h) to make it clear
that ensuring that it is safe to enter and
exit an enclosed space is part of the
attendant’s duties.
Paragraph (i), which is being adopted
without change from the proposal,
requires that test instruments used to
monitor atmospheres in enclosed spaces
have a minimum accuracy of ±10
percent and be kept in calibration. This
provision will ensure that test
measurements are accurate so that
hazardous conditions will be detected
when they arise. The accuracy of
instruments used for testing the
atmosphere of these spaces is important
for employee safety, and calibration is
critical to test-instrument accuracy. As
noted in the preamble to the proposal
and to the 1994 § 1910.269 final rule,
OSHA considers ±10 percent to be the
minimum accuracy needed to detect
hazardous conditions reliably (70 FR
34849, 59 FR 4369).
Two commenters objected to the
proposed requirements (Exs. 0128,
0227). EEI recommended that the
standard only require ‘‘that test
instruments be kept in calibration using
the recommendations set forth by the
specific manufacturer’’ and not address
accuracy (Ex. 0227). Mr. Mark Spence of
Dow Chemical Company argued that
OSHA did not demonstrate that the
provision was necessary or that
calibration has been a problem (Ex.
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0128). He stated that the general
industry permit-space standard did not
contain such a requirement, but only
requires that the atmospheres in spaces
be monitored (id.).
OSHA rejects the recommendations
from these two commenters. Mr. Spence
is incorrect. The permit-space standard
requires test equipment to be calibrated.
As mentioned previously,
§ 1910.146(c)(5) contains requirements
for alternative procedures for permit
spaces that are analogous to the
enclosed-space requirements contained
in § 1926.953 of the final rule. Paragraph
(c)(5)(ii)(C) of § 1910.146 requires
atmospheric testing using a calibrated
test instrument. Paragraph (d) of
§ 1910.146, which contains
requirements for permit-required
confined-space programs, specifies, at
paragraph (d)(4)(i), that employers
maintain ‘‘[t]esting and monitoring
equipment needed to comply with
paragraph (d)(5).’’ As OSHA concluded
in the preamble to the general industry
permit-space final rule, if test
equipment ‘‘is properly selected,
calibrated, and maintained . . ., the
testing and monitoring needs for entry
and work in permit-required confined
spaces can be effectively met’’ (58 FR
4498). Thus, the use of inaccurate or
uncalibrated test instruments does not
meet the permit-space standard.
OSHA rejects EEI’s recommendation
that the standard not address accuracy.
The Agency concluded in the 1994
§ 1910.269 rulemaking that the
requirement for test instruments to be
accurate within ±10 percent was
reasonably necessary for the protection
of employees (59 FR 4369). OSHA
continues to believe that the accuracy of
instruments used for testing the
atmosphere of these spaces is important,
and EEI offered no evidence to the
contrary.
OSHA also rejects EEI’s assertion that
equipment calibrated to manufacturers’
specification is an adequate substitute
for test equipment accuracy. Calibration
and accuracy are not synonymous. A
calibrated test instrument is one that has
been compared to a standard reference
source for the substance (oxygen, or a
toxic or flammable gas) to be measured.
Accuracy is a measure of the precision
with which the substance can be
measured. An oxygen meter, for
example, with an accuracy of ±20
percent could give a reading as much as
20 percent above or below the actual
oxygen content even when it is properly
calibrated. It is evident that this
calibrated instrument would not meet
the final rule’s minimum accuracy
requirement of ±10 percent.
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Several commenters recommended
that OSHA include in the final rule
specific requirements on how to keep
instruments calibrated. (See, for
example, Exs. 0196, 0211, 0227.) For
instance, ISEA recommended that
OSHA refer employers and employees
to the Agency’s Safety and Health
Information Bulletin ‘‘Verification of
Calibration for Direct-Reading Portable
Gas Monitors’’ (SHIB 05–04–2004) for
information on this topic (Ex. 0211).96
As noted earlier, EEI recommended that
test instruments be calibrated in
accordance with manufacturers’
instructions (Ex. 0227). Another
commenter, Mr. Lee Marchessault with
Workplace Safety Solutions agreed that
the standard should require calibration
in accordance with manufacturers’
instructions because test instruments
‘‘may go out of calibration 2 hours after
being calibrated’’ (Ex. 0196).
OSHA is not adopting these
recommendations. The Agency decided
to adopt a performance-based approach
for this requirement to provide
compliance flexibility. OSHA considers
a test instrument to be ‘‘kept in
calibration,’’ as required by paragraph
(i), when the employer follows the
manufacturers’ calibration instructions
or other reasonable guidelines for the
calibration of the instrument involved.
The Agency anticipates that most
employers will follow manufacturers’
instructions. However, these
instructions might not be available if the
manufacturer has gone out of business.
In addition, there are other sources of
information on proper calibration
methods. As mentioned earlier, ISEA
noted one appropriate source of
information that can be used instead,
although the Agency decided against
including a reference to that publication
in the final rule.
Mr. Kevin Taylor with the Lyondell
Chemical Company asked for
clarification of the requirement that test
instruments have a minimum accuracy
of ±10 percent (Ex. 0218). He inquired
whether that level of accuracy was
needed for each measured gas or
whether the accuracy measurement was
based on total detection of gases.
OSHA clarifies that the accuracy
required by the final rule pertains to
each gas being measured. Moreover, the
accuracy of the instrument must be
determined based on the threshold
quantities that would make the
atmosphere within the space hazardous
(as per the definition of ‘‘hazardous
atmosphere’’ in § 1926.968). For
96 This document is available on the OSHA Web
site at: https://www.osha.gov/dts/shib/
shib050404.pdf.
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example, a particular enclosed space
could potentially contain hazardous
levels of methane, carbon dioxide, and
carbon monoxide, as well as insufficient
levels of oxygen. The instrument or
instruments used to test the space in
this example must be accurate to within
±10 percent of: (1) A 0.5-percent
concentration of methane (which is 10
percent of its lower flammable limit),97
(2) the permissible exposure limits
(PELs) contained in Subpart D for both
carbon dioxide and carbon monoxide
(9,000 and 55 mg/m3, respectively), and
(3) atmospheric concentrations of
oxygen at 19.5 percent. It is important
for the test instrument to be accurate
near the threshold because those are the
critical values for determining whether
or not a space is hazardous.
As noted earlier, because of the lack
of adequate ventilation, enclosed spaces
can accumulate hazardous
concentrations of flammable gases and
vapors, or an oxygen deficient
atmosphere could develop. It is
important to keep concentrations of
oxygen and flammable gases and vapors
at safe levels; otherwise, an explosion
could occur while employees are in the
space, or an oxygen deficiency could
lead to suffocation of an employee.
Toward these ends, paragraphs (j)
through (o) of the final rule address the
testing of the atmosphere in the space
and ventilation of the space. OSHA
notes that the specific testing
requirements in paragraphs (j), (k), and
(o) must be met irrespective of the
results of the employer’s evaluation
performed under paragraph (e). The
evaluation performed under paragraph
(e) serves only to ensure that it is safe
to remove the cover and will not
determine whether an enclosed space
contains a hazardous atmosphere. The
testing required by paragraphs (j), (k),
and (o) will ensure, as required by
paragraph (g), that employees not enter
an enclosed space while it contains a
hazardous atmosphere unless they
follow the requirements of the general
industry permit-space standard.
Paragraph (j), which is being adopted
without substantive change from the
proposal, requires that, before an
employee enters an enclosed space, the
atmosphere in the space be tested for
oxygen deficiency and that the testing
be done with a direct-reading meter or
similar instrument capable of collecting
and immediately analyzing data
samples without the need for off-site
evaluation. Continuous forced airventilation is permitted as an alternative
to testing. However, procedures for such
97 The lower flammable limit for methane is 5
percent, and 10 percent of that value is 0.5 percent.
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ventilation must ensure that employees
are not exposed to the hazards posed by
oxygen deficiency.98 (See also
paragraph (m) for additional
requirements relating to ventilation of
the space.)
Paragraph (k), which is being adopted
without change from the proposal,
requires that, before employees enter an
enclosed space, the internal atmosphere
of the space be tested for flammable
gases and vapors. If the results of the
test indicate the presence of a hazardous
atmosphere, employees may not enter
under the procedures specified by
§ 1926.953. (See § 1926.953(g).) So that
the results are accurate and relevant to
the atmosphere in the space at the time
of employee entry, testing must be
performed with a direct-reading meter,
or similar instrument, capable of
collecting and immediately analyzing
data samples without the need for offsite evaluation. The flammability test
required by this paragraph must be
performed after oxygen testing and
ventilation required by paragraph (j)
demonstrate that the enclosed space has
sufficient oxygen for an accurate
flammability test.
If flammable gases or vapors are
detected or if an oxygen deficiency is
found, paragraph (l), which is being
adopted without substantive change
from the proposal, requires the
employer to provide forced-air
ventilation to maintain safe levels of
oxygen and to prevent a hazardous
concentration of flammable gases or
vapors from accumulating. As an
alternative to ventilation, an employer
may use a continuous monitoring
system that ensures that no hazardous
atmosphere develops and no increase in
flammable gas or vapor concentrations
above safe levels occur if flammable
gases or vapors are detected at safe
levels. The language in the final rule
clarifies that the monitoring must
ensure that concentrations of flammable
gases and vapors do not increase above
safe levels (as opposed to not increasing
at all). The definition of hazardous
atmosphere contains guidelines for
determining whether the concentration
of a substance is at a hazardous level.
OSHA is including a note to this effect
after paragraph (l). An identical note
appears after paragraph (o). OSHA
changed the title of this paragraph in the
final rule to ‘‘Ventilation, and
monitoring for flammable gases or
98 The definition of ‘‘hazardous atmosphere’’
determines what concentrations of oxygen are
considered hazardous. (See § 1926.968.) Paragraph
(g) of final § 1926.953 prohibits entry into an
enclosed space while a hazardous atmosphere is
present.
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vapors’’ to accurately reflect the
contents of the paragraph.
Paragraph (m), which is being
adopted without substantive change
from the proposal, contains specific
requirements for the ventilation of
enclosed spaces. When forced-air
ventilation is used, it must begin before
entry is made and must be maintained
long enough for the employer to be able
to demonstrate that a safe atmosphere
exists before employees are allowed to
enter the space. To accomplish this, the
ventilation must be maintained long
enough to purge the atmosphere within
the space of hazardous levels of
flammable gases and vapors and to
supply an adequate concentration of
oxygen.
OSHA decided not to specify a
minimum number of air changes before
employee entry into the enclosed space
is permitted. Instead, the Agency places
the burden on the employer to ensure
that the atmosphere is safe before such
entry. The employer can discharge this
duty either by testing to determine the
safety of the atmosphere in the space or
by a thorough evaluation of the air flow
required to make the atmosphere safe. In
this way, the safety of employees
working in enclosed spaces will not be
dependent on speculation by a
supervisor or an employee.99
Paragraph (m) also requires the air
provided by the ventilating equipment
to be directed at the immediate area
within the enclosed space where
employees are at work. The forced-air
ventilation must be maintained the
entire time the employees are present
within the space. These provisions
ensure that a hazardous atmosphere
does not reoccur where employees are
working.
NIOSH recommended that ‘‘the
atmosphere in a confined space be
tested before entry and monitored
continuously while workers are in the
confined space to determine if the
atmosphere has changed due to the
work being performed’’ (Ex. 0130).
NIOSH identified its publication
‘‘Worker Deaths in Confined Spaces: A
Summary of NIOSH Surveillance and
Investigative Findings,’’ Publication No.
94–103, as evidence of the need for
continuous monitoring (id.).
As explained earlier in this section of
the preamble, the final rule requires the
atmosphere in enclosed spaces to be
tested before entry. OSHA concludes,
however, that continuous monitoring of
enclosed spaces is unnecessary. By
99 This discussion, which also appeared in the
preamble to the proposal, responds to one
commenter’s request for clarification of how the
employer could demonstrate that the atmosphere in
the enclosed space is safe (Ex. 0186).
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Federal Register / Vol. 79, No. 70 / Friday, April 11, 2014 / Rules and Regulations
definition, enclosed spaces contain a
hazardous atmosphere only under
abnormal conditions. Thus, enclosed
spaces almost never contain the types of
conditions that will cause a hazardous
atmosphere to reoccur after employers
implement the precautions required by
§ 1926.953 (such as forced-air
ventilation). If these precautions are not
sufficient to keep the atmosphere in the
space safe, then the space would not
qualify for entry under § 1926.953, and
entry could only proceed under the
general industry permit-required
confined space standard, as specified by
paragraph (a) of that section. Therefore,
OSHA has not adopted NIOSH’s
recommendation in the final rule.
Two commenters noted that proposed
paragraph (m) might be impossible to
implement under certain conditions and
recommended that the final rule
recognize these conditions (Exs. 0128,
0224). One of these commenters, Dow
Chemical Company, noted that it is not
always possible to test atmospheric
conditions before entry into an enclosed
space (Ex. 0128). The other commenter,
the Alabama Rural Electric Association
of Cooperatives, maintained that it was
not always feasible to use forced-air
ventilation because of space constraints
(Ex. 0224).
OSHA concludes that no changes to
paragraph (m) are necessary. The final
rule, as with the proposal, recognizes
that the enclosed-space procedures
might not adequately protect employees
in some circumstances. Paragraph (a) of
the final rule requires that employers
follow the general industry permit-space
standard at § 1910.146 whenever the
precautions required by final
§§ 1926.953 and 1926.965 are
insufficient to adequately control the
hazards posed by the space. These
conditions include any conditions that
make complying with those two
sections in this final rule infeasible.
Therefore, OSHA is including paragraph
(m) in the final rule as proposed.
To ensure that the air supplied by the
ventilating equipment provides a safe
atmosphere, paragraph (n), which is
being adopted without substantive
change from the proposal, requires the
air supply to be from a clean source and
prohibits it from increasing the hazards
in the enclosed space. For example, the
final rule prohibits positioning the air
intake for ventilating equipment near
the exhaust from a gasoline or diesel
engine because doing so would
contaminate the atmosphere in the
enclosed space.
The use of open flames in enclosed
spaces is safe only when flammable
gases or vapors are not present in
hazardous quantities. For this reason,
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final paragraph (o), which is being
adopted without change from the
proposal, requires additional testing for
flammable gases and vapors if open
flames are to be used in enclosed
spaces. The tests must be performed
immediately before the open-flame
device is used and at least once per hour
while the device is in use. More
frequent testing is required if conditions
indicate the need for it. Examples of
such conditions include the presence of
volatile flammable liquids in the
enclosed space and a history of
hazardous quantities of flammable
vapors or gases in such a space.
20381
5. Section 1926.954, Personal protective
equipment
Final § 1926.954 contains
requirements for personal protective
equipment (PPE). Paragraph (a), which
is being adopted without change from
the proposal, clarifies that PPE used by
employees during work covered by
Subpart V must meet Subpart E of Part
1926.
Mr. Daniel Shipp with ISEA
recommended that OSHA update the
national consensus standards
incorporated by reference in Subpart E
(Ex. 0211). He pointed out, for example,
that § 1926.100, which covers head
protection, incorporates two outdated
ANSI standards, namely ANSI Z89.1–
1969, Safety Requirements for Industrial
Head Protection, and ANSI Z89.2–1971,
Industrial Protective Helmets for
Electrical Workers (id.).
Updating the national consensus
standards incorporated by reference in
Subpart E is beyond the scope of this
rulemaking, so OSHA is not adopting
Mr. Shipp’s recommendation in this
final rule. However, on June 22, 2012,
OSHA published a direct final rule
updating its head protection standard in
Subpart E (77 FR 37587–37600).100 On
November 16, 2012, OSHA published a
notice confirming the effective date of
the direct final rule (77 FR 68684;
effective date—September 20, 2012).
That rulemaking action updates the
national consensus standard for head
protection incorporated in Subpart E of
the construction standards as
recommended by Mr. Shipp.
The preamble to the proposal noted
that OSHA had separately proposed
regulatory language for the general PPE
standards to clarify that employers are
generally responsible for the cost of PPE
(70 FR 34868–34869; 64 FR 15402, Mar.
31, 1999). OSHA published the final
rule on employer payment for PPE on
November 15, 2007 (72 FR 64342). The
final rule on employer payment for PPE
requires employers to pay for the PPE
used to comply with OSHA standards,
with a few exceptions. The exceptions
include: (1) Everyday clothing, such as
longsleeve shirts, long pants, street
shoes, and normal work boots; and (2)
ordinary clothing, skin creams, or other
items, used solely for protection from
weather, such as winter coats, jackets,
gloves, parkas, rubber boots, hats,
raincoats, ordinary sunglasses, and
sunscreen. (See §§ 1910.132(h) and
1926.95(d).)
Employers must pay for fall
protection equipment and other PPE
used by employees in compliance with
this final rule to the extent required by
§ 1926.95(d), the general construction
rule regarding payment for PPE, or
§ 1910.132(h), the general rule regarding
payment for PPE in general industry.
(See 72 FR 64369 (explaining that the
general PPE-payment provisions ‘‘apply
to all OSHA standards requiring PPE’’);
see also the March 16, 2009, letter of
interpretation to Mr. William
Mattiford 101 (employers must pay for
body belts, positioning straps, and poleand tree-climbing equipment in
accordance with § 1910.132(h)) and the
May 1, 2008, letter to Mr. Gil
Niedenthal 102 (employers must pay for
body belts and pole climbers in
accordance with § 1910.132(h)).)
OSHA included a note to final
§ 1926.954(a) to indicate that
§ 1926.95(d) sets employer payment
obligations for the PPE required by
subpart V, including, but not limited to,
the fall protection equipment required
by final § 1926.954(b), the electrical
protective equipment required by final
§ 1926.960(c), and the flame-resistant
and arc-rated clothing and other
protective equipment required by final
§ 1926.960(g). (See the summary and
explanation for § 1926.960(g), later in
this section of the preamble, for a
discussion of the issue of employer
payment for flame-resistant and arcrated clothing.)
Paragraph (b) of the final rule sets
requirements for personal fall protection
systems. Subpart M of part 1926, which
sets requirements for fall protection for
100 OSHA also updated its consensus standards
for general industry and maritime on September 9,
2009 (74 FR 46350). The Agency again updated the
general industry and maritime standards with the
June 22, 2012, direct final rule because OSHA
published the proposal for the 2009 final rule before
ANSI updated its head-protection standard that
year.
101 The letter of interpretation to Mr. Mattiford is
available at https://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_table=
INTERPRETATIONS&p_id=27014.
102 The letter of interpretation to Mr. Niedenthal
is available at https://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_table=
INTERPRETATIONS&p_id=27091.
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Federal Register / Vol. 79, No. 70 / Friday, April 11, 2014 / Rules and Regulations
construction, contains provisions
covering two types of personal fall
protection systems: Personal fall arrest
systems, addressed in § 1926.502(d),
and positioning device systems,
addressed in § 1926.502(e). Subpart M
defines a ‘‘personal fall arrest system’’
as a system used to arrest an employee
in a fall from a working level. It consists
of an anchorage, connectors, and body
harness and may include a lanyard,
deceleration device, lifeline, or suitable
combinations of these. (See
§ 1926.500(b).) Personal fall arrest
systems are designed to safely arrest the
fall of an employee working on a
horizontal or vertical surface.
Subpart M defines a ‘‘positioning
device system’’ as a body belt or body
harness system rigged to allow an
employee to be supported on an
elevated vertical surface, such as a wall,
and work with both hands free while
leaning. (See § 1926.500(b).)
Positioning device systems are
designed to support an employee
working on a vertical surface so that the
employee can work with both hands
without falling. Proposed Subpart V
contained requirements for ‘‘work
positioning equipment,’’ which is
equivalent to ‘‘positioning device
system’’ as that term is defined in
subpart M. (See the summary and
explanation for final § 1926.954(b)(2),
later in this section of the preamble.)
A third form of personal fall
protection system, which is not
specifically addressed in Subpart M, is
a tethering, restraint, or travel-restricting
system. OSHA’s steel erection standard
in Subpart R of Part 1926 contains
requirements for ‘‘fall restraint
systems,’’ which it defines as a fall
protection system that prevents the user
from falling any distance. The system
consists of either a body belt or body
harness, along with an anchorage,
connectors and other necessary
equipment. The other components
typically include a lanyard, and may
also include a lifeline and other devices.
(See § 1926.751.103)
Fall restraint, tethering, and travelrestricting equipment are all designed to
prevent employees from falling, in some
cases by restraining an employee’s
access to unprotected edges (restraint,
tethering, and travel-restricting
equipment) and in other cases by
holding the employee in place to
prevent falling (restraint equipment).
IBEW recommended that the fall
protection provisions in proposed
103 The term ‘‘fall restraint system’’ as defined in
§ 1926.751 is a broad term that includes travelrestricting equipment, tethering systems, and other
systems that prevent an employee from falling any
distance.
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paragraph (b), and in its general
industry counterpart, proposed
§ 1910.269(g)(2), contain a reference to
IEEE Std 1307, Standard for Fall
Protection for Utility Work (Ex. 0230; Tr.
904–905, 983–984). The union noted
that this is the only consensus standard
addressing specific fall protection issues
for the utility industry (Ex. 0230).
OSHA agrees that this consensus
standard provides useful information to
help employers comply with some
provisions of the final rule and added
the IEEE standard to the list of reference
documents in Appendix G to subpart V
and Appendix G to § 1910.269.104 The
Agency is not, however, referencing
IEEE Std 1307 in § 1926.954 of the final
rule. OSHA made substantial changes to
the fall protection requirements in the
final rule, and the IEEE standard does
not reflect all of the final rule’s
requirements. For example, on and after
April 1, 2015, final
§ 1926.954(b)(3)(iii)(C) generally does
not permit qualified employees to climb
poles, towers, or similar structures
without fall protection. (See the
summary and explanation for final
§ 1926.954(b)(3)(iii), later in this section
of the preamble.) In contrast, section
6.2.1 of IEEE Std 1307–2004 permits
qualified climbers to climb poles,
towers, and similar structures without
fall protection (Ex. 0427).105
Proposed paragraph (b)(1) provided
that personal fall arrest systems had to
meet the requirements of Subpart M of
Part 1926. Existing § 1910.269(g)(2)(i)
already contains a similar requirement.
A note following proposed paragraph
(b)(1) indicated that this provision
would apply to all personal fall arrest
systems used in work covered by
subpart V. OSHA is not including this
note in the final rule as it is
unnecessary.
OSHA received a number of
comments about proposed paragraph
(b)(1). (See, for example, Exs. 0128,
0180, 0211, 0219, 0227, 0230.) Some of
these comments generally supported the
proposal, noting that there are no
situations in which work covered by
Subpart V would necessitate different
requirements for fall arrest equipment
than those already found in Subpart M.
(See, for example, Exs. 0219, 0227,
0230.) Mr. Mark Spence with Dow
104 See the discussion of the appendices to the
final rule, later in this section of the preamble. As
explained in the appendices, the referenced
national consensus standards, including IEEE Std
1307, contain detailed specifications that employers
may follow in complying with the more
performance-oriented requirements of OSHA’s final
rule. However, compliance with IEEE Std 1307 is
not a substitute for compliance with § 1926.954(b).
105 IEEE Std 1307–2004 is the most recent edition
of that consensus standard.
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Chemical Company supported the
incorporation of subpart M in both
subpart V and § 1910.269, but noted
OSHA’s plan to revise the general
industry fall protection standard. He
recommended that § 1910.269 and
subpart V eventually be revised to refer
to the updated general industry fall
protection provisions:
The existing general industry standard
[§ 1910.269] requires personal fall arrest
equipment to meet the requirements of the
construction industry fall protection
standards, 29 CFR Part 1926, Subpart M.
Both § 1910.269 and Subpart M were
promulgated in 1994, whereas the general
industry fall protection standards date back
to 1971 (and are based on earlier
requirements). To take advantage of the
updated fall protection requirements in the
construction standards, OSHA chose to make
them applicable to work under this general
industry standard. [Footnote omitted.]
*
*
*
*
*
Dow sees no current option for OSHA
other than continuing to refer to Subpart M,
supplementing it as appropriate with new
provisions, as OSHA has done here.
However, Dow urges OSHA to proceed
expeditiously with the issuance of . . . new
general industry fall protection . . .
standards. Once . . . new [general industry
fall protection standards are] published as a
final rule, OSHA should revise both [Subpart
V and § 1910.269] to refer to the new
[provisions]. [Ex. 0126]
On May 24, 2010, OSHA proposed to
revise the general industry walkingworking surfaces standards and the
personal protective equipment
standards (75 FR 28862). The proposal
included a new standard for personal
fall protection systems, § 1910.140,
which would increase consistency
between construction, maritime, and
general industry standards. When that
rulemaking is finalized, OSHA will
consider whether the cross-references in
subpart V and § 1910.269 should be
changed as recommended by Mr.
Spence.
Two commenters noted that subpart
M does not address arc-flash resistance
for fall arrest equipment and
recommended that OSHA require this
equipment to pass arc-flash tests (Exs.
0180, 0211). Mr. Daniel Shipp of ISEA
supported arc-flash testing as follows:
We believe that workers in electric power
transmission and distribution have special
requirements different from those in general
construction activities. These special
requirements are recognized as hazards
associated with exposure to high-voltage
electric current. The hazard of exposure to
energized electrical sources often occurs at
height[s] where personal fall arrest systems
are required. The hazard of electric arc flash
has been addressed in the ASTM F887–04
[Standard Specifications for Personal
Climbing Equipment] for full body harnesses
used in fall arrest.
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We support the inclusion of electric arcflash resistance requirements, referenced in
ASTM F887–04, to be extended to [include]
fall arrest PPE, especially full body harnesses
and shock absorbing lanyards that are worn
together as part of a complete fall arrest
system. These components would be exposed
to potentially damaging thermal shock in the
event of an arc flash. The damage to lanyards
not designed to withstand a high-voltage arc
flash can be quite severe, reducing strength
to levels below the factor of safety necessary
to assure arrest of a fall. Tests have been
performed by the Kinetrics high energy
laboratory on high-tensile webbing, such as
that used in fall protection PPE products.
Testing at exposure levels of 40 cal/cm2, in
accordance with the procedures in ASTM
F1958/F1958M–99 [Standard Test Method
for Determining the Ignitability of Non-flameResistance Materials for Clothing by Electric
Arc Exposure Method Using Mannequins],
demonstrated ignition and melting of the
webbing sufficient to reduce webbing
strength by greater than 30 percent.
One common example of this hazard
involves employees tied off in bucket trucks
working in close proximity to high-voltage
power lines. The fall arrest harness and
lanyard are typically exposed above the edge
of the bucket where contact with electric arc
flash is possible. In the event of an incident,
including a fall by ejection out of the bucket,
the strength of fall arrest components could
be severely compromised if they were
exposed to a high-voltage electric arc flash.
[Ex. 0211]
Mr. Leo Muckerheide of Safety
Consulting Services similarly
recommended that harnesses and
lanyards used by employees working on
or near energized circuits meet ASTM
F887–04, because that consensus
standard provides performance criteria
for arc resistance (Ex. 0180).
OSHA recognizes that employees
performing work covered by subpart V
and § 1910.269 are sometimes exposed
to hazards posed by electric arcs. In fact,
final §§ 1910.269(l)(8) and 1926.960(g)
are designed to protect employees from
electric arcs. In addition, the Agency
already recognized the need for workpositioning equipment to be capable of
passing a flammability test to ensure
that the equipment does not fail if an
electric arc occurs. (See final
§§ 1910.269(g)(2)(iii)(G)(5) and
1926.954(b)(2)(vii)(E).) On the other
hand, in work covered by subpart V or
§ 1910.269, personal fall arrest
equipment has broader application than
work-positioning equipment, with
work-positioning equipment being used
primarily on support structures for
overhead power lines. Several
applications for personal fall arrest
equipment involve work that does not
pose electric-arc hazards, especially in
electric power generation work covered
by § 1910.269. For example, an
employee working on a cooling tower or
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atop a dam at an electric power
generation plant would not normally be
exposed to these hazards. Consequently,
OSHA decided not to include a general
requirement for all fall arrest equipment
used under the final rule to be capable
of passing an electric-arc test.
However, OSHA agrees that electric
arcs can damage personal fall arrest
equipment as readily as workpositioning equipment. The testing to
which the commenters referred, and
which is the basis of the test data found
in the record, demonstrates that
harnesses subjected to an electric arc
can fail a drop test (Ex. 0432). The
Agency concludes from these test data
that personal fall arrest equipment worn
by an employee who is exposed to an
electric arc could fail if it is not
designed to withstand the heat energy
involved. OSHA also agrees with the
commenters that employees working on
or near energized circuits are exposed to
electric arcs when the circuit parts are
exposed (Ex. 0180). Accordingly, OSHA
adopted a requirement in the final rule
that fall arrest equipment used by
employees exposed to hazards from
flames or electric arcs be capable of
passing a drop test after exposure to an
electric arc 106 with a heat energy of
40±5 cal/cm2. This requirement matches
the electric arc performance required of
fall arrest equipment by ASTM F887–04
(Ex. 0055). The provision appears in
final paragraph (b)(1)(ii).
Paragraph (g)(1) of § 1926.960 in the
final rule requires employers to identify
employees exposed to the hazards of
flames or electric arcs. When these
employees are using personal fall arrest
equipment, that equipment also would
be exposed to flame or electric-arc
hazards, and the final rule requires this
fall arrest equipment to be capable of
passing a drop test equivalent to the test
specified in paragraph (b)(2)(xii)
(discussed later in this section of the
preamble) after exposure to an electric
arc with a heat energy of 40±5 cal/cm2.
Harnesses and shock-absorbing lanyards
meeting ASTM F887–12e1 107 will be
deemed to comply with this provision.
OSHA received a substantial number
of comments addressing fall protection
106 The electric arc test required by this paragraph
is a test exposing the equipment to an electric arc
with a specified incident heat energy. ASTM F887–
12e1 includes an electric-arc test method that
involves positioning the fall arrest equipment in
front of two vertically mounted electrodes. The
electric arc forms between the electrodes.
107 The final rule is based on the edition of the
consensus standard that is in the record, ASTM
F887–04, Standard Specifications for Personal
Climbing Equipment (Ex. 0055). OSHA reviewed
the most recent edition of this standard, ASTM
F887–12e1, and found that equipment meeting that
standard will also comply with final
§ 1926.954(b)(1)(ii).
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20383
requirements for employees working in
aerial lifts. Existing fall protection
requirements to protect employees in
aerial lifts performing work, including
line-clearance tree-trimming work,
covered by Subpart V or § 1910.269 are
found in several standards. In
construction, the construction aerial lift
standard (§ 1926.453) and subpart M
apply. For maintenance and operation
work, the general industry aerial lift
standard (§ 1910.67) and existing
§ 1910.269(g)(2) (incorporating subpart
M of the construction standards) apply.
Currently, line-clearance tree-trimming
work is typically governed by the fall
protection requirements in § 1910.269
and, depending on the type of work
performed, falls under either the general
industry or construction aerial lift
standard.
Paragraph (b)(2)(v) of § 1926.453 in
the construction standard for aerial lifts
requires an employee working from an
aerial lift to wear a body belt with a
lanyard attached to the boom or basket.
However, the introductory text to
§ 1926.502(d) in subpart M provides that
‘‘body belts are not acceptable as part of
a personal fall arrest system.’’ The
hazards of using a body belt as part of
a fall arrest system are described in the
preamble to the Subpart M final rule (59
FR 40672, 40702–40703, Aug. 9, 1994)
and later in this section of the preamble.
In short, since the fall-arrest forces are
more concentrated for a body belt
compared to a body harness, the risk of
injury in a fall is much greater with a
body belt. In addition, an employee can
fall out of a body belt in a fall. Lastly,
an employee faces an unacceptable risk
of further injury while suspended in a
body belt awaiting rescue.
Given the potential discrepancy
between the aerial lift standard’s
requirement for body belts and the
subpart M limitation on the use of body
belts in fall arrest systems, a note
following § 1926.453(b)(2)(v) explains
that § 1926.502(d) provides that body
belts are not acceptable as part of a
personal fall arrest system. The use of a
body belt in a tethering system or in a
restraint system is acceptable and is
regulated under § 1926.502(e).
Like the aerial lift standard in
construction, the general industry aerial
lift standard at § 1910.67(c)(2)(v)
requires an employee working from an
aerial lift to wear a body belt with a
lanyard attached to the boom or basket.
Even though existing § 1910.269(g)(2)(i)
requires fall arrest equipment to meet
subpart M of part 1926, which prohibits
the use of body belts in personal fall
arrest systems, the Agency previously
decided that employers could use body
belts and lanyards configured as fall
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arrest systems to protect employees
doing work covered by § 1910.269 in
aerial lifts.
OSHA explained in the preamble to
the proposal that this rulemaking would
prohibit the use of body belts in
personal fall arrest systems for all work
covered by § 1910.269 and subpart V,
including work done from aerial lifts (70
FR 34850). The tree trimming industry
criticized OSHA’s proposed application
of the Subpart M prohibition on body
belts in personal fall arrest systems on
the basis that it left line-clearance tree
trimming employers with two (in the
industry’s view, undesirable) options—
providing either (1) a personal fall arrest
system with a body harness, or (2) a
positioning system that, under proposed
§ 1926.954(b)(3)(iv) (or proposed
§ 1910.269(g)(2)(iii)(D)), is rigged to
prevent free falls of more than 0.6
meters (2 feet). (See, for example, Exs.
0174, 0200, 0502, 0503; Tr. 611–619,
756–760.)
The tree trimming industry is
mistaken about the compliance options
available to its employers. The 0.6-meter
free-fall limit applies only to workpositioning equipment, which may not
be used in aerial lifts. As noted
previously, under § 1926.500(b) of
subpart M, ‘‘positioning device system’’
is defined as ‘‘a body belt or body
harness system rigged to allow an
employee to be supported on an
elevated vertical surface, such as a wall,
and work with both hands free while
leaning.’’ Positioning device systems are
not permitted to be used from a
horizontal surface, such as the platform
or bucket of an aerial lift.108
Although employees in aerial lifts
cannot use work-positioning equipment,
they can use restraint systems. As noted
previously, a restraint system is a
method of fall protection that prevents
the worker from falling, for example, by
preventing the employee from reaching
an unprotected edge. Body belts are
permissible in restraint systems. If an
employer has an employee use a fall
restraint system, it must ensure that the
lanyard and anchor are arranged so that
the employee is not exposed to falling
108 See, for example, the following OSHA letters
of interpretation:
May 11, 2001, to Mr. Jessie L. Simmons (https://
www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=24360);
August 14, 2000, to Mr. Charles E. Hill (https://
www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=24110); and
April 20, 1998, to Mr. Jonathan Hemenway
Glazier (https://www.osha.gov/pls/oshaweb/
owadisp.show_document?p_
table=INTERPRETATIONS&p_id=22569).
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any distance.109 In addition, for a
restraint system to work, the anchorage
must be strong enough to prevent the
worker from moving past the point
where the system is fully extended,
including an appropriate safety factor.
In a November 2, 1995, letter of
interpretation to Mr. Dennis Gilmore,
OSHA suggested that, at a minimum, a
fall restraint system have the capacity to
withstand at least 13.3 kilonewtons
(3,000 pounds) or twice the maximum
expected force that is needed to restrain
the employee from exposure to the fall
hazard.110 The Agency recommended
that, in determining this force,
employers should consider site-specific
factors such as the force generated by an
employee (including his or her tools,
equipment and materials) walking,
slipping, tripping, leaning, or sliding
along the work surface.111 With respect
to work in aerial lifts, to the extent that
the bucket or platform can become
separated from the boom as noted by
several commenters (see, for example,
Tr. 614–615, 700), the restraint system
would need to be anchored to the boom.
The proposed rule gave line-clearance
tree trimming employers two options for
employees in aerial lifts: (1) Use a
personal fall arrest system with a
harness; or (2) use a fall restraint system
with a body belt or a harness. With
respect to the first option, the tree
trimming industry argued that personal
fall arrest systems with body harnesses
pose two hazards unique to lineclearance tree trimmers: (1) An
electrocution hazard in the event of a
fall into a power line and (2) a hazard
associated with a harness’ being pulled
into a chipper. (See, for example, Exs.
0174, 0200, 0502, 0503; Tr. 616–617,
757–758.) Testifying on behalf of ULCC,
Mr. Andrew Salvadore explained these
arguments as follows:
It is to be noted that this full body harness
as one of the options is potentially
problematic though for line clearance tree
trimmers. [D]ue to the unique way that line
clearance tree trimmers work, this is for two
reasons.
Reason 1: Linemen work next to energized
conductors at arm’s height. So if they fall
109 See, for example, the August 14, 2000, letter
of interpretation to Mr. Charles E. Hill (https://
www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=24110).
110 This letter of interpretation is available at
(https://osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=22006.
111 See also the following letters of interpretation:
November 8, 2002, to Mr. Jeff Baum (https://
osha.gov/pls/oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=24576); and
November 2, 1995, to Mr. Mike Amen (https://
osha.gov/pls/oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=21999).
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from the aerial lift, they fall below the wire
suspended in the air. But because . . . line
clearance tree trimmers uniquely work from
aerial lifts routinely positioned . . . or
traveling above the wires if they were to fall
from the bucket, they would likely fall onto
the wire below when using the six-foot
lanyard and full body harness, facing certain
death by electrocution.
Reason 2: Some line clearance tree
trimming companies have their tree trimmers
help feed brush into the truck’s wood
chippers. This is a concern among many line
clearance tree trimming safety professionals
in that the harness’s appendage straps . . .
can get caught on the brush being fed into the
chipper and drag the operator into the
chipper. Additionally the donning and
doffing of a full body harness may predispose
the aerial lif[t] operator to take [an]
unacceptable risk of aiding a coworker
chipping brush on the ground or conversely
removing the harness and not putting it back
on when returning [aloft] in the lift. [Tr. 616–
617]
In their posthearing comments, ULCC
and TCIA expanded on this testimony.
These organizations acknowledged that
power line workers also work above
power lines, but maintained that there
are still significant differences that make
it more dangerous to use personal fall
arrest equipment with harnesses for
line-clearance tree trimming work (Exs.
0502, 0503). First, ULCC and TCIA
argued that, unlike line-clearance tree
trimmers, line workers take measures to
protect themselves from contact with
power lines below the aerial lift bucket.
For example, TCIA commented:
Through questioning of IBEW Panelists Jim
Tomaseski and Don Hartley (Hearing
Transcript, pages 1016–1019), we discovered
that it is the lineman’s typical practice to
insulate wires underneath the person in an
elevated work position in an aerial lift when
there is the possibility of the worker coming
within (including falling within) the
minimum approach distance. Obviously, it
effectively frees the lineman from concern of
their fall protection allowing them to drop
into the conductor(s). [I]nsulating the line is
infeasible or impractical for our crews since
they do not possess the tools or expertise to
implement it. [Ex. 0503]
Second, ULCC asserted that line
workers perform significantly less work
above power lines than line-clearance
tree trimmers, explaining:
Linemen usually work at the height of the
electric line; their work from above the line
is atypical—we estimate that less than 20%
of linemen work is from above the line. Thus,
the amount of linemen work [conducted]
from above an electric line is di minimis
[sic]. [Ex. 0502; emphasis included in
original]
First, with respect to fall arrest
equipment, OSHA does not consider
body harnesses to pose greater hazards
to line-clearance tree trimmers than
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body belts. The hazard to a worker from
being pulled into a chipper is easily
dismissed. OSHA acknowledges that
there are serious hazards associated
with operating chippers, including the
hazard that workers could be caught by
the chipper feed mechanism. NIOSH
published an article warning of hazards
associated with the operation of
chippers (see NIOSH Publication No.
99–145, ‘‘Hazard ID 8—Injury
Associated with Working Near or
Operating Wood Chippers;’’ Ex. 0481),
and that publication provides
recommendations to protect workers
against being caught in the feed
mechanism.112 These recommendations
include: (1) Having workers wear closefitting clothing and gloves, (2) having
workers wear trousers without cuffs,
and (3) ensuring that employees tuck in
their clothing. Consistent with these
recommendations, OSHA expects that
any hazards associated with using a
chipper while wearing a harness can be
avoided by requiring employees to
remove their harnesses before working
with the chipper. The tree trimming
industry commented that employees
might not want to take off their
harnesses before feeding brush into
chippers. (See, for example, Ex. 0502;
Tr. 616–617.) OSHA does not find that
argument persuasive. Employers can
avoid this concern altogether by having
these workers perform other groundbased work, such as moving the cut tree
branches near the chipper, while ground
workers, who are not wearing harnesses,
feed the branches into the chippers.
Second, OSHA does not consider the
risk of falling into a power line to be as
serious as the tree care industry
portrays. If an employee falls from an
aerial lift while using a personal fall
arrest system with a harness, contact
with a power line, though possible, is
not certain. Sometimes the employee
will not be working over the line. In
other situations, the line will be on one
side of the aerial lift bucket, but the
employee will fall out on the other side
where no conductors are present. In
addition, the line may be far enough
away that the employee does not reach
it during the fall. In any event, the
hazards associated with an employee
falling into a power line can be
reduced—or even removed altogether—
by using a shorter lanyard as suggested
by some rulemaking participants. (See,
for example, Ex. 0505; Tr. 694–695.) In
this regard, IBEW noted: ‘‘If . . . the
normal lanyard length [for a fall arrest
system] of 5 to 6 feet is too long, the
lanyard can be shortened to 3 or 4 feet,
112 This document is available at https://
www.cdc.gov/niosh/docs/99–145.
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thereby eliminating the anticipated
problems’’ (Ex. 0505). Noting that the
attachment point on a harness will be
farther from the anchorage on the boom
than is the attachment point on a body
belt, ULCC claimed that a 0.9-meter (3foot) lanyard was unworkable with a
body harness (Ex. 0502). OSHA is not
suggesting that a 0.9-meter lanyard with
a body harness is feasible, only that a
lanyard shorter than 1.8 meters (6 feet)
could be used to reduce the risk of
contact with a power line. A retractable
lanyard could be used to keep the length
of the lanyard as short as possible,
thereby reducing the risk even further.
Finally, the tree trimming
associations’ attempt to portray the
hazards of falling into power lines as
unique to their industry is flawed. The
evidence is clear from the comments of
employees who perform line work that
power line workers also work above
power lines and can fall into them. (See,
for example, Ex. 0505; Tr. 971.) In
addition, ULCC’s attempt to distinguish
line-clearance tree trimming work from
power line work on the grounds that
power line workers insulate the
conductors above which they are
working is unpersuasive. Like lineclearance tree trimmers, power line
workers often work above energized
power lines that have not been
insulated. The final rule does not
require insulation on conductors for a
power line worker maintaining the
minimum approach distance. In
addition, insulating the lines is not
always possible. According to
§ 1926.97(c)(2)(i) and Table E–4 of the
final rule, the highest maximum use
voltage for rubber insulating equipment,
such as rubber insulating line hose or
blankets, is 36 kilovolts. The maximum
use voltage for plastic guard equipment
is 72.5 kilovolts (Ex. 0073). Insulation is
not available above those voltages.
TCIA argued that insulating power
lines is not feasible or practical for lineclearance tree trimming crews (Ex.
0503). OSHA is not persuaded by this
argument. To the extent that it is the
practice of line workers to insulate
conductors beneath them, OSHA
concludes that this practice also
represents a feasible means of protecting
line-clearance tree trimmers from the
hazard of falling into the line. The
comment that line-clearance tree
trimmers are not currently being trained
in this practice is not relevant to
whether it is feasible. If necessary, a
line-clearance tree trimming employer
could have the electric utility install the
insulation or train line-clearance tree
trimmers so that they are qualified to
install insulation. In any event, the final
rule does not require insulation for line-
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20385
clearance tree trimmers; the final rule at
§ 1910.269(r)(1)(iii) simply requires
them to maintain the minimum
approach distance from power lines.
The use of insulation would simply be
one way for line-clearance tree trimming
employers to address their concern
about employees falling into power
lines while using personal fall arrest
systems.
The tree trimming industry did not
submit any comments directly
addressing the use of restraint systems,
which is the second compliance option
available to line-clearance tree trimming
employers. Instead, as a result of the
industry’s misunderstanding regarding
the applicability of the 0.6-meter (2-foot)
free-fall distance for work-positioning
systems (described earlier), it simply
argued that it would be impossible or
unsafe for employees working from an
aerial lift to use a 0.6-meter lanyard
with a body belt for their work. (See, for
example, Exs. 0174, 0200, 0419, 0502,
0503; Tr. 613–615, 756.)
Mr. Andrew Salvadore, representing
ULCC, testified as follows:
[W]e can’t do line clearance tree trimming
with a lanyard of two foot [sic] or less. There
are three reasons for this.
Reason No. 1: Line clearance tree trimmers
need to be able to reach from the four corners
of an aerial lift bucket to do their work
because [of the need] to maintain a minimum
approach distance from energized wires
different from linemen who can work right
next to the wires. We can’t get to the four
corners of the bucket with a two-foot or
shorter lanyard, typically anchored . . .
outside of the bucket on the boom. This
prevents us from reaching outside of the
bucket with our tools or extending from the
bucket. . . .
Reason 2: The two-foot limitation is also
unworkable because we usually work from
[an] aerial lift positioned above energized
conductors, reaching down to the tree
branches below adjacent to conductors using
insulated pole tools. This is different from
linemen who typically position their lift
buckets right next to the wire at arm’s length.
We lack the range of movement within the
bucket necessary to reach over the bucket
and down to the worksite because we would
be restrained to the side of the bucket closest
to the anchor. Relocation of an anchor is not
[an] easy fix because the anchor is required
to withstand a 5,000 pounds of force and
typically can’t be installed on the bucket . . .
because [of] the lack of [a] strong enough
anchoring point and because if the bucket
breaks off in a catastrophic incident the
worker goes down with the anchor attached
to the bucket [rather than] being suspended
by the lanyard attached to the boom.
The Third Reason: Our people may be
potentially yanked out of the bucket into
precisely the fall that is sought to be avoided
by the proposal because line clearance tree
trimmers routinely rotate and articulate their
lift buckets in ways that would exceed the
distance of a short lanyard. . . . [This
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exposes] the worker to being yanked out of
the bucket by the short lanyard when the
range of articulation of the bucket exceeds
the short length of the lanyard. [Tr. 613–615]
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To address these problems, the tree care
industry recommended that OSHA
permit the use of a 0.9-meter (3-foot)
shock-absorbing lanyard with a body
belt. (See, for example, Exs. 0174, 0200,
0502, 0503; Tr. 615—616, 759—760.)
The industry proposed a 408-kilogram
(900-pound) limitation on fall arrest
forces, presumably to remove hazards
associated with concentrated fall arrest
forces in falls into body belts (id.).
As noted earlier, the tree care industry
misinterpreted its compliance options
under the proposed rule. For work from
an aerial lift, there are only two options:
(1) Fall arrest equipment and (2) a fall
restraint system. Restraint systems do
not permit any free fall. An acceptable
restraint system for an aerial lift would
prevent an employee from falling out of
the lift and from being catapulted from
the lift (for example, if the vehicle
supporting the aerial lift was struck by
a vehicle or if a large tree section struck
the boom). Body belts are permitted as
part of a restraint system; however, a
system rigged to allow an employee to
free fall even 0.6 meters (2 feet) would
not be acceptable as a restraint system.
The system proposed by the tree care
industry, namely a body belt connected
to a 0.9-meter (3-foot) lanyard attached
to an anchorage on the boom of an aerial
lift, would not prevent the employee
from falling out of or being catapulted
from an aerial lift. Therefore, it would
not be acceptable as a restraint system.
Moreover, with a body belt instead of
a harness, the system proposed by the
tree care industry would not be an
acceptable fall arrest system. Even if it
provides sufficient protection to
employees against concentrated fall
arrest forces, it does not address the
other two significant hazards associated
with falling into body belts, that is,
falling out of the body belt and
sustaining further injury during
suspension.113
113 Paragraph (d)(16) of § 1926.502 requires a
personal fall arrest system to be rigged so that the
employee cannot free fall more than 6 feet (1.8
meters) nor contact any lower level. The Agency
notes that the lanyard may need to be shorter than
the maximum free-fall distance. This is the case for
aerial lift work. The anchorage point on the boom
of an aerial lift may be below the attachment point
on the body belt or harness. As a result, the
employee could free fall a distance equal to twice
the length of the lanyard if he or she is ejected or
catapulted from the aerial lift, as can happen when
a vehicle strikes the aerial lift truck or a falling
object, such as a tree branch, strikes the boom. This
is not an unlikely event as several accidents in the
record demonstrate (Ex. 0003; these three accidents
can be viewed at https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=14507743&
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The tree care industry asserted that
OSHA has not demonstrated that using
body belts in personal fall arrest systems
in aerial lifts poses hazards to lineclearance tree trimmers. (See, for
example, Exs. 0174, 0200, 0502, 0503;
Tr. 613, 758–759.) TCIA made this point
as follows:
protection. [Ex. 0174; emphasis included in
original]
Preliminarily, there is NO showing in the
subject notice of rule making that . . .
allowing a body belt and lanyard for fall
protection from aerial devices . . . creates a
risk which merits modification of existing
practice. It is our industry’s experience that
line clearance tree trimmers are not being
injured by virtue of using body belts (OSHA
cites no evidence, nor contrary evidence of
any such bucket fall hazard or hazard from
body belt lanyards over two feet long in line
clearance tree trimming), and that lack of
compliance with PPE use requirements is
directly proportional to how hard or
uncomfortable the PPE is to use. Between
1984 and 2002, there were 34 OSHArecorded fatalities in Tree Trimming (SIC
0783) involving aerial device operators and
falls. The details of these accidents illustrate
where the greatest problems lie:
• 23 of 34 fatalities were caused by
catastrophic mechanical failures of some part
of the aerial device that slammed the victim
to the ground from considerable height. Fall
protection, or lack of it, was not a factor in
these fatalities.
• 5 of 34 fatalities were caused by a tree
or limb striking the aerial lift boom, again
causing failure of the aerial device. Again,
fall protection was not a factor.
• 6 of 34 fatalities were caused by
unsecured falls from the aerial device, and
probably would have been prevented by the
use of any means of fall protection.
At a recent meeting of the Tree Care
Industry Association Safety Committee (a
tree care industry trade association), with the
safety directors of 20 of the largest tree care
companies representing well over 60,000 tree
care employees present, a survey was taken
as to whether these companies had any
experience with aerial lift operators being
injured from secured falls out of buckets.
None did. For them, the more profound
problem was the operator who disobeyed
company policy and failed to wear any fall
In its posthearing comments, ULCC
further argued that the one accident
OSHA described, in which an employee
slipped out of a body belt, occurred to
a line worker, not a line-clearance tree
trimmer, and that this single accident
‘‘is statistically insignificant,
insufficiently documented on the
record, and in no way probative of any
problem of line clearance tree trimmers
falling from aerial lifts’’ (Ex. 0502).
ULCC further suggested that OSHA’s
proposal ignored the suspension-trauma
risk associated with full body harnesses
(Exs. 0481, 0502). (OSHA describes the
hazards related to prolonged suspension
in fall protection equipment later in this
section of the preamble.)
OSHA rejects these assertions. OSHA
closely examined issues related to the
use of body belts in arresting falls in its
Subpart M rulemaking (59 FR 40702–
40703). In that rulemaking, the Agency
concluded that ‘‘evidence in the record
clearly demonstrates that employees
who fall while wearing a body belt are
not afforded the level of protection they
would be if the fall occurred while the
employee was wearing a full body
harness’’ (59 FR 40703). In addition, the
Agency pointed to ‘‘evidence of injuries
resulting from the use of body belts’’ in
fall arrest systems (id.). Also, as
mentioned by ULCC, there is evidence
in this rulemaking of an incident in
which an employee, working from an
aerial lift while wearing a body belt in
a fall arrest system, slipped from the
belt in a fall (Ex. 0003 114). Contrary to
the tree care industry’s suggestion,
OSHA need not show that injuries are
presently occurring to line-clearance
tree trimmers because of falls into body
belts; it is sufficient that the Agency
found that tree trimming employees are
exposed to a significant risk of injury
under the existing standard and that the
final rule will substantially reduce that
risk. (See Section II.D, Significant Risk
and Reduction in Risk, earlier in this
preamble, for OSHA’s response to the
argument that the Agency is required to
demonstrate a significant risk for each of
the hazards addressed by this
rulemaking.) ULCC’s own analysis
confirms that line-clearance tree
trimmers are exposed to fall hazards
(Ex. 0174). Nearly 18 percent of falls
from aerial lifts were of the type that, if
the employee had been wearing a body
belt in a personal fall arrest system, he
or she would have been exposed to the
serious hazards, described earlier, that
id=953869&id=14333157). Thus, the tree industry’s
recommended lanyard length could result in a free
fall of 1.8 meters (6 feet).
114 The description of this accident is available at:
https://www.osha.gov/pls/imis/accidentsearch.
accident_detail?id=170155857.
The only fall protection issue arising in
aerial lifts is failure to use any form of fall
protection—an unsafe and non-compliant
behavior that the industry must strive to
eliminate. Similarly, if operators in the past
have worn body belts incorrectly, causing the
equipment to not deliver the level of
protection it should have, then there is a
behavioral issue to address in training.
It is our industry’s experience that workers
are not being injured by virtue of using body
belts . . . and that non-compliance with PPE
use requirements is directly proportional to
how hard or uncomfortable the PPE is to use.
[Ex. 0200; emphasis included in original]
ULCC had similar comments:
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are associated with using body belts in
fall arrest systems (id.).
The Agency acknowledges the
suspension risk from body harnesses
identified by ULCC. When an employee
is suspended in a body belt or harness,
a number of adverse medical effects can
occur, including upper or lower
extremity numbness; abdominal,
shoulder, or groin pain; respiratory
distress; nausea; dizziness; and
arrhythmias (Ex. 0088). At least one of
the adverse effects, orthostatic
incompetence, can lead to death (Ex.
0481). It is because of these hazards that
§ 1926.502(d)(20) in Subpart M requires
the employer to provide for prompt
rescue of employees in the event of a
fall or to assure that employees are able
to rescue themselves. In any event, the
hazards associated with prolonged
suspension in a body belt are
substantially more severe than the
hazards associated with suspension in a
harness. In 1985, the U.S. Technical
Advisory Group on Personal Equipment
for Protection Against Falling stated, in
comments on another OSHA
rulemaking: ‘‘The length of time which
a fallen person can tolerate suspension
in a body belt is measured in a very few
minutes under the most favorable
conditions’’ (Ex. 0084). In addition, a
1984 U.S. Air Force literature review
recounted one study that found that
‘‘two subjects evaluated in . . . waist
belt[s] with shoulder straps tolerated
suspension for 1 min 21 sec and 3 min’’
(Ex. 0088).115 That same study showed
that subjects suspended in full body
harnesses could tolerate suspension for
approximately 20 to 30 minutes (id.).
The tree care industry commented
that, to the extent injuries are occurring,
they are caused by the failure of
employees to use any fall protection,
rather than by the use of body belts.
(See, for example, Exs. 0174, 0200.) This
argument supports, rather than
undermines, a requirement for
harnesses in personal fall arrest systems.
To the extent better enforcement of fall
protection requirements by employers is
a critical component of protecting
employees in aerial lifts, harnesses are
preferable to body belts. It is not always
possible to detect from the ground
whether an employee is wearing a body
belt, but it is relatively easy to
determine if an employee is wearing a
body harness (Tr. 972–973). If
employees initially resist the use of
body harnesses, as suggested by some
commenters (see, for example, Exs.
115 Hearon, B.F., Brinkley, J.W., ‘‘Fall Arrest and
Post-Fall Suspension: Literature Review and
Directions for Further Research,’’ AFAMRL–TR–84–
021, April 1984.
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0174, 0200, 0219), employers must be
proactive in communicating the need
for, and ensuring the use of, the
required equipment.
The Agency concludes that the use of
a 0.9-meter shock-absorbing lanyard
with a body belt, as proposed by the tree
trimming industry, is not an adequate
substitute for the use of a harness in a
fall arrest system. OSHA has not been
persuaded to abandon its finding in the
Subpart M rulemaking that body belts
present unacceptable risks in fall arrest
situations and should be prohibited as
components of fall arrest equipment.
OSHA is adopting in the final rule the
requirement proposed in paragraph
(b)(1) that personal fall arrest equipment
meet Subpart M of Part 1926. This
provision appears in final
§ 1926.954(b)(1)(i).
ULCC noted what it perceived as an
implied, but unstated, revision in the
proposal to the provisions contained in
the general industry aerial lift standard
(§ 1910.67(c)(2)(v)) requiring employees
working in aerial lifts to use body belts
and lanyards. (See, for example, Ex.
0174.)
In the preamble to the proposal,
OSHA explained that it was relying on
the provisions in the aerial lift standards
to establish the employer’s duty to
provide fall protection for employees,
but that Subpart M would govern the
criteria fall arrest equipment must meet
(70 FR 34850). In other words, for work
covered by this rule, body belts would
not be permitted in personal fall arrest
systems. The ULCC commented:
‘‘OSHA’s suggestion that [the aerial lift
standard] describes only the ‘duty’ to
use fall protection rather than the kind
of fall protection, respectfully, is a
makeweight’’ (Ex. 0502).
In light of ULCC’s comments, the
Agency is concerned that some
employers reading the final rule may
mistakenly assume that the body belts
required by §§ 1910.67(c)(2)(v) and
1926.453(b)(2)(v) remain acceptable for
use in personal fall arrest systems. In
addition, the Agency wants to make it
clear in the final rule that workpositioning equipment is unacceptable
from the horizontal working surface of
an aerial lift. Employees working from
aerial lifts covered by the final rule must
be protected using either a fall restraint
system or a personal fall arrest system.
Therefore, OSHA is adding a provision
in final §§ 1910.269(g)(2)(iv)(C)(1) and
1926.954(b)(3)(iii)(A) providing that
employees working from aerial lifts be
protected with a fall restraint system or
a personal fall arrest system and that the
provisions of the aerial lift standards
requiring the use of body belts and
lanyards do not apply. This provision
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20387
clearly states the requirement contained
in the proposal. As a consequence of
this change, the final rule does not
include the text in Note 1 to proposed
§ 1910.269(g)(2)(iii)(C) and Note 1 to
proposed § 1926.954(b)(3)(iii) referring
to fall protection for aerial lifts or
referencing the general industry and
construction standards on aerial lifts.
(The corresponding notes in the final
rule are Note 1 to
§ 1910.269(g)(2)(iv)(C)(2) and
(g)(2)(iv)(C)(3) and Note 1 to
§ 1926.954(b)(3)(iii)(B) and (b)(3)(iii)(C).)
OSHA is adopting revised
requirements for work-positioning
equipment in § 1926.954(b)(2).116
Section 1926.959 of existing Subpart V
contains requirements for body belts,
safety straps,117 and lanyards.118 This
equipment was traditionally used as
both work-positioning equipment and
fall arrest equipment in the maintenance
and construction of electric power
transmission and distribution
installations. However, fall arrest
equipment and work-positioning
equipment present significant
differences in the way they are used and
in the forces they place on an
employee’s body. With fall arrest
equipment, an employee has freedom of
movement within an area restricted by
the length of the lanyard or other device
connecting the employee to the
anchorage. In contrast, and as explained
earlier, work-positioning equipment is
used on a vertical surface to support an
employee in position while he or she
works. The employee ‘‘leans’’ into this
equipment so that he or she can work
with both hands free. If a fall occurs
while an employee is wearing fall arrest
equipment, the employee will free fall
up to 1.8 meters (6 feet) before the slack
is removed and the equipment begins to
arrest the fall. In this case, the fall arrest
forces can be high, and they need to be
spread over a relatively large area of the
116 In § 1910.269(g)(2)(ii), OSHA proposed to
require body belts and positioning straps for work
positioning to meet § 1926.954(b)(2). The final rule
duplicates the requirements of § 1926.954(b)(2) in
§ 1910.269(g)(2)(iii) rather than referencing them.
117 ‘‘Safety straps’’ is an older, deprecated term
for ‘‘positioning straps.’’
118 Existing § 1926.500(a)(3)(iii) states that
additional performance requirements for personal
climbing equipment, lineman’s body belts, safety
straps, and lanyards are provided in subpart V.
OSHA is revising the language in this provision to
make it consistent with the terms used in final
Subpart V. Furthermore, because the Agency is
adopting, in subpart V, an additional requirement
for fall arrest equipment used by employees
exposed to electric arcs (as described earlier in this
section of the preamble), OSHA is adding fall arrest
equipment to the list of equipment in
§ 1926.500(a)(3)(iii). As revised, § 1926.500(a)(3)(iii)
states that additional performance requirements for
fall arrest and work-positioning equipment are
provided in Subpart V.
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body to avoid injury to the employee.
Additionally, the velocity at which an
employee falls can reach up to 6.1
meters per second (20 feet per second).
Work-positioning equipment is
normally used to prevent a fall from
occurring in the first place. If the
employee slips and if the workpositioning equipment is anchored, the
employee will only fall a short distance
(no more than 0.6 meters (2 feet) under
paragraph (b)(3)(iv) of final § 1926.954).
This distance limits the forces on the
employee and the maximum velocity of
a fall. Additionally, because of the way
the equipment is used, the employee
should not be free falling. Instead, the
work-positioning equipment will be
exerting some force on the employee to
stop the fall, thereby further limiting the
maximum force and velocity. As long as
the employee is working on a vertical
surface, the chance of an employee
using work-positioning equipment
falling out of, or being suspended at the
waist in, a body belt is extremely low.
In the final rule, OSHA is applying
requirements to personal fall arrest
systems that differ from the
requirements that apply to workpositioning equipment. As discussed
previously, personal fall arrest systems
must meet subpart M of part 1926, as
required by paragraph (b)(1)(i),
supplemented by the requirement in
final paragraph (b)(1)(ii) that the
equipment withstand exposure to
electric arcs. Work-positioning
equipment must meet the requirements
contained in paragraph (b)(2) of the final
rule. Employers engaged in electric
power transmission and distribution
work may use the same equipment for
fall arrest and for work positioning
provided the equipment meets both sets
of requirements. In fact, as noted in the
preamble to the proposal, several
manufacturers market combination body
harness-body belt equipment, which can
be used as fall arrest systems by
employees working on horizontal
surfaces or as work-positioning systems
supporting employees working on
vertical surfaces (70 FR 34850).
Paragraph (b)(2) of the final rule is
based on existing § 1926.959 and ASTM
F887–04, Standard Specifications for
Personal Climbing Equipment, which
was the latest edition of the national
consensus standard applicable to workpositioning equipment when OSHA
developed the proposed rule (Ex. 0055).
Although OSHA is adopting
requirements derived from the ASTM
standard, the final rule is written in
performance-oriented terms. Detailed
specifications contained in the ASTM
standard, which do not directly impact
the safety of employees, were not
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included in the final rule. The Agency
believes that this approach will retain
the protection for employees afforded by
the ASTM standard, while giving
employers flexibility in meeting the
OSHA standard and accommodating
future changes in the ASTM standard
without needing to change the OSHA
standard. This is similar to the approach
OSHA took in final § 1926.97, discussed
previously.
While the ASTM standard does not
cover lanyards, paragraph (b)(2), as
proposed, would have applied many of
the requirements based on the ASTM
standard to lanyards. Existing
§ 1926.959 imposes the same basic
requirements on lanyards.
OSHA requested comment on
whether any of the proposed
requirements for work-positioning
equipment should not be applicable to
lanyards. Some commenters supported
the Agency’s proposal. (See, for
example, Exs. 0211, 0230.) For instance,
IBEW stated:
[L]anyards used for fall protection for
electric power transmission and distribution
work [already] meet the requirements of
ASTM F887–04. Therefore these
requirements, as proposed, should be
applicable to lanyards used for work
positioning equipment. [Ex. 0230]
However, Buckingham Manufacturing
Company, a manufacturer of workpositioning equipment used by line
workers, opposed the application of
some of the proposed requirements for
work-positioning equipment to
lanyards:
Buckingham Mfg. recommends including a
section on lanyards to remove requirements
outlined in the referenced sections that are
not applicable to lanyards such as: (b)(2)(vii)
and including at least criteria such as
strength requirements for the rope or
webbing used to manufacture . . . a lanyard,
the minimum number of rope tucks for rope
lanyards, the length of stitching for turnover
at ends of web lanyards, stitching used be of
a contrasting color to facilitate visual
inspection, etc. [Ex. 0199]
ASTM F887–04 refers to the straps
used with work-positioning equipment
as ‘‘positioning straps,’’ not lanyards.119
That consensus standard uses the term
‘‘lanyard’’ only with respect to personal
fall arrest equipment. In addition,
subpart M uses the term ‘‘lanyard’’ only
in the requirements applicable to
personal fall arrest systems in
§ 1926.502(d). However, existing
§ 1926.959 applies to ‘‘body belts, safety
straps, and lanyards’’ used for either
119 ASTM F887–12e1 uses the term ‘‘adjustable
positioning lanyards’’ for equipment used as part of
certain positioning devices. OSHA treats these
lanyards as ‘‘positioning straps’’ under the final
rule.
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work positioning or fall arrest. Because
the term ‘‘lanyard’’ is most typically
used with reference to fall arrest
equipment, OSHA is concerned that
using that term in requirements for
work-positioning equipment could lead
employers or employees to believe that
work-positioning equipment is
acceptable for use in fall arrest
situations, for example, when an
employee is working from a horizontal
surface. For these reasons, OSHA
decided to use the term ‘‘positioning
strap’’ instead of lanyard in final
paragraph (b)(2) to describe the strap
used to connect a body belt to an
anchorage in work-positioning
equipment. Thus, any strap used with
work-positioning equipment is a
‘‘positioning strap’’ for the purposes of
paragraph (b)(2). This language also
should address Buckingham
Manufacturing’s concerns that some of
the proposed requirements were
inapplicable to lanyards. The Agency
believes that Buckingham
Manufacturing’s comment was referring
to lanyards used with personal fall
arrest systems, which OSHA recognizes
may not meet all of the requirements for
positioning straps in final
§ 1926.954(b)(2). Paragraph (b)(2)(vii)
contains specifications for positioning
straps that are essential to electric
power generation, transmission, and
distribution work, including
requirements for electrical performance,
strength, and flame resistance (Ex.
0055). Lanyards, which are used with
personal fall arrest systems, have to
meet appropriate strength and, if
necessary, arc-resistance requirements
under subpart M and final
§ 1926.954(b)(1)(ii).
Paragraph (b)(2)(i), which is being
adopted without substantive change
from the proposal, requires hardware for
body belts and positioning straps to be
made from drop-forged steel, pressed
steel, formed steel, or equivalent
material. This hardware also must have
a corrosion-resistant finish. Surfaces
must be smooth and free of sharp edges.
These requirements ensure that the
hardware is durable, strong enough to
withstand the forces likely to be
imposed, and free of sharp edges that
could damage other parts of the workpositioning equipment. These
requirements are equivalent to existing
§ 1926.959(a)(1), except that the existing
standard does not permit hardware to be
made of any material other than dropforged or pressed steel. Although ASTM
F887–04 requires hardware to be made
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of drop-forged steel,120 OSHA explained
in the preamble to the proposal that,
while the drop-forged steel process
produces hardware that more uniformly
meets the required strength criteria and
will retain its strength over a longer
period than pressed or formed steel, it
is possible for other processes to
produce hardware that is equivalent in
terms of strength and durability (70 FR
34851). Paragraphs (d)(1) and (e)(3) of
§ 1926.502 already permit ‘‘connectors’’
(that is, ‘‘hardware’’ as that term is used
in this final rule) to be made of
materials other than drop-forged or
pressed steel.
OSHA invited comments on whether
alternative materials would provide
adequate safety to employees. Most
commenters responding to this issue
supported the proposed language
accepting the use of equivalent
materials. (See, for example, Exs. 0126,
0162, 0173, 0175, 0186, 0230.) For
instance, Ms. Salud Layton of the
Virginia, Maryland & Delaware
Association of Electric Cooperatives
commented:
We support the flexibility OSHA [is]
offering in this area. Allowing hardware to be
made of material other than drop-forged or
pressed steel allows for potential alternatives
to be evaluated for use. Other material,
however, must meet the strength and
durability criteria of drop-forged or pressed
steel materials. [Ex. 0175]
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Other commenters supported the
proposal because it would permit the
use of alternative materials that might
be developed in the future (Exs. 0162,
0186, 0230). Mr. Daniel Shipp with
ISEA commented that the ‘‘use of nonferrous materials, including high-tensile
aluminum with [a] protective anodize
coating, is common’’ and noted that
there are ‘‘criteria [available] for
evaluating the equivalence between
forged alloy steel and other materials’’
(Ex. 0211).
Although OSHA received no outright
opposition to the proposal, ASTM
Committee F18 on Electrical Protective
Equipment for Workers, the committee
responsible for developing ASTM F887,
submitted the following statement from
Mr. Hans Nichols, P.E., Metallurgical
Consulting:
My opinion is that forgings are superior to
stampings. The principal advantage of
forgings is control of grain direction to match
the part geometry. The grain direction of a
stamping will be oriented transverse to the
part in some areas. Since the mechanical
properties, i.e.—yield strength and impact
strength, are lower in the transverse
120 The current edition of this standard, ASTM
F887–12e1, also requires hardware to be made from
drop-forged steel in Section 15.4.1.1.
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direction, this area of the part would be a
weak point. [Ex. 0148]
OSHA agrees that some materials
have advantages over others and expects
that manufacturers typically base their
design decisions on factors such as
these. However, the fact that forgings
may result in more uniform strength
throughout a material than stampings is
not relevant to the overall strength of
hardware. It is the area of least strength
that determines whether hardware has
sufficient overall strength, and the
design-test requirements in the final
rule (discussed later in this section of
the preamble) ensure that hardware, and
the entire work-positioning system, are
sufficiently strong. In other words, the
testing requirements in the rule ensure
that the weakest part of the weakest
piece of the system will not fail under
conditions likely to be encountered
during use. In addition, the final rule
requires that the hardware be made of
material that has strength and durability
equivalent to that of drop-forged,
pressed, or formed steel, materials used
successfully for work-positioning
equipment for decades. Therefore,
OSHA is including paragraph (b)(2)(i) in
the final rule substantially as proposed.
Paragraph (b)(2)(ii), which is being
adopted without substantive change
from the proposal, requires buckles to
be capable of withstanding an 8.9kilonewton (2,000-pound-force) tension
test with a maximum permanent
deformation no greater than 0.4
millimeters (0.0156 inches). This
requirement, which also can be found in
existing § 1926.959(a)(2), will ensure
that buckles do not fail if a fall occurs.
Paragraph (b)(2)(iii), which is being
adopted without substantive change
from the proposal, requires that D rings
be capable of withstanding a 22kilonewton (5,000-pound-force) tensile
test without cracking or breaking. (A D
ring is a metal ring in the shape of a
‘‘D.’’ See Figure 2, which shows a
snaphook and a D ring.) This provision,
which is equivalent to existing
§ 1926.959(a)(3), will ensure that D rings
do not fail if a fall occurs.
Paragraph (b)(2)(iv), which is being
adopted without substantive change
from the proposal, is equivalent to
existing § 1926.959(a)(4) and requires
snaphooks to be capable of withstanding
a 22-kilonewton (5,000-pound-force)
tension test without failure. A note
following this provision indicates that
distortion of the snaphook sufficient to
release the keeper is considered to be
tensile failure. The language of the note
in the final rule was revised from the
proposal to make it clear that such
distortion is only one form of failure.
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20389
The snaphook breaking completely is a
more obvious failure not mentioned in
the note.
Paragraph (b)(2)(v), which is being
adopted without change from the
proposal, prohibits leather or leather
substitutes from being used alone as a
load-bearing component of a body-belt
and positioning-strap assembly. This is
a new requirement for Subpart V and
was derived from ASTM F887–04,
Sections 14.2.1 and 15.2.1.121 The
requirement is necessary because
leather and leather substitutes do not
retain their strength as they age. Because
this loss in strength is not always easy
to detect by visual inspection, it can
lead to failure under fall conditions.
Paragraph (b)(2)(vi), which is being
adopted without substantive change
from the proposal, requires that plied
fabric used in positioning straps and in
load-bearing portions of body belts be
constructed so that no raw edges are
exposed and the plies do not separate.
This new requirement, which also is
based on ASTM F887–04, in this
instance, Sections 14.2.2 and 15.2.2,
will prevent plied fabric from
separating, which could cause it to fail
under fall conditions.122
Although work-positioning
equipment used in electric power
transmission and distribution work is
not to be used as insulation from live
parts, positioning straps could come
into accidental contact with live parts
while an employee is working. Thus,
OSHA deems it important for this
equipment to provide a specified level
of insulation. Accordingly, the Agency
proposed, in paragraphs (b)(2)(vii)(A)
and (b)(2)(vii)(B), to require positioning
straps to be capable of passing dielectric
and leakage current tests.123 Similar
requirements are found in existing
§ 1926.959(b)(1). The voltages listed in
the proposed paragraphs were
alternating current. A note following
proposed paragraph (b)(2)(vii)(B)
indicated that equivalent direct current
tests also would be acceptable.
In the preamble to the proposed rule,
OSHA explained that ASTM F887–04
did not require positioning straps to
pass a withstand-voltage test (70 FR
121 These requirements are also contained in the
latest edition, ASTM F887–12e1, in Sections 14.2.1
and 15.2.1.1.
122 These requirements are also contained in the
latest edition, ASTM F887–12e1, in Sections 14.2.2
and 15.2.1.2.
123 The dielectric and leakage-current tests
required by these paragraphs involve attaching
electrodes to the fall protection equipment,
applying a test voltage across the electrodes, and
checking for deterioration (in the case of the
dielectric test) or measuring leakage current (in the
case of the leakage-current test). ASTM F887–12e1
includes test methods for these two tests.
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34851). Instead, the consensus standard
stated in a note that the fabric used in
the positioning straps must pass a
withstand-voltage test. The Agency
invited comment on whether
performing electrical tests on
positioning straps is necessary for
employee safety in electric transmission
and distribution work (that is, whether
the requirements proposed in
paragraphs (b)(2)(vii)(A) and
(b)(2)(vii)(B) were necessary).124 A
number of commenters responded to
this question. Some commenters
supported OSHA’s proposal. (See, for
example, Exs. 0148, 0230.) For instance,
IBEW explained:
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Positioning straps should offer a minimum
level of insulation in the event [the] strap
comes in contact with energized parts. The
manufacturing specifications from ASTM
F887–04 do not ensure the positioning strap
actually offers any level of insulation. As
stated in the proposal, the ASTM
requirements only require the fabric used to
make the strap be tested for leakage current.
Other products used [in] the manufacture of
the strap could . . . jeopardize the electrical
[insulation] integrity of the fabric. Therefore,
the leakage current of the finished product
will not be known without a separate test.
[Ex. 0230]
ASTM commented that ‘‘requirements
in ASTM F887 04 for leakage current
and withstand testing of the positioning
strap material in Sections 15.3.1 and
15.3.1—Note 2 are adequate for the
performance of the positioning strap’’
(Ex. 0148). The organization
recommended that the ASTM language
‘‘be repeated in the Final 1926.954, or
incorporated by reference’’ (id.).
Other commenters did not see a need
to perform electrical tests on positioning
straps. (See, for example, Exs. 0162,
0173, 0186, 0219.) For instance, Mr.
Anthony Ahern with Ohio Rural
Electric Cooperatives argued: ‘‘Given the
environment these devices will be used
in, within 5 minutes of being used the
first time they will probably have
enough dirt and wood preservative
ground into them that they couldn’t
pass such a test again’’ (Ex. 0186). He
also noted that this equipment has been
in service for years and he is not aware
of any accidents that have occurred due
to the breakdown of a positioning strap
(id.). Mr. Allen Oracion with Energy
United EMC maintained that
positioning straps will be separated
from energized parts by at least the
124 The preamble to the proposal asked
specifically about the withstand test requirement
proposed in paragraph (b)(2)(vii)(A); however, most
commenters responded to the question of whether
there is a need to perform electrical tests on
positioning straps (the withstand test and the
leakage test proposed in paragraph (b)(2)(vii)(B)).
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minimum approach distance, making
withstand tests unnecessary (Ex. 0219).
OSHA believes that requiring
positioning straps to be capable of
passing the electrical tests in proposed
§ 1926.954(b)(2)(vii)(A) and (b)(2)(vii)(B)
will provide an additional measure of
protection to employees if a conductor
or other energized part slips and lands
on the strap or if the strap slips from the
employee’s hand and lands on an
energized part. In response to Mr.
Oracion’s comment, the Agency notes
that the minimum approach distance
will not always protect employees
exposed to electric-shock hazards. For
example, minimum approach distances
do not apply to conductors on which
work is being performed by employees
using rubber insulating gloves (as
explained under the discussion of
§ 1926.960(c)(1) of the final rule). The
proposed withstand- and leakage-testing
requirements will confirm that the
fabric used in the manufacture of the
strap will provide insulation from
electrical contact and that the
manufacturing process that created the
strap did not compromise the fabric’s
insulating properties. Although the
equipment may become contaminated
during use, as noted by Mr. Ahern, the
inspection requirements in
§ 1926.954(b)(3)(i) of the final rule
(discussed later in this section of the
preamble) will ensure that any
contamination that can affect the
insulating properties of the equipment
will be identified and removed. In
addition, any contamination will
normally be on the portion of the
positioning strap in contact with a pole;
the remaining portion of the strap will
still provide a measure of protection.
The testing requirements in final
paragraphs (b)(2)(vii)(A) and
(b)(2)(vii)(B) are also equivalent to the
tests required by ASTM F887–12e1
(Section 15.3.1 and Note 2). It is not
clear why ASTM included the
requirement that positioning straps pass
a withstand test in a note rather than in
the rule itself. OSHA is including the
requirement that positioning straps be
capable of passing a withstand test in
the text of final § 1926.954(b)(2)(vii)(A)
to make it clear that this provision is
mandatory. The Agency believes that
straps currently being manufactured and
used usually meet the final provisions.
There is no evidence in the rulemaking
record that current positioning straps do
not meet these requirements. Therefore,
OSHA is including paragraphs
(b)(2)(vii)(A) and (b)(2)(vii)(B) in the
final rule as proposed.
Paragraphs (b)(2)(vii)(C) and
(b)(2)(vii)(D), which are being adopted
without substantive change from the
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proposal, contain new requirements for
positioning straps to be capable of
passing tension tests and buckle-tear
tests. These tests are based on ASTM
F887–04, sections 15.3.2 and 15.3.3, and
will ensure that individual parts of
positioning straps have adequate
strength and will not fail during a
fall.125
Paragraph (b)(2)(vii)(E) requires
positioning straps to be capable of
passing a flammability test (described in
Table V–1). This requirement, and the
test in Table V–1, are based on ASTM
F887–04, Section 15.3.4.126 If an electric
arc occurs while an employee is
working, the work-positioning
equipment must be capable of
supporting the employee in case he or
she loses consciousness. It is
particularly important for the
positioning strap to be resistant to
igniting, because, once ignited, it would
quickly lose its strength and fail.
Mr. Pat McAlister with Henry County
REMC questioned the ‘‘value in the
proposed arc testing requirement’’
because his company was ‘‘not aware of
any situation where exposure to thermal
energy has contributed to failure of’’
positioning straps (Ex. 0210).
OSHA responds that, although
paragraph (b)(2)(vii)(E) will help ensure
that positioning straps do not fail if an
electric arc occurs, the standard just
requires positioning straps to be capable
of passing a flammability test; the
standard does not require electric-arc
testing. As noted later in the discussion
of § 1926.960(g) of the final rule, electric
power generation, transmission, and
distribution work exposes employees to
hazards from electric arcs. Paragraph
(b)(2)(vii)(E) of § 1926.954 protects
against some of those hazards, including
ignition of the positioning strap, which
could lead to failure of the strap and
burns to the employee. ASTM F887 has
required positioning straps to be capable
of passing a flammability test since
1988, so the Agency is not surprised
that Mr. McAlister is not aware of
failures of positioning straps in electricarc exposures. Having ASTM adopt a
requirement for positioning straps to
pass a flammability test is evidence that
the consensus of industry opinion is
that such testing is necessary. Therefore,
OSHA is including paragraph
(b)(2)(vii)(E) in the final rule as
proposed. (OSHA, however, has made
nonsubstantive, clarifying changes to
final Table V–1.)
125 These requirements are also contained in the
latest edition, ASTM F887–12e1, in Section 15.3.2
and 15.3.3.
126 This requirement is also contained in the
latest edition, ASTM F887–12e1, in Section 15.3.4.
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Paragraph (b)(2)(viii), which is being
adopted without substantive change
from the proposal, requires the cushion
part of a body belt to be at least 76
millimeters (3 inches) wide, with no
exposed rivets on the inside. This
requirement is equivalent to existing
§ 1926.959(b)(2)(i) and (ii).
Existing § 1926.959(b)(2)(iii), which
requires the cushion part of the body
belt to be at least 0.15625 inches thick
if made of leather, was omitted from the
final rule. The strength of the body belt
assembly, which this existing provision
addresses, is now adequately addressed
by the performance-based strength
criteria specified in final
§ 1926.954(b)(2)(xii) (discussed later in
this section of the preamble).
Additionally, as noted previously, loadbearing portions of the body belt may no
longer be constructed of leather alone
under paragraph (b)(2)(v) of the final
rule.
Paragraph (b)(2)(ix), which is being
adopted without substantive change
from the proposal, requires that tool
loops on a body belt be situated so that
the 100 millimeters (4 inches) at the
center of the back of the body belt
(measured from D ring to D ring) are free
of tool loops and other attachments.
OSHA based this requirement on ASTM
F887–04, Section 14.4.3, which is
similar to existing § 1926.959(b)(3). This
requirement will prevent spine injuries
to employees who fall onto their backs
while wearing a body belt, which could
happen to an employee walking on the
ground before or after climbing a pole.
Existing § 1926.959(b)(2)(iv) requires
body belts to contain pocket tabs for
attaching tool pockets. ASTM F887–04
also contained a requirement that body
belts have pocket tabs. In the proposal,
OSHA stated that it did not consider
provisions regarding pocket tabs to be
necessary for the protection of
employees; the Agency believed that
these requirements ensured that body
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belts were suitable as tool belts, but did
not contribute significantly to the safety
of employees (70 FR 34851).
ASTM Committee F18 on Electrical
Protective Equipment for Workers
clarified the purpose of the
requirements for pocket tabs in the
consensus standard as follows:
[Pocket tabs are] addressed in ASTM F887–
04, Section 14.4.1[127] as follows: ‘‘The belt
shall have pocket tabs extending at least 11⁄2″
(3.8 cm) down, and with the point of
attachment at least 3 in. (7.6 cm) back of the
inside of the circle dee rings on each side for
the attachment of pliers or tool pockets. On
shifting dee belts, the measurement for
pocket tabs shall be taken when the dee ring
section is centered.’’
*
*
*
*
*
The primary reason for the specific
placement of these pocket tabs is to assist in
eliminating the interference of tools being
carried on the belt with the proper
engagement of a positioning strap snaphook
into the body belt dee ring.
Therefore, this detail is important for the
safety of employees using these body belts.
[Ex. 0148]
The committee recommended that
OSHA either adopt the ASTM language
or incorporate it by reference.
OSHA does not believe that pocket
tabs are a hazard. The tabs are flush
with the body belt and extend down
from it. They do not interfere with the
attachment of snaphooks to the D rings.
OSHA agrees that tool pockets fastened
to the tabs, or the tools in those pockets,
could interfere under certain conditions.
For example, a large tool or pocket
could interfere with the attachment of
snaphooks and D rings even with the
tabs positioned as required by the
consensus standard. The Agency
believes that this hazard is better
addressed by the general requirement in
final paragraph (b)(3)(i) (discussed later
in this section of the preamble) that
work-positioning equipment be
127 Section 14.3.1 in ASTM F887–12e1 contains
an identical requirement.
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inspected to ensure that it is in safe
working condition before use. In
addition, the ASTM committee did not
explain why tabs are necessary in the
first place. Therefore, OSHA is not
adopting the committee’s
recommendation to add the ASTM
requirement on pocket tabs in the final
rule.
Existing § 1926.959(b)(3) permits a
maximum of four tool loops on body
belts. As explained in the preamble to
the proposal, OSHA does not believe
that this provision is necessary for the
protection of employees (70 FR 34851).
Like existing § 1926.959(b)(2)(iv), this
requirement ensures only that body
belts are suitable as tool belts. OSHA
received no comments on the proposed
removal of this requirement, and the
final rule removes this requirement from
subpart V.128
Paragraph (b)(2)(x), which is being
adopted without change from the
proposal, requires copper, steel, or
equivalent liners to be used around the
bars of D rings. This provision, which
duplicates existing § 1926.959(b)(4), will
prevent wear between the D ring and the
body belt fabric. Such wear could
contribute to failure of the body belt
during use.
In paragraph (b)(2)(xi), OSHA
proposed that snaphooks used as part of
work-positioning equipment be of the
locking type. A snaphook has a keeper
designed to prevent the D ring to which
it is attached from coming out of the
opening of the snaphook. (See Figure 1.)
However, if the design of the snaphook
is not compatible with the design of the
D ring, the D ring can roll around, press
open the keeper, and free itself from the
snaphook. (See Figure 2.)
128 Existing § 1926.959(b)(3) also requires the 100millimeter (4-inch) section of the body belt in the
middle of the back to be free of tool loops and other
attachments. This portion of the existing paragraph
is retained as § 1926.954(b)(2)(ix) in the final rule,
as described previously.
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For many years, ASTM F887 had a
requirement that snaphooks be
compatible with the D rings with which
they were used. Even with this
requirement, however, accidents
resulting from snaphook roll-outs still
occurred. As OSHA explained in the
preamble to the proposal, several factors
account for this condition (70 FR
34852). First, while one manufacturer
can (and most do) thoroughly test its
snaphooks and its D rings to ensure
‘‘compatibility,’’ no manufacturer can
test its hardware in every conceivable
combination with other manufacturers’
hardware, especially since some models
of snaphooks and D rings are no longer
manufactured. While an employer might
be able to test all of the different
hardware combinations with its existing
equipment, the employer normally does
not have the expertise necessary to
conduct such tests in a comprehensive
manner. Second, snaphook keepers can
be depressed by objects other than the
D rings to which they are attached. For
example, a loose guy (a support line)
could fall onto the keeper while an
employee is repositioning himself or
herself. This situation could allow the D
ring to escape from the snaphook, and
the employee would fall as soon as he
or she leaned back into the workpositioning equipment. The lockingtype snaphooks OSHA proposed to
require will not open unless employees
release the locking mechanisms.
A few commenters objected to the
requirement for locking snaphooks,
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maintaining that existing pole straps
with nonlocking snaphooks have been
used safely and effectively for many
years. (See, for example, Exs. 0210,
0225.) Mr. Jonathan Glazier with the
National Rural Electric Cooperative
Association (NRECA) questioned the
safety benefits of locking snaphooks,
commenting:
Is the cost of replacing the thousands of
non-locking snaphooks in use today
outweighed by the benefit? Certainly workers
are familiar with the rudimentary technology
presented by non-locking snaphooks, so the
danger they present is low. [Ex. 0233]
A majority of the rulemaking
participants who commented on this
issue agreed that the proposed
requirement for locking snaphooks was
justified. (See, for example, Exs. 0167,
0169, 0213; Tr. 579.) For instance,
Quanta Services commented that ‘‘the
current requirement [to use] snaphooks
compatible with the particular D rings
with which they are used is not
sufficient because accidents from
snaphook rollover still occur’’ and
agreed with OSHA that the proposal to
require locking snaphooks ‘‘will provide
greater protection’’ (Ex. 0169).
Snaphook rollout is a recognized
hazard, as indicated by updated
requirements in the consensus standard.
The ASTM committee believed that the
former requirement for compatibility
between snaphooks and D rings was
inadequate to protect employees; thus,
the committee included a requirement
for locking snaphooks in ASTM F887–
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04 (Ex. 0055). Evidence in the record
indicates that the committee was
correct; one exhibit showed that two
workers were killed when the
snaphooks they were using apparently
rolled out (Ex. 0003).129 OSHA
considered the record on this issue and
concluded that the proposed
requirement for locking snaphooks is
justified; therefore, the Agency is
including the proposed provision in the
final rule.
Mr. Lee Marchessault with Workplace
Safety Solutions recommended that the
term ‘‘double locking type’’ be used
rather than ‘‘locking type’’ (Ex. 0196; Tr.
579). His comment addressed the
reference to locking snaphooks in
proposed paragraph (b)(3)(vi) (discussed
later in this section of the preamble),
but, because paragraph (b)(2)(xi)
contains the requirement that
snaphooks on positioning straps be of
the locking type, his comment applies
equally here.
The devices specified in the standard
are ‘‘locking snaphooks.’’ They are also
known as ‘‘double-locking snaphooks.’’
However, this latter term is a misnomer.
There is only a single locking
mechanism. The keeper, which ‘‘keeps’’
the snaphook on the D ring, is not selflocking. Consequently, these devices are
correctly known as ‘‘locking
129 Descriptions of these two accidents can be
viewed at: https://www.osha.gov/pls/imis/
accidentsearch.accident_
detail?id=922336&id=14340061.
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snaphooks,’’ and OSHA is using this
term in the final rule.
In issuing the proposal, OSHA
recognized that there might be
thousands of existing nonlocking
snaphooks currently in use and
requested comment on whether it
should phase in the requirement for
locking snaphooks for older equipment
or allow employers to continue using
existing equipment that otherwise
complies with the standard until it
wears out and must be replaced.
Several commenters recommended
grandfathering existing equipment and
requiring that only newly purchased
positioning straps be equipped with
locking snaphooks. (See, for example,
Exs. 0162, 0175, 0210, 0224, 0225, 0227,
0233.) For instance, the Virginia,
Maryland & Delaware Association of
Electric Cooperatives commented:
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[G]randfathering existing equipment for
those companies that have not started
utilizing locking snap-hooks is prudent. For
companies currently using older equipment,
the requirement should be that as the older
equipment is phased out or worn out, new
equipment must be the locking snap-hook
type. [Ex. 0175]
In addition, Mr. Glazier with NRECA
was concerned that requiring an
immediate switch to locking snaphooks
could lead to a shortage of compliant
equipment (Ex. 0233).
Other commenters argued that there
should be little or no phase-in period
because nonlocking snaphooks have not
been available for over 10 years and
because employees would be left at risk.
(See, for example, Exs. 0148, 0199,
0212.) TVA commented that it had
‘‘prohibited nonlocking snaphooks for a
number of years’’ before OSHA’s
proposal (Ex. 0213). The Southern
Company and ASTM Committee F18
recommended a phase-in period of no
more than 12 months (Exs. 0148, 0212).
Buckingham Manufacturing Company
recommended a phase-in period of no
more than 3 months (Ex. 0199).
According to the ASTM committee,
manufacturers stopped producing
nonlocking snaphooks before 1998 (Ex.
0148). In addition, evidence in the
record indicates that the average useful
life of a body belt or body harness is 5
years (Ex. 0080). The Agency believes
that the useful life of positioning straps
(to which snaphooks are affixed) also is
approximately 5 years because they are
made from the same materials and are
subject to the same conditions of use.
Thus, any nonlocking snaphooks still
remaining in use are substantially
beyond their expected useful life and
are probably in need of replacement. In
addition, there is evidence in the record
that the vast majority of positioning
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straps in use already have locking
snaphooks. Mr. James Tomaseski of
IBEW testified that, based on a survey
of the union’s members, 80 percent of
electric utilities and contractors
performing work covered by the final
rule require the use of locking
snaphooks (Tr. 976). He also testified
that locking snaphooks are used even by
companies that do not require them and
that there will not be a problem with
availability (Tr. 975–976). Therefore,
OSHA concludes that a phase-in period
of 90 days should be adequate to
comply with the requirement.
Compliance with paragraph (b)(2)(xi) is
required on the effective date of the
final rule: July 10, 2014.
OSHA proposed three requirements
for locking snaphooks to ensure that
keepers do not open without employees
intentionally releasing them. First, for
the keeper to open, a locking
mechanism would have to be released,
or a destructive force would have to be
impressed on the keeper (paragraph
(b)(2)(xi)(A)). Second, a force in the
range of 6.7 N (1.5 lbf) to 17.8 N (4 lbf)
would be required to release the locking
mechanism (paragraph (b)(2)(xi)(B)).
Third, with a force on the keeper and
the locking mechanism released, the
keeper must be designed not to open
with a force of 11.2 N (2.5 lbf) or less,
and the keeper must begin to open
before the force exceeds 17.8 N (4 lbf)
(paragraph (b)(2)(xi)(C)).130 These
requirements are based on ASTM F887–
04, section 15.4.1.131 Proposed
paragraph (b)(2)(xi)(C), relating to the
spring tension on the keeper, was
equivalent to existing § 1926.959(b)(6).
Mr. Daniel Shipp with ISEA objected
to these proposed requirements and
maintained that the provisions on workpositioning equipment should be
consistent with § 1910.66 (Powered
platforms for building maintenance),
Appendix C, and § 1926.502 (Fall
protection systems criteria and
practices), commenting:
Neither of these [existing] standards set
forth detailed specifications for the forces
required to actuate the locking and gate
mechanisms of snaphooks. The determining
factors that relate most closely to incidents of
accidental disengagement of a snaphook from
its connector are (a) the compatibility in size
and shape of the connecting element, and (b)
the tensile strength of the gate in the closed
and locked position, which are fully
discussed in 1910.66 and 1926.502. It is
difficult to envision one range of force
130 In proposed paragraphs (b)(2)(xi)(B) and
(b)(2)(xi)(C), the metric units were not equal to the
English units. The metric units were corrected in
the final rule.
131 These requirement are also contained in the
latest edition, ASTM F887–12e1, in Section 15.4.2.1.
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20393
requirements that would apply equally to all
locking snaphooks because of the wide
variety of existing and possible snaphook
designs.
OSHA should limit its regulation of selfclosing and self-locking snaphooks to use in
work positioning applications that follow
existing fall protection regulations. The
addition of further restrictive requirements
will have the effect of possibly eliminating
otherwise safe and efficient equipment from
the marketplace without any demonstrable
improvement in worker safety. [Ex. 0211]
It is not clear from Mr. Shipp’s
comment whether he opposes the
requirement that snaphooks be of the
locking type. If he does, there is ample
evidence in the record, as discussed
previously, to support the adoption of a
requirement for locking snaphooks.
Therefore, the Agency will focus on his
comments relating to the forces used to
unlock and open keepers. The proposed
paragraphs ensure the adequacy of the
locking mechanism by requiring a
destructive force to open the keeper if
it is not first unlocked and by specifying
the minimum force required to open the
locking mechanism. The proposed
paragraphs also ensure that the keeper
does not open unintentionally if the
locking mechanism is opened
accidentally (for example, by a loose
conductor striking it), or if it breaks.
In addition to specifying minimum
forces, the proposed paragraphs
specified the maximum forces necessary
to open the locking mechanism and the
keeper when the locking mechanism is
open. Because this equipment is
frequently used with rubber insulating
gloves and leather protectors, employees
have limited dexterity when they are
opening and closing keepers (Ex. 0173).
Snaphook keepers that are too difficult
to unlock or open by employees wearing
rubber insulating gloves could interfere
with connecting a snaphook to a D ring
and lead to falls. In addition, employees
develop a rhythm, buckling and
unbuckling the positioning straps into
the D rings of their body belts (see, for
example, 269–Ex. 3–11). Snaphook
keepers that are too difficult to unlock
or open will interfere with this rhythm,
potentially leading to falls. These
conditions are not present for
employees working from power
platforms covered by § 1910.66 or in
general construction work covered by
§ 1926.502.
As noted previously, existing subpart
V already requires the opening force on
the keeper to be within the range
specified in the proposal. Also, the
inclusion of similar provisions in ASTM
F887 is evidence that the ASTM
committee concluded that there is a
need for the requirements proposed in
paragraph (b)(2)(xi). For these reasons,
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OSHA is including paragraphs
(b)(2)(xi)(A), (b)(2)(xi)(B), and
(b)(2)(xi)(C) in the final rule as
proposed. (As previously noted, OSHA
has corrected the metric units in these
provisions in the final rule.)
Mr. Frank Owen Brockman of Farmers
Rural Electric Cooperative Corporation
recommended that OSHA prohibit the
use of any snaphook that requires
employees to remove gloves before
opening the snaphook (Ex. 0173). As
noted earlier, the objective performance
requirements in paragraph (b)(2)(xi) will
ensure that snaphooks meeting the
standard are usable by employees
wearing rubber insulating gloves and
leather protectors. The Agency does not
believe that adding a requirement that
snaphooks be capable of being opened
by an employee wearing gloves will
improve the safety of these devices.
OSHA believes, however, that
employers will consider this facet of
snaphook design when selecting
positioning straps, if only to minimize
employee complaints.
Existing § 1926.959(b)(7) requires
body belts, safety straps, and lanyards to
be capable of passing a drop test in
which a test load is dropped from a
specific height and the equipment
arrests the fall. The test consists of
dropping a 113.4-kg (250-lbm) bag of
sand a distance of either 1.2 meters (4
feet) or 1.8 meters (6 feet), for safety
straps and lanyards, respectively.132
OSHA explained in the preamble to
the proposal that ASTM adopted a
different test in ASTM F887–04 (70 FR
34853). Under the existing OSHA test,
the bag of sand can be fitted with the
body belt in different ways, resulting in
tests that are not necessarily consistent
among different testing laboratories. To
overcome this problem, ASTM 887–04
adopted a drop test that uses a rigid
steel mass of a specified design. To
compensate for differences between a
rigid mass and the more deformable
human body, the ASTM standard uses
a lower test mass, 100 kg (220 lbm), and
a shorter drop height, 1 meter (39.4
inches). OSHA proposed to replace the
drop test in existing § 1926.959(b)(7)
with a test modeled on the test specified
in the 2004 ASTM standard.133
Proposed paragraph (b)(2)(xii)(A)
would have required the test mass to be
rigidly constructed of steel or equivalent
material having a mass of 100 kg (220.5
lbm). OSHA explained in the proposal
that this mass was comparable to the
113.4-kg (250-lbm) bag of sand that must
be used under the existing OSHA
standard (70 FR 34853). Even though
the proposed test mass was lighter than
a heavy power line worker, OSHA
explained that the proposed test method
would place significantly more stress on
the equipment than an employee of the
same mass because the test drop was
greater than the maximum permitted
free-fall distance and because the test
mass was rigid (id.).
Proposed paragraphs (b)(2)(xii)(B) and
(b)(2)(xii)(C) specified the means used to
attach body belts and positioning straps
during testing. These provisions would
ensure that the work-positioning
equipment being tested was properly
attached to the test apparatus.
Proposed paragraph (b)(2)(xii)(D)
provided for the test mass to be dropped
an unobstructed distance of 1 meter
(39.4 inches). OSHA explained in the
preamble that, for positioning straps,
this distance was equivalent (given the
rigid test mass) to the existing
standard’s test distance of 1.2 meters (4
feet) (70 FR 34853).
Proposed paragraphs (b)(2)(xii)(E) and
(b)(2)(xii)(F) specified the following
acceptance criteria for tested equipment:
(1) Body belts would have had to arrest
the fall successfully and be capable of
supporting the test mass after the test,
and (2) positioning straps would have
had to successfully arrest the fall
without breaking or allowing an
arresting force exceeding 17.8
kilonewtons (4,000 pounds-force).
Additionally, the proposal provided that
snaphooks on positioning straps not
distort sufficiently to allow release of
the keeper.
OSHA requested comment on
whether the proposed test was
reasonable and appropriate and, more
specifically, whether the requirement
for a rigid test mass of 100 kg (220.5
lbm) dropped a distance of 1 meter (39.4
inches) was sufficiently protective.
Most rulemaking participants who
commented on this issue supported the
proposed requirements. (See, for
example, Exs. 0126, 0199, 0230.) For
instance, IBEW commented:
132 As noted earlier, existing § 1926.959 covers
body belts, safety straps, and lanyards as both fall
arrest and work-positioning equipment. Paragraph
(b)(2) of final § 1926.954 covers only workpositioning equipment. Lanyards, which are used in
fall arrest and are not covered in final
§ 1926.954(b)(2), have to be capable of withstanding
higher forces as required by § 1926.502(d)(9).
133 ASTM F887–12e1 specifies equivalent test
procedures and criteria for this equipment.
This change has been accepted in the
ASTM standard. The ASTM Technical
Subcommittee realized more consistent
results were necessary, and therefore,
through experimentation with different test
methods, developed the test method using a
specific design of a rigid steel mass. OSHA
should recognize this test method as the best
industry practice. [Ex. 0230]
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Two commenters noted that the test
mass specified in the proposed rule was
adequate for workers weighing up to
140 kg (310 lbm) (Exs. 0199, 0211). Mr.
James Rullo of Buckingham
Manufacturing explained:
The standard conversion factor used in the
industry for the sand bag to steel mass is 1.4
which when applied to the 220.5 lbm equates
to 310 lbm. That would seem to cover the
general range of line workers. In addition, the
straight drop with the wire cable imposes
forces on the equipment which we believe to
be more severe than most falls that might be
experienced by line workers. [Ex. 0199]
Mr. Daniel Shipp with ISEA supported
the proposal’s requirement for testing
with a 100-kg rigid test mass, but
recommended a modification for
workers weighing more than 140 kg:
ISEA supports the change to a test mass of
rigid steel construction, weighing 100 kg (220
lb). Our members’ experience in testing fall
protection products leads us to conclude that
the rigid mass will produce more repeatable
results than testing with a sand-filled bag.
However, we believe the 100 kg test mass
should only be sufficient to qualify products
for use by employees with a maximum body
weight up to 140 kg (310 lb). For employees
with weights greater [than] 140 kg (310 lb),
including body weight, clothing, tools and
other user-borne objects, the test should be
modified to increase the test mass
proportionately greater than 100 kg (220 lb).
For example, for a worker with an all-up
weight of 160 kg (354 lb), the test mass
should be increased to 114 kg (251 lb). [Ex.
0211]
The ASTM committee and the fallprotection equipment-manufacturing
industry recognize the proposed tests as
being reasonable and adequate. As some
of the commenters noted, the proposed
test mass will impose sufficient stress
on work-positioning equipment for a
worker weighing 140 kg (310 lbm),
including tools and equipment.
However, OSHA concludes that the
proposed test is insufficiently protective
for workers weighing more than 140 kg
when fully equipped. Therefore, the
Agency is adopting paragraph
(b)(2)(xii)(A) as proposed, except that
the final rule requires work-positioning
equipment used by employees with an
equipped weight of more than 140 kg to
be capable of passing the same test, but
with a test mass of proportionally
greater mass (that is, the test mass must
equal the mass of the equipped worker
divided by 1.4). With this change, the
final rule will ensure that workpositioning equipment will adequately
protect even the heaviest workers.
OSHA believes that, if any equipped
worker has a mass greater than 140 kg,
the employer will order workpositioning equipment that is adequate
for the increased mass and that
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manufacturers will supply workpositioning equipment that has been
tested with a mass that conforms to the
standard.
In the final rule, OSHA is adopting
the remaining provisions in
§ 1926.954(b)(2)(xii), namely paragraphs
(b)(2)(xii)(B) through (b)(2)(xii)(F),
without substantive change from the
proposal.
OSHA proposed three notes to
paragraph (b)(2). The first note indicated
that paragraph (b)(2) applies to all workpositioning equipment used in work
covered by subpart V. The Agency is not
including this note in the final rule as
it is unnecessary.
The Ohio Rural Electric Cooperatives
suggested that, instead of the specific
provisions proposed in paragraph (b)(2),
the standard require only that belts be
certified to ASTM F887–04 (Ex. 0186).
A note to final paragraph (b)(2) (Note 2
in the proposal), which appears after
final paragraph (b)(2)(xii)(F), provides
that, when used by employees weighing
no more than 140 kg (310 lbm) fully
equipped, body belts and positioning
straps that conform to ASTM F887–
12 e1, the most recent edition of that
standard, are deemed to be in
compliance with paragraph (b)(2). This
note clearly informs employers that
body belts and positioning straps
meeting that consensus standard also
meet the testing requirements in
OSHA’s final rule. To avoid confusion,
the Agency removed the phrase ‘‘the
manufacturing and construction
requirements of,’’ which modified
‘‘paragraph (b)(2) of this section’’ and
which appeared in the proposal, from
the language of this note in the final
rule. The purpose of this phrase was to
describe the contents of paragraph (b)(2)
rather than restrict the application of the
note. The Agency restricted the
application of the note in the final rule
to body belts and safety straps used by
employees weighing no more than 140
kg (310 lbm), as the ASTM standard
does not address this aspect of the final
rule.134
Note 2 in the proposal provided that
work-positioning equipment meeting
the consensus standard also needed to
meet proposed paragraphs (b)(2)(iv),
which specified tensile testing for
snaphooks, and (b)(2)(xi), which
required snaphooks to be of the locking
type. ASTM Committee F18 stated that
ASTM F887–04 contained nearly
identical requirements and suggested
that the note omit references to those
134 Body belts and safety straps that meet ASTM
F887–12e1, but with the test weight adjusted as
required by § 1926.954(b)(2)(xii)(A), will be deemed
to be in compliance with final § 1926.954(b)(2).
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two proposed paragraphs (Ex. 0148).
OSHA agrees that ASTM F887–04
adequately covered all the requirements
in final paragraph (b)(2), and OSHA
removed the two referenced paragraphs
(paragraphs (b)(2)(iv) and (b)(2)(xi))
from the note in the final rule. In
addition, the Agency reviewed the latest
edition of the ASTM standard, ASTM
F887–12e1, and found that it also
adequately addresses all of the design
requirements in the final rule.
Consequently, the note in the final rule
states that, when used by employees
weighing no more than 140 kg (310 lbm)
fully equipped, body belts and
positioning straps meeting this later
edition of the consensus standard will
be deemed as complying with paragraph
(b)(2).
OSHA also proposed a third note to
paragraph (b)(2) indicating that body
belts and positioning straps meeting
§ 1926.502(e) on positioning device
systems would be deemed to be in
compliance with the manufacturing and
construction requirements of paragraph
(b)(2) of proposed § 1926.954, provided
that the equipment also conformed to
proposed paragraph (b)(2)(vii), which
contained provisions addressing
electrical and flame-resistance tests for
positioning straps, as well as
requirements for positioning straps to be
capable of withstanding a tension test
and a buckle-tear test. The preamble to
the proposal explained that body belts
and positioning straps that are parts of
positioning device systems addressed by
§ 1926.502(e) serve the same function as
work-positioning equipment used for
work covered by subpart V (70 FR
34853). OSHA originally believed that
body belts and positioning straps that
met the design criteria specified by
§ 1926.502(e), as well as the provisions
in proposed § 1926.954(b)(2)(vii), would
generally be sufficiently strong for
power line work.
OSHA reexamined the need for, and
appropriateness of, proposed Note 3 to
§ 1926.954(b)(2) in light of the
rulemaking record for subpart V. As
indicated by Mr. Daniel Shipp with
ISEA, § 1926.502(e) does not contain
requirements comparable to those in
final § 1926.954(b)(2)(xi)(B) and
(b)(2)(xi)(C) for the minimum and
maximum opening and closing forces
for snaphook keepers and locking
mechanisms. As explained in the
discussion of final § 1926.954(b)(2)(xi)
earlier in this section of the preamble,
OSHA believes that snaphooks must
meet these performance requirements to
be adequately protective in the
conditions encountered by employees
performing work covered by Subpart V.
In addition, § 1926.502(e) does not
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contain requirements comparable to
several other provisions of final
§ 1926.954(b)(2), including those
prohibiting leather in load-bearing
components of body-belt and
positioning-strap assemblies (paragraph
(b)(2)(v)), prohibiting tool loops in the
center 100 millimeters (4 inches) of the
back of a body belt (paragraph
(b)(2)(ix)), and requiring a maximum
arresting force during the drop test
(paragraph (b)(2)(xii)(F)). OSHA believes
that these also are important
requirements necessary for the safety of
employees performing work covered by
Subpart V. Consequently, OSHA is not
including Note 3 to proposed
§ 1926.954(b)(2) in the final rule.
Some commenters were concerned
that the proposal required the tests in
paragraph (b)(2) to be conducted by the
employer. (See, for example, Exs. 0169,
0175, 0186.) OSHA notes that the final
rule states that work-positioning
equipment must be ‘‘capable’’ of passing
these tests. The tests in the final rule
could be performed by the manufacturer
on samples that are representative of the
finished product. However, it will be
the employer’s responsibility to ensure
that it selects, and has its employees
use, a type of equipment that has been
subject to adequate testing by the
manufacturer. The final rule does not
require employers to conduct the tests
specified by paragraph (b)(2) when the
manufacturer conducts such testing.
Employers will be able to determine, in
most instances, whether workpositioning equipment meets the OSHA
standard simply by ensuring that the
manufacturer has tested the equipment
in accordance with the OSHA standard
or ASTM F887–12 e1. The tests required
by paragraph (b)(2) are potentially
destructive and should never be
performed on work-positioning
equipment that will be used by
employees (Exs. 0055, 0072).
Paragraph (b)(3) addresses the care
and use of fall protection equipment. As
OSHA explained in the preamble to the
proposal, fall protection equipment
provides maximum protection only
when it is properly used and
maintained (70 FR 34853). Existing
§ 1926.951(b)(3) requires this equipment
to be inspected each day before use.
OSHA believed that this requirement
had to be supplemented by additional
requirements to protect employees fully
from fall hazards posed by electric
power transmission and distribution
work and, therefore, proposed to add
requirements to subpart V, borrowed
from existing § 1910.269(g)(2) and
§ 1926.502(d) and (e), regulating the care
and use of fall protection equipment.
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Paragraph (b)(3)(i) requires the
employer to ensure that workpositioning equipment is inspected
before use each day to determine if it is
in safe working condition. (Paragraph
(d)(21) of § 1926.502 already contains a
similar requirement for fall arrest
equipment that applies, and will
continue to apply, to work covered by
Subpart V.) Paragraph (b)(3)(i) also
prohibits the use of work-positioning
equipment that is not in safe working
condition. The proposal was worded to
prohibit the use of ‘‘defective
equipment.’’ OSHA replaced this term
in the final rule with ‘‘equipment that
is not in safe working condition’’ and
added ‘‘work-positioning’’ before
‘‘equipment’’ to clarify that this
provision applies to any condition that
would make work-positioning
equipment unsafe. This language also
makes it consistent with the
requirement in this paragraph to inspect
the equipment to determine if it is in
‘‘safe working condition.’’ This
paragraph ensures that protective
equipment will be capable of protecting
employees when needed. This
requirement is similar to existing
§ 1926.951(b)(3), except that the
prohibition on the use of unsafe
equipment is now stated explicitly. A
thorough inspection of fall protection
equipment can detect defects such as
cracked snaphooks and D rings, frayed
lanyards, loose snaphook keepers, and
bent buckles. A note to this paragraph
states that a guide to the inspection of
this equipment is included in Appendix
F.
Paragraph (b)(3)(ii) requires personal
fall arrest systems to be used in
accordance with § 1926.502(d).
Paragraph (d)(21) of § 1926.502
provides: ‘‘Personal fall arrest systems
shall be inspected prior to each use for
wear, damage and other deterioration,
and defective components shall be
removed from service.’’ Removing
‘‘defective’’ equipment from service in
accordance with § 1926.502(d)(21) will
ensure that employees are not using fall
arrest equipment that is not in safe
working condition.135
OSHA explained in the proposal that
personal fall arrest equipment is
sometimes used as work-positioning
equipment such that the employee can
135 Subpart M, Appendix C, section II, paragraph
(g) provides examples of defects that require
removing equipment from service. Such defects
include cuts, tears, abrasions, mold, or undue
stretching; alterations or additions which might
affect the efficiency of the equipment; damage due
to deterioration; contact with fire, acids, or other
corrosives; distorted hooks or faulty hook springs;
tongues unfitted to the shoulder of buckles; loose
or damaged mountings; nonfunctioning parts; or
wearing or internal deterioration in the ropes.
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lean into the body harness and perform
work (70 FR 34854). In this scenario, the
normal attachment point would be at
waist level. Paragraph (d)(17) of
§ 1926.502 requires the attachment
point for body harnesses to be located
in the center of the employee’s back
near shoulder level or above his or her
head. As the Agency explained in the
preamble to the proposal, such an
attachment could prevent the employee
from performing his or her job while the
employee is using work-positioning
equipment (id.), so OSHA proposed to
exempt fall arrest equipment used as
work-positioning equipment from this
requirement if the equipment was rigged
so that the maximum free-fall distance
was no greater than 0.6 meters (2 feet).
Mr. Daniel Shipp with ISEA agreed
with the proposal, commenting:
ISEA agrees with the proposed change to
allow frontal-attachment for personal fall
arrest on equipment that is used for work
positioning, with a maximum permissible
free fall distance of 0.6 m (2 ft). [Ex. 0211]
OSHA reconsidered including this
exception in the regulatory text of
paragraph (b)(3)(ii) and concluded that
it is unnecessary. Fall arrest equipment
that is rigged for work positioning is
considered to be work-positioning
equipment for the purposes of final
§ 1926.954(b). When fall protection
equipment is rigged for work
positioning, the equipment must meet
the requirements in paragraph (b) that
apply to work-positioning equipment,
and the provisions that apply to fall
arrest systems, including the anchorage
requirement in § 1926.502(d)(17), are
not applicable. When fall protection
equipment is rigged to arrest falls, the
equipment is considered to be a fall
arrest system, and the provisions for
those systems apply. OSHA included a
note to paragraph (b)(3)(ii) to clarify this
point.
In paragraph (b)(3)(iii), OSHA
proposed to require the use of a
personal fall arrest system or workpositioning equipment by employees
working at elevated locations more than
1.2 meters (4 feet) above the ground on
poles, towers, and similar structures if
other fall protection has not been
provided. As OSHA clarified in the
proposal, the term ‘‘similar structures’’
includes any structure that supports
electric power transmission or
distribution lines or equipment, such as
lattice substation structures and H-frame
wood transmission structures (70 FR
34854). A similar requirement is in
existing § 1910.269(g)(2)(v). (In existing
§ 1926.951(b)(1), OSHA requires fall
protection for ‘‘employees working at
elevated locations,’’ but does not specify
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a height at which such protection
becomes necessary.) Note 1 to proposed
paragraph (b)(3)(iii) indicated that these
fall protection requirements did not
apply to portions of buildings, electric
equipment, or aerial lifts, and referred to
the relevant portions of the construction
standards that do apply in those
instances (that is, subpart M for walking
and working surfaces generally and
§ 1926.453 for aerial lifts).136
Many rulemaking participants
commented on the proposed
requirement to use fall protection
starting at 1.2 meters (4 feet) above the
ground. (See, for example, Exs. 0173,
0183, 0186, 0196, 0202, 0210, 0219,
0229, 0233, 0239; Tr. 575–576.) Two
commenters recommended that Subpart
V mirror the Subpart M ‘‘6-foot rule,’’ in
other words, that fall protection not be
required until an employee is 1.8 meters
(6 feet) or more above the ground (Exs.
0196, 0219; Tr. 575–576). Lee
Marchessault with Workplace Safety
Solutions commented:
[The proposal] requires fall protection
when working at heights greater than 4 feet,
however the referrence [sic] to 1926 subpart
M requires 6 feet and therefore the fall
protection system is designed to engage at
distances not more than 6 feet. This renders
the system useless for a 5 foot fall in some
cases. An example may be working on a trash
platform of a hydro generation facility
cleaning racks that are 4.5 feet off the lower
walking surface. A fall restraint system works
best, but workers are allowed to use a harness
and 6 foot lanyard. [Ex. 0196]
Mr. Marchessault suggested in
testimony at the 2006 public hearing
that using different length lanyards for
different jobs would not be feasible (Tr.
576). The Virginia Maryland & Delaware
Association of Electric Cooperatives
commented that it did not see a need for
OSHA to set any height threshold for
fall protection in the standard,
explaining: ‘‘Line work is inherently
different than other occupations with
climbing a necessary skill required in
the trade. Therefore, specification of a
distance does not add additional safety
to the employee’’ (Ex. 0175).
Other commenters supported the
proposed 1.2-meter height or stated that
it generally has not presented problems
since it was adopted in existing
§ 1910.269. (See, for example, Exs. 0186,
0211, 0213, 0230.) IBEW commented
that ‘‘[t]he 1910.269 requirement [for
fall protection starting at] 1.2 meters (4
feet) has proven not [to] be problematic.
The addition of 2 feet will not offer
anything to the requirement’’ (Ex. 0230).
136 As noted earlier, the corresponding note in the
final rule does not pertain to fall protection for
employees in aerial lifts or reference § 1926.453.
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Most of the comments relating to the
starting height for fall protection were
from electric cooperatives or their
representatives who recommended that
OSHA not require fall protection until 3
meters (10 feet) above the ground for
employees who are undergoing training.
(See, for example, Exs. 0183, 0186,
0202, 0210, 0229, 0233, 0239.) For
instance, Mr. Anthony Ahern of Ohio
Rural Electric Cooperatives commented:
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[F]or training purposes it would be nice to
have the option of going to 10 feet without
fall protection . . . under close supervision.
At a height of only 4 [feet] a climber really
does not get a sense of height. Using fall
arrest equipment at higher levels gives the
new climber a false sense of security, can
hinder mobility and make it more difficult to
move around the pole. Being able to work
new climbers up to 10 [feet] after
demonstrating basic abilities at lower levels
would give the new climber a better sense of
working at heights and make it easier for
trainers to determine which [climbers] need
additional training or who simply can not
handle working on a pole. [Ex. 0186]
NRECA maintained that ‘‘in the highlysupervised and specially-equipped
environment of linemen training, the
extra height adds very little, if any extra
danger’’ (Ex. 0233).
As previously noted, the current
requirement in § 1910.269(g)(2)(v) for
fall protection starts at 1.2 meters (4
feet), and multiple commenters
indicated that this provision is not
causing problems. (See, for example,
Exs. 0186, 0230.) Adjustable-length
lanyards, retractable lanyards, and
work-positioning equipment can serve
to accommodate the varying heights at
which an employee will be working (Ex.
0211). In addition, the relevant
paragraph in the final rule
(§ 1926.954(b)(3)(iii)(B)) does not apply
to the example provided by Mr.
Marchessault (the ‘‘trash platform of a
hydro generation facility’’), as such
work locations are not ‘‘poles, towers, or
similar structures.’’ OSHA is not
persuaded by the speculation that
employees undergoing training
experience a ‘‘false sense of security’’ or
that employees using fall protection
cannot be successfully trained in the use
of free-climbing techniques. Employees
undergoing training can use
combination body belt-body harness
systems that attach both to a retractable
lanyard anchored to the top of a pole
(for fall arrest) and to a positioning strap
(for work positioning). This arrangement
will ensure protection for the trainees
until they master climbing techniques.
Any sense of security the employee
experiences using such equipment
would not be ‘‘false,’’ but rather would
be based on real protection. There is
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evidence in the record that unprotected
employees in training to climb wood
poles have been injured (Ex. 0003 137).
Several of these employees were
climbing wood poles with wood chips
at the base of the pole. The chips did
not protect the employees, and they
received serious injuries, for which all
but one were hospitalized. OSHA has
previously taken the position that wood
chips do not provide adequate fall
protection for employees, and the
evidence in this rulemaking does not
support a different conclusion. Under
final § 1926.954(b)(3)(iii)(B), employers
must provide employees with
appropriate fall protection when they
are in training to climb wood poles.138
The 1.2-meter threshold provides
additional safety when compared to
higher thresholds. The speed with
which an employee will strike the
ground increases with increasing height.
An extra 0.6 meters (2 feet) in height
increases fall velocity by over 20
percent, substantially increasing the
potential severity of any injuries the
employee receives. An extra 1.8 meters
(6 feet) in height increases fall velocity
by nearly 50 percent. After considering
the comments in the record, OSHA
concluded that the rationales offered by
these commenters do not justify
increasing the severity of the fall hazard
by increasing the height threshold.
Therefore, OSHA is adopting the
proposed requirement for fall protection
to start at 1.2 meters (4 feet) and, for the
reasons described previously, is not
adopting a less protective threshold for
employees undergoing training.
Southern Company suggested that
OSHA reference IEEE Std 1307–2004,
Standard for Fall Protection for Utility
Work, for work on transformers, circuit
breakers, and other large equipment.
That standard requires fall protection at
heights of 3.05 meters (10 feet) and
higher (Ex. 0212).
The duty to provide fall protection for
work on electric equipment, such as
transformers and capacitors, is not in
Subpart V or § 1910.269, but rather in
Part 1926, Subpart M, and Part 1910,
Subpart D, for construction and general
industry, respectively. The application
of Subpart D rather than § 1910.269 to
walking-working surfaces other than
137 See, for example, the descriptions of five
accidents at: https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=170157069&
id=170181432&id=170175269&id=170176630
&id=170204267.
138 As stated in Note 2 to paragraphs (b)(3)(iii)(B)
and (b)(3)(iii)(C), employees who have not
completed training in climbing and the use of fall
protection are not considered ‘‘qualified
employees’’ for the purposes of paragraph
(b)(3)(iii)(C), which permits qualified employees to
climb without fall protection in limited situations.
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20397
poles, towers, and similar structures
was explained in the preamble to the
1994 § 1910.269 final rule (59 FR 4374)
and in letters of interpretation.139 The
consensus standard’s requirement for
fall protection at heights over 3.05
meters conflicts with the more
protective requirements in Subparts M
and D. Also, for reasons noted earlier,
the Agency concluded that an increase
in the 1.2-meter (4-foot) and 1.8-meter
(6-foot) threshold heights for initiating
fall protection in Subparts D and M,
respectively, is not warranted. It should
be noted that IEEE Std 1307 is included
in Appendix G, and employers may find
that it contains useful information on
how to provide fall protection for work
covered by subpart V. However, OSHA
concludes that a nonmandatory
reference to the consensus standard for
a situation to which § 1926.954(b)(3)(iii)
does not apply, as recommended by
Southern Company, would be
inappropriate and misleading. Note 1 to
proposed § 1926.954(b)(3)(iii) stated that
‘‘[t]he duty to provide fall protection
associated with walking and working
surfaces is contained in subpart M of
this part.’’ However, the relevant
portion of existing § 1926.500(a) seems
to indicate otherwise, stating that
requirements relating to fall protection
for employees engaged in the
construction of electric transmission
and distribution lines and equipment
are provided in subpart V (see
§ 1926.500(a)(2)(vi)).
As was clear from Note 1 to proposed
§ 1926.954(b)(3)(iii), OSHA was proposing
that the duty to provide fall protection for
general walking working surfaces, that is,
everything other than aerial lifts and poles,
towers, and similar structures, would be
covered by subpart M. To clarify this point,
in the final rule, OSHA is revising
§ 1926.500(a)(2)(vi) so that the subpart V
exemption applies only to the duty to
provide fall protection for aerial lifts and
poles, towers, and similar structures.
Existing § 1910.269(g)(2)(v) permits
travel-restricting equipment as an
alternative to fall arrest or workpositioning systems. OSHA proposed to
omit the use of travel-restricting
equipment as a recognized fall
protection system for electric power
transmission and distribution work on
poles, towers, and similar structures. In
the preamble to the proposal, the
Agency explained that travel-restricting
equipment is only appropriate for work
139 See, for example, the October 18, 1995, letter
to Mr. Lonnie Bell (https://www.osha.gov/pls/
oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=21981) and the
December 18, 1997, letter to Mr. Dimitrios Mihou
(https://www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=22508).
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on open-sided platforms, where
employees can walk around the working
surface with the travel-restricting
equipment keeping them from
approaching too close to an unguarded
edge (70 FR 34854). When it published
the proposal, the Agency did not believe
that this type of working surface could
be found on poles, towers, or similar
structures (id.). Therefore, OSHA did
not include travel-restricting equipment
as an acceptable fall protection system
in proposed § 1926.954(b)(3)(iii) and
proposed to remove the reference to
travel-restricting equipment in existing
§ 1910.269(g)(2)(v), but invited
comments on this omission.
Many commenters argued that there
are surfaces used in work covered by
Subpart V for which travel-restricting
equipment is appropriate and
recommended that OSHA restore travelrestricting equipment as an alternative
form of fall protection. (See, for
example, Exs. 0126, 0173, 0183, 0201,
0202, 0210, 0225, 0229, 0230, 0233,
0239.) However, few of these
commenters provided specific, relevant
examples. IBEW commented that travelrestricting equipment is sometimes used
when an employee is transferring from
a crossarm to a hook ladder or working
or climbing above an energized circuit
(Ex. 0230). In addition, Duke Energy
asserted that the top of large
transformers and rooftop installations
were places where travel-restricting
equipment could be used (Ex. 0201).
OSHA concludes that the examples
provided by IBEW and Duke Energy are
not relevant because the paragraph at
issue does not apply to the tops of
transformers or rooftops. Also, travelrestricting equipment, which is used to
protect employees from fall hazards at
unprotected edges, is not an appropriate
form of fall protection for employees
transferring from one location to another
or for employees working or climbing
above energized equipment.
Several commenters maintained that
open-sided platforms are found on
electric utility structures. (See, for
example, Exs. 0126, 0183, 0202, 0229,
0233, 0239.) One of them, BGE,
commented that it still has some opensided platforms on switch structures
(Ex. 0126).
OSHA previously concluded that
equipment that can prevent an
employee from falling, such as fall
restraint equipment, is an acceptable
form of fall protection. This conclusion
is consistent with Agency policy as
indicated in several letters of
interpretation. (See, for example, letter
dated November 2, 1995, to Mr. Mike
Amen, https://www.osha.gov/pls/
oshaweb/owadisp.show_document?p_
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table=INTERPRETATIONS&p_
id=21999, and letter dated August 14,
2000, to Mr. Charles E. Hill, https://
www.osha.gov/pls/oshaweb/
owadisp.show_document?p_
table=INTERPRETATIONS&p_
id=24110.) The term ‘‘travel restricting
equipment’’ appears only in existing
§ 1910.269; the equivalent terms
‘‘restraint system’’ and ‘‘tethering
system’’ are used consistently
throughout other OSHA standards, such
as § 1926.760(a)(1), and official letters of
interpretation (id.). The term ‘‘fall
restraint system,’’ as defined in
§ 1926.751 (in the steel erection
standard), is a broad term that OSHA
generally uses to refer to any equipment
that prevents employees from falling.
Thus, ‘‘fall restraint’’ includes travelrestricting equipment, tethering
systems, and other systems that prevent
falls from occurring. On the basis of
comments received on travel-restricting
equipment, OSHA believes that there
are situations in which fall restraint
systems can be used to protect
employees performing work on poles,
towers, and similar structures; therefore,
the final rule includes these systems as
an acceptable form of fall protection.
In reviewing the rulemaking record
for § 1926.954, the Agency noted
situations in which commenters
appeared confused about the proper use
of the various forms of fall protection.
For example, the tree care industry
believed that it was acceptable for
employees working from aerial lifts to
use work-positioning equipment (Exs.
0174, 0200, 0502, 0503), and IBEW
condoned the use of travel-restricting
equipment in what appear to be fallarrest situations (Ex. 0230). OSHA
adopted two changes in the final rule to
clarify these terms. First, in
§§ 1910.269(x) and 1926.968, OSHA is
defining the three forms of fall
protection listed in paragraph (b)(3)(iii)
of the final rule.
The final rule defines ‘‘personal fall
arrest system’’ as a system used to arrest
an employee in a fall from a working
level. This definition is borrowed from
§ 1926.500(b) in subpart M. The Agency
is not, however, including the
descriptive text following the definition
in § 1926.500(b), which describes the
various parts of personal fall arrest
systems. Although this description is
not a necessary part of the definition,
OSHA notes that it describes personal
fall arrest systems as consisting of an
anchorage, connectors, and a body
harness and indicates that such
equipment may include a lanyard,
deceleration device, lifeline, or suitable
combinations of these.
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The final rule defines ‘‘workpositioning equipment’’ as a body belt
or body harness system rigged to allow
an employee to be supported on an
elevated vertical surface, such as a
utility pole or tower leg, and work with
both hands free while leaning. This
definition is based on the definition of
‘‘positioning device system’’ in
§ 1926.500(b) in subpart M. However,
OSHA is replacing the example of
vertical surface work in the subpart M
definition with examples of vertical
surfaces that are commonly found in
electric power generation, transmission,
and distribution work and that are
covered by the final rule.
Finally, the final rule defines ‘‘fall
restraint system’’ as a fall protection
system that prevents the user from
falling any distance. This definition is
borrowed from § 1926.751, which
specifies definitions for the steel
erection standard in subpart R of part
1926. The Agency is not including the
descriptive text following the definition,
which describes the various parts of fall
restraint systems. Although this
description is not a necessary part of the
definition, OSHA notes that it describes
such systems as consisting of either a
body belt or body harness, along with an
anchorage, connectors and other
necessary equipment. The final rule
does not specify strength requirements
for fall restraint systems; however, the
system must be strong enough to
restrain the worker from exposure to the
fall hazard.140
Second, OSHA is adding the phrase
‘‘as appropriate’’ to the requirement in
paragraph (b)(3)(iii)(B) to provide a
personal fall arrest system, workpositioning equipment, or fall restraint
system on poles, towers, or similar
structures. This addition will make it
clear that the system the employer
chooses to implement must be
appropriate for the situation, as
indicated by the respective definitions.
For example, because work-positioning
equipment, by definition, is to be used
on a vertical working surface, it would
be inappropriate to use this equipment
on horizontal working surfaces, such as
a crossarm or horizontal tower arm.
140 OSHA recommended more specific strength
criteria in a letter of interpretation dated November
2, 1995, to Mr. Mike Amen (https://www.osha.gov/
pls/oshaweb/owadisp.show_document?p_table=
INTERPRETATIONS&p_id=21999). This letter
stated: ‘‘OSHA has no specific standards for
restraint systems, however, we suggest that as a
minimum, fall restraint systems should have the
capacity to withstand at least twice the maximum
expected force that is needed to restrain the person
from exposure to the fall hazard. In determining
this force, consideration should be given to sitespecific factors such as the force generated by a
person walking, leaning, or sliding down the
working surface.’’
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With these modifications, the relevant
provision in the final rule, which is in
paragraph (b)(3)(iii)(B), states that,
except as provided in paragraph
(b)(3)(iii)(C), each employee in elevated
locations more than 1.2 meters (4 feet)
above the ground on poles, towers, or
similar structures must use a personal
fall arrest system, work-positioning
equipment, or fall restraint system, as
appropriate, if the employer has not
provided other fall protection meeting
Subpart M.
In the final rule, OSHA also added the
phrase ‘‘meeting subpart M of this part’’
to clarify that the requirements of
Subpart M apply to other forms of fall
protection. The Agency is making a
corresponding clarification in final
§ 1910.269(g)(2)(iv)(C)(2) that ‘‘other fall
protection’’ must meet the general
industry fall protection requirements in
subpart D.
The Southern Company
recommended that OSHA not specify
the type of fall protection equipment to
be used for open-sided platforms (Ex.
0212).
The language OSHA is adopting in
paragraph (b)(3)(iii)(B) of the final rule
provides the employer some latitude in
deciding which form of fall protection is
appropriate for employees working at
elevated locations on poles, towers, and
similar structures. However, the rule
requires that the selected fall protection
equipment be appropriate for the fall
hazard. Using equipment for an
application for which it is not designed
exposes employees to hazards that were
not considered in the design of the
equipment. For example, an employee
using work-positioning equipment in a
fall-arrest situation could fall out of the
equipment or be injured by fall-arrest
forces. Thus, the Agency concludes that
employers must select fall protection
equipment that is appropriate for the
hazard to which the employee is
exposed. Consequently, an employee
exposed to a fall hazard on an opensided platform more than 1.2 meters (4
feet) above the ground must use either
a fall arrest system or a fall restraint
system, with the fall restraint system
eliminating exposure to the fall hazard
altogether.
Proposed paragraph (b)(3)(iii)
included an exemption from fall
protection requirements for qualified
employees climbing or changing
locations on poles, towers, or similar
structures unless conditions, such as ice
or high winds, could cause the
employee to lose his or her grip or
footing. Two rulemaking participants
objected to the proposed provision
allowing qualified employees to climb
or change location without using fall
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protection (Exs. 0130, 0196; Tr. 576–
579). NIOSH recommended ‘‘that fall
protection equipment be used by all
employees, including qualified
employees, climbing or changing
location on poles, towers, and other
walking/working surfaces that present a
potential fall hazard in both general
industry and construction’’ (Ex. 0130).
NIOSH supported its recommendation
with a report that summarized
surveillance data and investigative
reports of fatal work-related falls from
elevations (Ex. 0144). The first report
noted that, according to National
Traumatic Occupational Fatalities
surveillance-system data, 23 percent of
fatal falls in the transportation/
communications/public utilities sector
were from structures, predominantly
poles and towers. This report provided
detailed information about two fatalities
involving employees performing work
on poles or towers covered by this final
rule:
• A power line worker died in a fall
from a utility pole. As he was securing
his positioning strap around the pole, he
contacted a 120-volt conductor and fell
as he tried to free himself from the
conductor. He landed on his head and
died of a broken neck.
• A painter died in a fall from an
electric power transmission tower. As
the employee unhooked his lanyard to
reposition himself on the tower, he lost
his balance and fell to the ground. He
died of massive internal trauma
sustained in the fall.
In both of these cases, NIOSH
recommended evaluating the possibility
of using 100-percent fall protection,
including using fall protection while
employees climb and relocate.
Lee Marchessault of Workplace Safety
Solutions also recommended requiring
fall protection for employees climbing
or changing location on poles, towers, or
similar structures, commenting:
I have asked line workers in many
companies if they have ‘‘cutout’’ (gaffs
released and fallen to some extent from a
pole). [141] The answer is almost universal,
most (more than 90%) have cutout at lease
once. The resulting injury is usually a nasty
sliver from a treated wood pole or minor
bruises or broken bones. This is a known
hazard and yet it is allowed to continue even
though there are devices that prevent this
injury. This section should be eliminated
from this regulation and replaced with ‘‘fall
restraint devices are required from the
ground for climbing poles or similar
141 A line worker using positioning equipment on
a wood pole uses pole climbers, leg irons that are
strapped to the worker’s legs. A gaff, or spike,
protrudes from the leg iron. The gaffs penetrate the
wood of the pole and support the weight of the
worker. A cutout occurs when the gaff slips out of
the wood, allowing the worker to fall.
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structures more than 6 feet and these devices
shall be of a type that cannot be defeated
where practicable’’. In other words, systems
modifying existing pole straps, or pole
mounted devices that need to be installed
once you arrive would not be allowed
because free-climbing is still or may still be
done. Pole top mounted retractable devices
protect from free fall but will not prevent
slowly slipping down the pole picking up
slivers from every gaff cut along the way. A
system such as or similar to Buckingham’s
Bucksqueeze fall protection belt would meet
this requirement. Regarding towers and
structures, there is equipment or options
available for most circumstances. [Ex. 0196]
Mr. Marchessault recognized, however,
that there may be times when it is not
feasible to provide protection and
suggested that the standard account for
those situations (Tr. 595).
Other rulemaking participants
supported the proposed provision in
paragraph (b)(3)(iii) that permitted
qualified employees to free climb
without fall protection. (See, for
example, Exs. 0167, 0185, 0212.) For
instance, Mr. John Vocke with Pacific
Gas and Electric Company (PG&E)
recommended that OSHA retain the
exception allowing employees to free
climb poles and towers, commenting:
PG&E submits that the ‘‘free climbing’’ of
utility poles and/or towers should continue
to be permitted by the OSHA regulations. As
more cable television, telephone and
communication equipment is situated on
utility poles, safe climbing space on these
structures becomes a consideration. In order
for line workers to access overhead electric
facilities, in some instances, free climbing is
a safer alternative. [Ex. 0185]
Whether to provide fall protection for
employees climbing poles, towers, and
similar structures was an issue in the
1994 § 1910.269 rulemaking.
Participants in that rulemaking
submitted substantial evidence on the
need for, and feasibility of, providing
such protection. Based on accident data
submitted to that record in several
exhibits, the Agency found that
employees are at risk of injury when
free climbing:
[T]hese exhibits demonstrate that electric
power generation, transmission, and
distribution workers face a significant risk of
serious injury due to falls under current
industry practices. To determine the extent to
which they face hazards addressed by
proposed § 1910.269(g)(2)(v), OSHA analyzed
fall accidents included in various exhibits
contained in the rulemaking record. . . .
[E]mployees do fall while climbing poles,
towers, or similar structures—26 percent of
the falling accidents related to § 1910.269
occurred in this manner. The evidence in the
record indicates that climbing a pole, tower,
or similar structure is not as safe, under
current industry practices, as some of the
hearing witnesses testified. Therefore, the
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Agency has decided that the final standard
must provide additional protection beyond
that provided by the existing industry
practices. . . . [59 FR 4373]
Although OSHA concluded that it
was not always safe to free climb, the
Agency ‘‘accepted the position that it is
not always necessary for a qualified
employee to use a pole strap when
climbing an unstepped wooden pole’’
(id.) Therefore, in existing
§ 1910.269(g)(2)(v), OSHA adopted a
rule, identical to that proposed in
paragraph (b)(3)(iii), that allowed free
climbing ‘‘unless conditions . . . could
cause the employee to lose his or her
grip or footing.’’ OSHA believed that the
rule adopted in § 1910.269 would
ensure that employees were protected
when conditions were most likely to
lead to falls.
The Agency examined the accident
information in the current record to
determine if the rule in existing
§ 1910.269(g)(2)(v) has reduced
climbing-related accidents. Table 3
presents relevant accident information
from the 1994 record, and from the
record in this rulemaking, to show the
number of fall accidents occurring over
time.
TABLE 3—FALLS BY YEAR
Number of accidents 2
Type of fall 1
1981–1989
1991–1993
1994
1995
1996
1997
1998
1999
11
7
3
12
15
5
0
6
3
0
0
0
5
0
0
0
2
0
0
1
3
0
0
2
1
0
0
0
3
1
0
2
Climbing 3 .........................................................................................
At work location ...............................................................................
Other (not stated) .............................................................................
Failure of Structure ..........................................................................
Notes: 1. The table only includes falls from poles, towers, and similar structures.
2. Each accident involves the death or serious injury of one or more employees.
3. Climbing includes descending and changing location.
Sources: 1981–1989—Table 1 in the preamble to the 1994 § 1910.269 final rule (59 FR 4373).
1991–1999—Exs. 0003 and 0400.
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The number of accidents in the years
1991 through 1999 are based on OSHA
IMIS data. Because IMIS reports are
based on investigations resulting from
employer reports of accidents, and
because employers are not required to
report accidents that do not involve a
fatality or the hospitalization of three or
more employees, it is likely that IMIS
data substantially undercount the
number of nonfatal injuries. Even
without adjusting for potential
undercounting, however, the table
shows that employees still face a
significant risk of being severely injured
in a fall while climbing poles, towers, or
similar structures. In the 3 years before
§ 1910.269 was promulgated, employees
climbing poles, towers, or similar
structures experienced five accidents
per year, on average. In the first 6 years
after that standard was promulgated,
there were approximately three
accidents per year, on average, for a
reduction of two accidents per year, on
average.142 This is in sharp contrast to
the reduction in the number of falls
experienced by employees at the work
location on poles, towers, and similar
structures. This type of accident has
largely disappeared since OSHA issued
§ 1910.269.
142 OSHA examined accident data for electric
utilities for the years 2009 and 2010. In that
industry alone, four employees were injured (three
fatally) when they fell from structures supporting
overhead power lines. (See the descriptions of these
four accidents at: https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=2024
69680&id=202489316&id=201491990&id=2018
59964.) In half the cases, the employees were
climbing or changing location.
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In addition, more than a third of the
falls experienced by employees
climbing wood structures occurred
when the employee’s gaff cut out of the
wood and caused the employee to fall
to the ground (Exs. 0003, 0004). This is
also the experience reported by Mr.
Marchessault of Workplace Safety
Solutions (Tr. 578). Federal and State
compliance records reported that the
poles involved in two of the gaff cutout
accidents reflected in Table 3 had no
observable defects (Ex. 0003143). Even
though both of those accidents occurred
before § 1910.269 was promulgated, it is
likely that nothing in that standard
would have prevented those accidents.
Based on the comments, Mr.
Marchessault’s testimony, and the
accident descriptions in the record,
OSHA concludes that gaff cutout is
pervasive, cannot be reliably predicted,
and can lead to death or serious
physical harm. (Mr. Marchessault
described the injuries as ‘‘slivers’’ in his
testimony, but injuries from gaff cutout
accidents have included such serious
injuries as severe fractures, a
concussion, and a collapsed lung for
which the injured employees were
hospitalized (Exs. 0003, 0400).144)
The current rule in § 1910.269
requires employers to protect employees
143 See the descriptions of the two accidents at:
https://www.osha.gov/pls/imis/accidentsearch.
accident_detail?id=170374144&id=170611693.
144 OSHA also has documentation, not included
in this analysis, of three instances in which
employees were killed when they fell from utility
poles as a result of gaff cutout (https://
www.osha.gov/pls/imis/accidentsearch.accident_
detail?id=170252852&id=14422471&id=14412209).
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from falling while climbing or changing
location under specified circumstances,
and evidence in this record indicates
that in many, if not all, circumstances
it is feasible for employees to climb and
change locations while protected. For
example, Mr. Marchessault of
Workplace Safety Solutions testified
that there are ‘‘equipment options
available for most circumstances
[involving employees climbing or
changing location]’’ (Tr. 576); Mr.
Steven Theis of MYR testified that he
was aware that one utility required 100percent fall protection (Tr. 1357); and
IBEW noted that some employers
require ‘‘fulltime attachment while
climbing and working on a wood
pole’’ 145 (Ex. 0230). According to an
IBEW survey of 102 IBEW construction
locals, more than a quarter of 93 locals
responding to one question in the
survey reported that ‘‘the employer
require[s] continuous attachment to the
pole when climbing,’’ and nearly a third
of 91 locals responding to another
question reported that ‘‘the employer
require[s] continuous attachment to the
145 OSHA concludes that, in describing the
‘‘climbing’’ of poles or structures, rulemaking
participants used the term ‘‘climbing’’ broadly to
indicate any employee movement, including
‘‘changing location,’’ on poles or structures, as
climbing a pole or structure to get to the working
position involves the same horizontal and vertical
movements as changing location vertically or
horizontally on a pole or structure. OSHA also
concludes that, in this context, rulemaking
participants used the term ‘‘working’’ narrowly to
indicate the activity of working in stationary
positions on poles or structures and not broadly to
also indicate the activity of climbing or changing
location on poles or structures.
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structure when climbing’’ (Ex. 0230).
The preamble to the 1994 final rule for
§ 1910.269 noted that the Electrical
Division of the Panama Canal
Commission and Ontario Hydro in
Canada required fall protection for their
employees while they work on elevated
structures (59 FR 4372–4373).
There are several new forms of workpositioning equipment that can provide
continuous attachment for employees
climbing or changing location on poles,
towers, and similar structures. The
preamble to the proposal noted the Pole
Shark and Pole Choker (70 FR
34855).146 Two commenters pointed to
the BuckSqueeze as another workpositioning system that can provide
continuous attachment while employees
are climbing or changing location on
wood structures (Ex. 0199; Tr. 578).147
A video of this equipment being used
demonstrates that an employee
proficient in its use can ascend and
descend poles with relative ease while
being protected from falling (Ex. 0492).
Rulemaking participants indicated that
fall protection equipment is available to
protect employees climbing or changing
location on towers and similar
structures (Exs. 0144, 0196). This
equipment includes rail and rope-grab
systems to which an employee can
attach a harness and a lanyard,
retractable lanyards attached above the
employee, and double-lanyard systems
(Ex. 0199; Tr. 578, 587 148). OSHA
believes that these, and similar new,
devices make it easier to provide fall
protection for employees climbing or
changing location on poles, towers, and
similar structures, as evidenced by the
growing prevalence of employers
requiring 100-percent attachment.
Therefore, OSHA concludes that
employees climbing or changing
location on poles, towers, and similar
structures can use fall protection under
more conditions than required by
existing § 1910.269(g)(2)(v).
However, OSHA also concludes that
there may be circumstances that
preclude the use of fall protection while
146 A Pole Shark is a device that uses jaws and
a spur wheel to grip the pole and provide an
anchorage for climbing wood poles. A Pole Choker
is a pole strap with an integrated choker strap. The
employee tightens the choker strap against the pole
to prevent the pole strap from sliding down the
pole. Note that, throughout this notice, references
to these and other products are examples only and
do not constitute an endorsement by OSHA.
147 A BuckSqueeze is a pole strap with an
integrated choker strap. The employee tightens the
choker strap against the pole to prevent the pole
strap from sliding down the pole.
148 Mr. Marchessault described a double-strap
system for use on a pole (Tr. 587). OSHA believes
that employers can adapt this system, using
lanyards in place of positioning straps, for use on
a tower or similar structure.
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employees are climbing or changing
location. For example, Mr. James
Tomaseski of IBEW testified, ‘‘[O]n
congested poles, to be able to ascend the
pole to your working area could be a
major task in itself. On the congested
poles it is enough of a task already, but
adding to the point that you have to stay
connected the entire time, it would be
at best difficult’’ (Tr. 977). Mr. Theis of
MYR Group echoed these concerns:
[Employees] are using [pole chokers] now.
And some of the guys are telling us they can’t
be used in all situations. In a lot of situations,
they can be. When they start getting into a
very congested pole, very congested area,
they become more cumbersome than they are
of any benefit. [Tr. 1357]
Consequently, OSHA decided to
modify the provision proposed in
paragraph (b)(3)(iii) (paragraph
(b)(3)(iii)(C) in the final rule) to require
fall protection even for qualified
employees climbing or changing
location on poles, towers, or similar
structures, unless the employer can
demonstrate that the conditions at the
worksite would make using fall
protection infeasible or would create a
greater hazard for employees climbing
or changing location on these structures
while using fall protection. This rule
will ensure that 100-percent fall
protection is the default procedure
when employees are working on these
structures and, therefore, will better
protect employees than the current
requirement. Based on the rulemaking
record, OSHA would consider it feasible
to use fall protection while climbing or
changing location on a structure with
few or no obstructions. Employers may,
however, make reasonable
determinations of what conditions, for
example, the degree of congestion on a
pole, would result in a greater hazard
for employees climbing with fall
protection than without fall protection.
Employers making these determinations
must consider the use of devices that
provide for continuous attachment and
should account for other conditions that
would make climbing or changing
location without fall protection unsafe,
including such conditions as ice, high
winds, and the other conditions noted
in existing § 1910.269(g)(2)(v). In
addition, OSHA notes that this
provision does not affect fall protection
requirements in final
§ 1926.954(b)(3)(iii)(B) for employees
once they reach the work location.
Because the final rule permits
qualified employees to climb or change
location without fall protection under
limited circumstances, the Agency
anticipates that it will be necessary for
employees to occasionally defeat the
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20401
continuous attachment feature on the
fall protection equipment. Therefore,
OSHA decided not to require the
equipment used to meet paragraph
(b)(3)(iii)(C) of the final rule to be
incapable of being defeated by
employees, as recommended by Mr.
Marchessault (Ex. 0196).
Even though under existing
§ 1910.269(g)(2)(v) there already are
some circumstances in which employers
must provide equipment that will
protect employees who are climbing or
changing location on structures, OSHA
believes that many employers covered
by the final rule will need additional
time to explore options to select
equipment that best protects their
employees while climbing or changing
location. In some cases, the equipment
employers currently are providing may
not be ideal for everyday use. In
addition, employers will need time to
train employees to become proficient in
the use of any new equipment. Before
employees gain proficiency, it is
possible that not only will they have
difficulties climbing or changing
location on structures, but the
equipment may distract them from
climbing or changing location safely. As
noted by Mr. Gene Trombley,
representing EEI in the 1994
rulemaking, ‘‘To suddenly try to require
them to change years and years of
training and experience would, I feel,
cause a serious reduction in that high
level of confidence and ability’’ (DC Tr.
853, as quoted in the preamble to the
1994 rulemaking, 59 FR 4372).149
Therefore, OSHA is giving employers
until April 1, 2015, to comply with the
new requirements in
§ 1926.954(b)(3)(iii)(C) of the final rule.
This delay should provide sufficient
time for employers to: Evaluate the
various types of fall protection
equipment that employees climbing or
changing location can use; select and
purchase the type of equipment that
best satisfies their needs; train
employees in the use of this equipment;
and certify that the employees
demonstrated proficiency in using the
equipment.
In the intervening period, paragraph
(b)(3)(iii)(C) of the final rule will apply
the existing rule from § 1910.269, which
permits qualified employees to climb
and change location without fall
protection as long as there are no
conditions, such as ice, high winds, the
149 This transcript is available for inspection and
copying in OSHA’s Docket Office, Docket No. S–
015, U.S. Department of Labor, 200 Constitution
Avenue NW., Room N2625, Washington, DC 20210;
telephone (202) 693–2350. (OSHA’s TTY number is
(877) 889–5627.) OSHA Docket Office hours of
operation are 8:15 a.m. to 4:45 p.m., ET.
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design of the structure (for example, no
provision for holding on with hands), or
the presence of contaminants on the
structure, that could cause the employee
to lose his or her grip or footing. The
conditions specifically listed in the
standard are not the only ones
warranting the use of fall protection for
climbing and changing position. Other
factors affecting the risk of an
employee’s falling include the level of
competence of the employee, the
condition of a structure, the
configuration of attachments on a
structure, and the need to have both
hands free for climbing. Moreover, if the
employee is not holding onto the
structure (for example, because the
employee is carrying tools or equipment
in his or her hands), the final rule
requires fall protection. Video tapes
entered into the 1994 § 1910.269
rulemaking record by EEI (269-Ex. 12–
6), which EEI claimed represented
typical, safe climbing practices in the
utility industry, show employees using
their hands to provide extra support and
balance.150 Climbing and changing
location in this manner will enable an
employee to continue to hold onto the
structure in case his or her foot slips.
When employees are not using their
hands for additional support, they are
much more likely to fall as a result of
a slip.
All of these revisions, including the
revisions related to fall protection for
employees working from aerial lifts
described earlier in this section of the
preamble, appear in final
§ 1926.954(b)(3)(iii).
Paragraph (e)(1) of § 1926.502 limits
the maximum free-fall distance for
work-positioning systems to 0.6 meters
(2 feet). OSHA proposed to adopt this
same limit in § 1926.954. However, in
electric power transmission and
distribution work, permanent
anchorages are not always available.
Many utility poles provide no
attachment points lower than the lowest
crossarm. If an employee is working
below the crossarm, there would be no
place on the pole where he or she can
attach the work-positioning equipment.
The preamble to the proposed rule
explained that, in such cases, workpositioning equipment still provides
some degree of fall protection in that the
equipment holds the employee in a
fixed work position and keeps him or
her from falling (70 FR 34855).
Therefore, OSHA proposed in paragraph
(b)(3)(iv) to require work-positioning
equipment to be rigged so that the
150 Exhibits in the 1994 § 1910.269 rulemaking
record (denoted as ‘‘269-Ex’’) also are available in
Docket Number S–015.
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employee could free fall no more than
0.6 meters (2 feet), unless no anchorage
was available. In the preamble to the
proposed rule, OSHA requested
comment on whether proposed
paragraph (b)(3)(iv) would provide
sufficient protection for employees and
on whether portable devices (such as a
Pole Shark, Pole Choker, or similar
device) could be used as suitable
anchorages.
Some commenters objected to the
proposed requirement that workpositioning equipment be rigged with a
maximum free fall of 0.6 meters (2 feet)
insofar as it would apply when
employees are working above
equipment that could serve as an
anchorage. (See, for example, Exs. 0201,
0230.) For instance, IBEW noted that an
employee using work-positioning
equipment might be much more than
0.6 meters above a potential attachment
point, such as a neutral bolt (Ex. 0230).
The union claimed that, if the employee
used this attachment point, the free-fall
distance would have to be more than 0.6
meters for the employee to reach the
work.
OSHA acknowledges these concerns,
but believes they can be eliminated by
the use of portable devices. With
portable devices, employees will not
have to rely on anchorages on poles or
structures because the employees would
have anchorages that are part of the
work-positioning equipment. Thus, it
would always be possible to rig the
equipment to accommodate a free fall of
no more than 0.6 meters.
Many commenters opposed requiring
portable devices to provide anchorages
for employees on poles, towers, and
similar structures. (See, for example,
Exs. 0125, 0127, 0149, 0151, 0162, 0171,
0173, 0175, 0177, 0186, 0200, 0209,
0227.) Some of these commenters
maintained that these devices do not
meet the strength requirements for
anchorages. (See, for example, Exs.
0177, 0227.) For instance, Mr. Thomas
Taylor with Consumers Energy
commented that ‘‘the specified portable
devices do not meet the specifications
for anchorages in Subpart M and were
never designed to be used for that
purpose’’ (Ex. 0177). Several
commenters argued that these devices
are not always effective, are difficult or
impossible to use in some
circumstances, are unnecessary, and
could even increase the risk to
employees. (See, for example, Exs. 0125,
0127, 0149, 0151, 0171, 0175, 0186,
0200.) For instance, Ms. Jill Lowe of the
Employers Electrical and
Communication Safety Committee of
Washington and Oregon commented:
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The use of an anchorage device [such as]
the pole shark, would not be an effective
anchor when working on a structural member
or sitting on a cross arm. The device would
only be effective when climbing a pole
without obstructions or working in a position
on a pole below a cross arm or structural
member. It must also be acknowledged that
some of these devices could not physically be
used due to limited space available on the
pole at the work position (i.e.: Secondaries,
crossarm braces, etc.) . . . .
More information and data would be
required before mandating the use of this
type of equipment. For example, how many
actual injuries have been recorded in a fall
where a worker is belted in on the pole?
Would this add weight or further encumber
the worker when climbing the pole? These
types of devices could be effective in severe
ice conditions, but for day to day use, would
not provide the desired efficacies and would
impede climbing, add to maneuvering
difficulties and could increase risk factor(s).
[Ex. 0151]
Ms. Salud Layton of the Virginia,
Maryland & Delaware Association of
Electric Cooperatives argued that these
devices pose a greater hazard because
they increase ‘‘the amount of time spent
on the pole, the complexity of the work
performed on the pole, and the number
of opportunities to make mistakes while
doing unnecessary jobs not related to
the original reason the pole was actually
climbed’’ (Ex. 0175).
Mr. Anthony Ahern with the Ohio
Rural Electric Cooperatives provided the
following explanation for his argument
that these devices can be difficult to use
and could potentially increase the risk
to employees:
Some of these devices, especially the poleshark, are large and very awkward to use.
They are very difficult to maneuver into a
narrow space and greatly limit movement on
the pole. It is next to impossible for a
lineman to turn around far enough with one
of these devices to be able to reach the end
of a ten foot cross arm or a davit arm or even
work on a transformer bank mounted on a
cluster rack. If two or more workers are
working in the same area on a pole, these
devices can really create a lot of interference.
Also, quite often a second safety is required
to be used with these devices so that the
climber can transition past cables, cross arms
or other equipment on a pole. This means an
extra snap hook in the D-rings and increases
the possibility of an accident because the
lineman grabs the wrong one. These devices
are also much more difficult to operate with
rubber gloves on than a conventional safety
strap. [Ex. 0186]
However, some commenters suggested
that these types of devices could be
used as anchorages. (See, for example,
Ex. 0199; Tr. 1338, 1357.) A video
submitted to the record shows one of
these devices successfully supporting an
employee who had fallen from a pole
(Ex. 0492).
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OSHA concludes that the concerns of
commenters who argued that portable
anchorage equipment is difficult to use
or poses increased hazards are
unwarranted. As noted earlier, some
employers already require 100-percent
attachment. The testimony of Messrs.
Marchessault (of Workplace Safety
Solutions) and Theis (of MYR Group)
offer evidence that Pole Sharks, Pole
Chokers, and similar devices can be,
and have been, used successfully as
anchorages (Tr. 576–579, 1338, 1357).
The videotape of one of these devices in
use clearly demonstrates that the
particular device is reasonably light and
not significantly more difficult to use
than the traditional positioning straps
currently used by power line workers
(Ex. 0492). Some of these devices
occupy about the same space on a pole
or structure as a positioning strap and,
therefore, should fit wherever those
straps fit (id.). Evidence also indicates
that, with training, employees can use
these devices proficiently (Ex. 0199; Tr.
576–579).
Mr. Ahern’s example of an employee
using positioning equipment to reach
the end of a 3-meter (10-foot) crossarm
supports the need for employees to use
an anchorage at the work location. The
end of the crossarm would be about 1.4
meters (4.6 feet) from the edge of the
pole. To perform such work, a 2-metertall (6.5-foot-tall) employee would have
to be in a nearly horizontal position to
reach the end of the arm. This position
increases the likelihood of gaff cutout,
because the gaffs would be at an angle
to the force applied by the employee’s
weight, which would be applied in a
vertical direction. A gaff is designed to
penetrate the wood when force is
applied along its length. When force is
applied perpendicular to the length of
the gaff, it can twist the gaff out of the
wood. In addition, to the extent it is
impossible to reach the end of the
crossarm with some of these devices,
other methods of working from the pole
can be used. For example, the employee
could work from a pole-mounted
platform, which would both enable the
employee to reach further from the pole
and provide an anchorage for the fall
protection equipment (269-Ex. 8–5).
Thus, the Agency concludes that there
is greater need for an anchorage when
work is performed in such positions.
The examples of working on a
crossarm or a structural member
provided by Ms. Lowe with the
Employers Electrical and
Communication Safety Committee of
Washington and Oregon are inapposite.
As noted earlier, work-positioning
equipment is inappropriate for use in
these situations; such equipment may be
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used only on vertical structural
members. It is not clear why Pole
Sharks, Pole Chokers, or similar devices,
which are designed to supplement or
replace traditional positioning straps,
could not be used on vertical members
in the same way a traditional
positioning strap can be used.
OSHA concludes that the accident
information in the record indicates that
there is a need for employees to use an
anchorage to keep them from falling
while they are at the work location (Exs.
0002, 0400). Two of the gaff cutout
accidents included in Table 3 occurred
while an employee was at the work
location. One commenter stated that one
of his company’s eight fall accidents
occurred while an employee was at the
work position (Ex. 0209). Although the
total number of accidents is not great,
these accidents are easily preventable.
The final rule, in paragraph
(b)(3)(iii)(C), already requires employees
to be protected while climbing. The
same equipment that protects an
employee climbing a pole can serve as
an anchorage and can prevent him or
her from falling while at the work
location as well (Ex. 0492; Tr. 576–579).
As a result, OSHA does not believe
there will often be problems finding or
providing anchorage points for workpositioning equipment that can satisfy
the 0.6-meter maximum free-fall
requirement.
The Agency notes that Consumers
Energy incorrectly identified the
relevant strength requirements for
anchorages used with work-positioning
equipment. Paragraph (b)(1)(i) of final
§ 1926.954 applies Subpart M only to
fall arrest equipment. Paragraph (b)(3)(v)
of final § 1926.954, described later in
this section of the preamble, requires
anchorages used with work-positioning
equipment to be capable of supporting
at least twice the potential impact load
of an employee’s fall, or 13.3
kilonewtons (3,000 pounds), whichever
is greater. OSHA concludes that it is
feasible with available technology for
portable anchorage devices to meet the
tensile-strength requirement in
paragraph (b)(3)(v) of the final rule. The
materials, including straps, buckles,
rivets, snaphooks, and other hardware,
that are, or could be, used in anchorages
also are used in positioning straps for
work-positioning equipment (Exs. 0055,
0492), which paragraph (b)(2)(vii)(C) of
the final rule requires to have greater
tensile strength than required by
paragraph (b)(3)(v) of the final rule. In
addition, Mr. Lee Marchessault with
Workplace Safety Solutions testified
about the experience of a line worker he
had been training (Tr. 577–578). The
line worker, who had been using a
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portable anchorage device (the
BuckSqueeze) during the training
exercise, experienced a gaff cutout, but
was not injured because the device
successfully arrested the fall (id.). The
videotape Mr. Marchessault submitted
for the record depicted this equipment
as successfully arresting the fall of the
worker who had been using it (Ex.
0492). Portable anchorage devices are
designed to arrest an employee’s fall
into work-positioning equipment; thus,
the devices almost certainly meet the
strength requirements in ASTM F887–
04, which, as noted earlier, are
equivalent to OSHA’s strength
requirements for work-positioning
equipment. In fact, the latest edition of
the consensus standard, ASTM F887–
12e1, contains equivalent strength
requirements for what it calls ‘‘wood
pole fall restriction devices.’’ 151 OSHA
has included a note following paragraph
(b)(3)(v) of the final rule to indicate that
wood-pole fall-restriction devices
meeting ASTM F887–12e1 are deemed
to meet the anchorage-strength
requirement when they are used in
accordance with manufacturers’
instructions.
For these reasons, paragraph (b)(3)(iv)
in the final rule requires workpositioning systems to be rigged so that
an employee can free fall no more than
0.6 meters (2 feet). OSHA is not
including the proposed exemption for
situations in which no anchorage is
available. In view of the availability of
wood-pole fall-restriction devices,
OSHA expects that in most, if not all,
circumstances, anchorages will not only
be available, but will be built into workpositioning equipment to permit
compliance with this provision, as well
as paragraph (b)(3)(iii)(C) of the final
rule. However, because the Agency
believes that employers will purchase
equipment that complies with both
paragraphs (b)(3)(iii)(C) and (b)(3)(iv),
OSHA is requiring compliance with
both of these paragraphs starting on
April 1, 2015. This delay should
provide employers with sufficient time
to evaluate, and then purchase,
compliant equipment.
Final paragraph (b)(3)(v), which is
being adopted without substantive
change from the proposal, requires
anchorages used with work-positioning
equipment to be capable of sustaining at
least twice the potential impact load of
an employee’s fall, or 13.3 kilonewtons
(3,000 pounds), whichever is greater.
151 Section 15.3.2 of ASTM F887–12e1 requires
these devices, when new, to have a breaking
strength of 13.3 kilonewtons (3,000 pounds).
Section 24 of that standard describes test
procedures for these devices to ensure that they will
successfully arrest a fall.
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This provision, which duplicates
§ 1926.502(e)(2), will ensure that an
anchorage will not fail when needed to
stop an employee’s fall. Comments on
the technological feasibility of this
provision are addressed in the summary
and explanation for paragraph (b)(3)(iv),
earlier in this section of the preamble.
Final paragraph (b)(3)(vi), which is
being adopted without substantive
change from the proposal, provides that,
unless a snaphook is a locking type and
designed specifically for the following
conditions, snaphooks on workpositioning equipment not be engaged
to any of the following:
(1) Webbing, rope, or wire rope;
(2) Other snaphooks;
(3) A D ring to which another
snaphook or other connector is attached;
(4) A horizontal lifeline; or
(5) Any object that is incompatibly
shaped or dimensioned in relation to
the snaphook such that accidental
disengagement could occur should the
connected object sufficiently depress
the snaphook keeper to allow release of
the object.
This paragraph, which duplicates
§ 1926.502(e)(8), prohibits methods of
attachment that are unsafe because of
the potential for accidental
disengagement of the snaphooks during
use.
6. Section 1926.955, Portable Ladders
and Platforms
Final § 1926.955 addresses portable
ladders and platforms. Paragraph (a)
provides that requirements for portable
ladders used in work covered by Part
1926, Subpart V are contained in Part
1926, Subpart X, except as noted in
§ 1926.955(b). Proposed paragraph (a)
also provided that the requirements for
fixed ladders in subpart D of part 1910
(§ 1910.27) applied to fixed ladders used
in electric power transmission and
distribution construction work. OSHA is
including proposed paragraph (a) in the
final rule with one change—deleting the
second provision.
Fixed ladders used in electric power
generation, transmission, and
distribution work are permanent
ladders. They are the same ladders
irrespective of whether the work being
performed on them is construction work
covered by subpart V or maintenance
work covered by § 1910.269. In the
preamble to the proposal, OSHA
explained that the Agency believed that
the Part 1910, Subpart D standards
should apply to these ladders during
construction, as well as during
maintenance work (70 FR 34855), but
requested comments on whether the
proposed incorporation of the general
industry standard for fixed ladders was
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warranted, especially in light of the
1990 proposed revision to Part 1910,
Subpart D (55 FR 13360, Apr. 10, 1990).
OSHA recently reproposed the revision
of that subpart (75 FR 28862, May 24,
2010).
A few commenters responded to this
issue. (See, for example, Exs. 0162,
0212, 0227, 0230.) Southern Company
was concerned about the proposed
incorporation of Subpart D,
commenting:
We question the use of 1910.27 for fixed
ladders since OSHA proposed the revision of
this standard over 15 years ago and there has
been no action to date. Due to the time that
has elapsed since OSHA published the
proposed revisions to 1910 Subpart D and the
revisions that have been made to the national
consensus standards for all types of ladders,
OSHA may wish to consider reopening the
rulemaking prior to proceeding with the
revisions to Subpart D. We recommend that
OSHA not reference Subpart D as a part of
the revisions to Subpart V and 1910.269 until
work on the revision to Subpart D is
completed. [Ex. 0212]
Southern Company also asked OSHA to
explain ‘‘why the provisions of 1910
Subpart D should be applied to fixed
ladders instead of the fixed ladder
requirements of 1926.1053’’ (id.).
Southern Company asserted that the
construction standard contained
requirements that are not found in the
general industry standard, but that
contribute to employee safety (id.).
EEI recommended that neither
§ 1926.955(a) nor the corresponding
provision in the general industry
standard, § 1910.269(h)(1), incorporate
part 1910, subpart D by reference until
OSHA finalizes revisions to part 1910,
subpart D (Ex. 0227). EEI asserted that
there were discrepancies between the
requirements for fixed ladders in
existing part 1910, subpart D, the 1990
proposed part 1910, subpart D, and the
then-current ANSI standard for fixed
ladders, ANSI A14.3–2002, American
National Standard for Ladders—Fixed—
Safety Requirements (id.). EEI also
asserted that the existing general
industry standard contained outdated
design requirements (id.).
OSHA accepts EEI’s and Southern
Company’s recommendation not to
apply the requirements for fixed ladders
in § 1910.27 to fixed ladders used in the
construction of electric power
transmission and distribution
installations, though not for the reasons
these commenters stated. OSHA
believes that the use of fixed ladders in
the construction of transmission and
distribution installations is not unique.
As such, the requirements that apply to
fixed ladders in the construction of
electric power transmission and
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distribution installations should be the
same as the requirements that apply
generally to construction work
(including, as Southern Company noted,
the requirements contained in
§ 1926.1053).
Because OSHA is not including the
cross-reference to subpart D for fixed
ladders in the final rule and because the
remaining provisions in § 1926.955(a)
apply only to portable ladders and
platforms, OSHA is revising the title of
§ 1926.955 to ‘‘Portable ladders and
platforms’’ to more accurately reflect the
contents of this section.
OSHA also accepts EEI’s and
Southern Company’s recommendation
not to reference in final § 1910.269(h)
the part 1910, subpart D provisions for
fixed ladders because, as with final
§ 1926.955, § 1910.269(h) in the final
rule covers only portable ladders and
platforms. Therefore, OSHA is revising
the title of § 1910.269(h) to ‘‘Portable
ladders and platforms’’ and is revising
the regulatory text of final
§ 1910.269(h)(1) to clarify that the
paragraph applies to portable ladders
and platforms, not fixed ladders. These
changes make final § 1910.269(h)
consistent with final § 1926.955.
MYR Group also had concerns about
applying the general industry standards
to construction work. MYR Group
maintained that contractors would have
little control over fixed ladders
provided by host employers (Ex. 0162).
The Agency notes that an employer
whose employees are performing the
work must adhere to OSHA standards.
If, for example, an electric utility’s fixed
ladder does not comply with Part 1926,
Subpart X, then a contractor whose
employees would be using that ladder
must take whatever measures are
necessary to protect its employees and
comply with Part 1926, Subpart X. Such
measures include enforcing any
contractual language requiring the
utility to address any noncompliant
ladders, using other means of accessing
the work area, such as portable ladders
or aerial lifts, and repairing or replacing
the ladder.
IBEW recommended that OSHA
consider the specifications for fixed
ladders in IEEE Std 1307, Standard for
Fall Protection for Utility Work, when
finalizing the language for subpart V
and § 1910.269 (Ex. 0230).The union
wrote:
[T]he committee responsible for
developing the standard went through great
pains to research ladders, step bolts, and
other climbing devices commonly installed
on electrical structures. Lineman climbing
boots and other equipment was looked at for
the purpose of establishing ladder and step
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bolt criteria that would be compatible with
the worker safety equipment. [Ex. 0230]
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OSHA rejects IBEW’s
recommendation to adopt requirements
based on IEEE Std 1307. Although that
consensus standard contains
requirements for structures found in
electric power generation, transmission,
and distribution work (for example,
utility poles and towers), those
structures are not unique to the electric
power industry; and the Agency
believes, therefore, that this rulemaking
is not the proper vehicle to regulate
them. The same types of structures are
found in other industries, in particular,
the telephone and cable-television
industries. Utility poles and towers are
used to support telephone lines, cable
television lines, communications
antennas, and other equipment used by
these industries. OSHA notes that its
recently proposed revision of part 1910,
subpart D includes requirements for
fixed ladders on towers and for step
bolts on towers and poles (see proposed
§ 1910.24, Step bolts and manhole steps;
75 FR 29136).
Paragraph (b) of the final rule
establishes requirements for special
ladders and platforms used for electrical
work. Because the lattice structure of an
electric power transmission tower and
overhead line conductors generally do
not provide solid footing or upper
support for ladders, OSHA is exempting
portable ladders used on structures or
conductors in conjunction with
overhead line work from the general
provisions of § 1926.1053(b)(5)(i) and
(b)(12), which address ladder support
and the use of ladders near exposed
electric equipment. As noted in the
preamble to the proposal, an example of
a type of ladder exempted from these
provisions is a portable hook ladder
used by power line workers to work on
overhead power lines (70 FR 34855).152
These ladders are hooked over the line
or other support member and then are
lashed in place at both ends to keep
them steady while employees are
working from them.
Final paragraphs (b)(1) through (b)(4)
and (c) provide employees with
protection that is similar to the
protection afforded to employees by
§ 1926.1053(b)(5)(i) and (b)(12). These
provisions require that these special
152 Existing § 1926.1053(b)(12) provides that
‘‘[l]adders shall have nonconductive siderails if
they are used where the employee or the ladder
could contact exposed energized electrical
equipment, except as provided in § 1926.951(c)(1)
of this part.’’ In this final rule, OSHA is replacing
the reference to § 1926.951(c)(1) with a reference to
the corresponding provision in the final rule,
§ 1926.955(c), and to final § 1926.955(b), which
exempts special ladders used for electrical work
from the requirement for nonconductive siderails.
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ladders and platforms be secured,
specify the acceptable loads and proper
strength of this equipment, and provide
that the ladders be used only for the
particular types of application for which
they are designed. These provisions
thereby ensure that employees are
adequately protected when using the
ladders covered by the final rule. In the
§ 1910.269 rulemaking, OSHA
concluded that these alternative criteria
provide for the safe use of this special
equipment, and the Agency is extending
the application of these alternative
criteria to work covered by Subpart V
(59 FR 4375). It should be noted that the
requirements for portable ladders in
final paragraphs (b)(1) through (b)(4)
apply in addition to requirements in
§ 1926.1053 for portable ladders. OSHA
revised the language in the final rule to
clarify that the requirements in
§ 1926.1053, except for paragraph
(b)(5)(i) and (b)(12), apply to portable
ladders used on structures or
conductors in conjunction with
overhead line work and that the
requirements in paragraphs (b)(1)
through (b)(4) apply only to portable
ladders and platforms used in this
manner.
Paragraph (b)(1) of final § 1926.955
requires portable platforms to be
capable of supporting without failure at
least 2.5 times the maximum intended
load in the configurations in which they
are used. Paragraph (b)(1) in the
proposed rule also applied this
requirement to portable ladders.
However, § 1926.1053(a)(1), which also
applies, already specifies the strength of
portable ladders. Having two standards
with different strength requirements for
portable ladders would be confusing.
Consequently, OSHA revised
§ 1926.955(b)(1) in the final rule so that
it covers only portable platforms.
Paragraph (b)(2) of final § 1926.955
prohibits portable ladders and platforms
from being loaded in excess of the
working loads for which they are
designed. It should be noted that, with
respect to portable ladders, compliance
with this provision constitutes
compliance with § 1926.1053(b)(3).
Paragraph (b)(3) of final § 1926.955
requires portable ladders and platforms
to be secured to prevent them from
becoming accidentally dislodged.153
Accordingly, with respect to portable
153 It should be noted that, to meet paragraph
(b)(3), employers must ensure that portable ladders
and platforms are always secured when in use,
regardless of the conditions of the surface on which
the ladder is placed. For example, when a
conductor platform, such as a cable cart, is
suspended from a line conductor by a trolley or
hooks, the platform must be secured to the
conductor so that it cannot fall if the trolley or
hooks become dislodged.
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ladders, OSHA concludes that
compliance with § 1926.955(b)(3)
constitutes compliance with
§ 1926.1053(b)(6), (b)(7), and (b)(8).154
Paragraph (b)(4) of final § 1926.955
requires portable ladders and platforms
to be used only in applications for
which they are designed. It should be
noted that, with respect to portable
ladders, compliance with this provision
constitutes compliance with
§ 1926.1053(b)(4).
Paragraph (c) prohibits the use of
portable metal, and other portable
conductive, ladders near exposed
energized lines or equipment. This
paragraph addresses the hazard to
employees of contacting energized lines
and equipment with conductive ladders.
However, as noted in the preamble to
the proposal, in specialized high-voltage
work, the use of nonconductive ladders
could present a greater hazard to
employees than the use of conductive
ladders (70 FR 34855–34856). In some
high-voltage work, voltage can be
induced on conductive objects in the
work area. When the clearances between
live parts operating at differing voltages,
and between the live parts and
grounded surfaces, are large enough that
it is relatively easy to maintain the
minimum approach distances required
by § 1926.960(c)(1), electric shock from
induced voltage on objects in the
vicinity of these high-voltage lines can
pose a greater hazard. Although these
voltages do not normally pose an
electrocution hazard, the involuntary
muscular reactions caused by contacting
objects at different voltages can lead to
falls. Using a conductive ladder in these
situations can minimize the voltage
differences between objects within an
employee’s reach, thereby reducing the
hazard to the employee. Therefore, the
final rule permits a conductive ladder to
be used if an employer can demonstrate
that the use of a nonconductive ladder
would present a greater hazard to
employees.
7. Section 1926.956, Hand and Portable
Power Equipment
Final § 1926.956 addresses hand and
portable power equipment. The title of
this section in the proposal was ‘‘Hand
and portable power tools.’’ OSHA
revised the title to comport with the
scope of the requirements in this
section, which address equipment
generally and not just tools. Paragraph
154 It should also be noted that § 1926.1053(b)(1),
which requires that portable ladders be secured in
certain situations, applies additional requirements
when portable ladders are used to access an upper
landing surface. Therefore, compliance with final
§ 1926.955(b)(3) does not constitute compliance
with these requirements.
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(a) of this section of the final rule
provides that electric equipment
connected by cord and plug is covered
by paragraph (b), portable and vehiclemounted generators used to supply
cord- and plug-connected equipment are
governed by paragraph (c), and
hydraulic and pneumatic tools are
covered by paragraph (d). OSHA took all
of the requirements in this section from
existing § 1910.269(i).
Electric equipment connected by cord
and plug must satisfy the requirements
in paragraph (b). Proposed paragraph
(b)(1) stated that cord- and plugconnected equipment supplied by
premises wiring is covered by Subpart
K of Part 1926. OSHA is not including
this proposed requirement in the final
rule because, first, OSHA determined
that the language in proposed paragraph
(b) improperly emphasized ‘‘premises
wiring.’’ The purpose of the proposed
provision was to clarify that equipment
covered by Subpart K would continue to
be covered by that Subpart (70 FR
34856). However, OSHA derived the
proposed provision from the
corresponding provision in existing
§ 1910.269(i). That provision was, in
turn, derived from § 1910.302(a)(1),
which specifies the scope of part 1910,
subpart S, and provides that the
subpart’s ‘‘design safety standards for
electric utilization of systems’’ apply to
‘‘electrical installations and utilization
equipment installed or used within or
on buildings, structures, and other
premises’’ (that is, premises wiring).
Section 1926.402, which specifies the
scope of Subpart K, does not use the
term ‘‘premises wiring.’’ Second,
proposed § 1926.956(b)(1), and its
counterpart in existing
§ 1910.269(i)(2)(i), are unnecessary
because these provisions simply refer to
requirements that already apply.
Therefore, to remove any ambiguity, the
Agency is not including proposed
§ 1926.956(b)(1) in the final rule and is
removing existing § 1910.269(i)(2)(i) and
is replacing the reference in existing
§ 1910.269(i)(2)(ii) (final
§ 1910.269(i)(2)) to any cord- and plugconnected equipment supplied by other
than premises wiring with a reference to
cord- and plug-connected equipment
not covered by Subpart S.
Pursuant to proposed paragraph
(b)(2), equipment not covered by
subpart K had to have the tool frame
grounded, be double insulated, or be
supplied by an isolating transformer
with an ungrounded secondary. The
proposed rule (and existing
§ 1926.951(f)(2)(iii)) did not specify any
limit on the secondary voltage of the
isolating transformer. OSHA is
promulgating this paragraph in the final
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rule (final paragraph (b)(3)) with one
substantive change—if an isolating
transformer with an ungrounded
secondary is used to comply with this
provision, its secondary voltage is
limited to 50 volts.
In the preamble to the proposed rule,
OSHA noted the widespread availability
of double-insulated tools and requested
comment on whether the option
permitting tools to be supplied through
an isolating transformer was still
necessary (75 FR 34856). Several
commenters responded to this request.
(See, for example, Exs. 0126, 0186,
0201, 0209, 0212, 0213, 0227, 0230.)
Most of these comments supported
retaining the proposed option that
permits cord- and plug-connected
equipment to be supplied by an
isolating transformer. (See, for example,
Exs. 0201, 0209, 0212, 0213, 0227.) For
instance, Duke Energy stated: ‘‘OSHA
should continue to allow the third
option of isolating transformers. While
most applications are covered by
grounding or double insulating, there
are unique situations where neither of
these is possible and an isolating
transformer may be necessary to protect
employees’’ (Ex. 0201). TVA
commented, without elaboration, that
‘‘[d]uring plant outages there are
situations where the use of isolating
transformers provides the best employee
safety’’ (Ex. 0213). Southern Company
relied on OSHA’s statement in the
preamble to the proposal 155 that using
isolating transformers is ‘‘an effective
means of protecting employees from
shock’’ (Ex. 0212).
Other commenters asserted that using
isolating transformers was an outdated
form of protection. (See, for example,
Exs. 0126, 0186, 0230.) For instance, Mr.
Anthony Ahern of Ohio Rural Electric
Cooperatives wrote:
Isolating transformers are not needed
today. Almost all tools today are either
double insulated or equipped with a
grounding (3 wire) cord and plug. OSHA
already has rules which cover the use and
maintenance of these types of tools. Further,
battery operated and gas powered tools are
becoming more and more common and
hydraulic tools are commonly used with
bucket trucks. [Ex. 0186]
IBEW commented, ‘‘Double insulated
hand tools are the industry standard. It
would be difficult to find tools that are
not double insulated or the tool frame
is not grounded’’ (Ex. 0230). IBEW
stated, however, that isolating
transformers continue to be an option
‘‘[i]f other types of tools continue to be
used’’ (id.).
155 See
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OSHA determined that the proposed
option permitting cord- and plugconnected equipment to be supplied by
an isolating transformer was
insufficiently protective and that this
option will only provide sufficient
protection against ground faults when
the isolation transformer has an
ungrounded secondary of no more than
50 volts. OSHA is imposing the 50-volt
limit on isolation transformers because,
although OSHA stated in the preamble
to the proposal that each of the three
options (grounding, double insulation,
and isolation) provided protection from
electric shock (70 FR 34856), OSHA
recognized in other standards the
limited protection provided by isolating
transformers.156 If unlimited voltages
are permitted with respect to the
isolating transformer option, employees
working with cord- and plug-connected
equipment operating at higher voltages
would be exposed to a serious electricshock hazard when a second ground
fault occurs. Even if equipment is
supplied by an isolating transformer
with an ungrounded secondary, there
will always be a path to ground for the
circuit conductors. This path will be
caused by leakage or by capacitive or
inductive coupling. Depending on the
location of this path, one of the circuit
conductors could have a voltage to
ground as high as the full circuit
voltage. Thus, while the corresponding
electrical standards for general industry
and construction at §§ 1910.304(g)(6)(vi)
and (g)(6)(vii) and 1926.404(f)(7)(iv),
respectively, permit all three options,
the standards (in
§§ 1910.304(g)(6)(vii)(A) and
1926.404(f)(7)(iv)(C)(6)) also limit the
secondary voltage on the isolating
transformer to 50 volts or less. Fifty
volts or less is widely recognized as a
generally safe voltage. (See, for example,
Exs. 0076, 0077, 0532.)
Paragraph (c) of final § 1926.956
requires portable and vehicle-mounted
generators used to supply cord- and
plug-connected equipment covered by
paragraph (b) to meet several
requirements. Under paragraph (c)(1),
the generator may only supply
equipment on the generator or the
vehicle (for example, lights mounted on
the generator or vehicle) and cord- and
plug-connected equipment through
receptacles mounted on the generator or
the vehicle. Paragraph (c)(2) provides
that non-current-carrying metal parts of
156 OSHA notes that TVA did not address the
safety of using an isolating transformer with a
secondary voltage of more than 50 volts during a
plant outage. However, pursuant to the final rule,
if TVA uses such a transformer during a plant
outage or otherwise, that transformer must have a
secondary voltage of not more than 50 volts.
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equipment, and the equipment
grounding conductor terminals of the
receptacles, must be bonded to the
generator frame. Paragraph (c)(3)
requires that the frame of vehiclemounted generators be bonded to the
vehicle frame. Finally, paragraph (c)(4)
requires the neutral conductor to be
bonded to the generator frame. The final
rule clarifies that these requirements
apply only when Subpart K does not
apply, as explained in the discussion of
§ 1926.956(b), earlier in this section of
the preamble. The requirements in this
paragraph are similar to the
corresponding Subpart K requirements,
which are contained in § 1926.404(f)(3).
Final paragraph (d), which is being
adopted without substantive change
from the proposal, applies to pneumatic
and hydraulic tools. Paragraph (d)(1) of
§ 1926.302 requires the fluids used in
hydraulic-powered tools to be fire
resistant. As explained in the preamble
to the proposed rule, insulating
hydraulic fluids are not inherently fire
resistant, and additives that could make
them fire resistant generally make the
hydraulic fluid unsuitable for use as
insulation (70 FR 34856). Because of
these characteristics and because
hydraulic fluids must be insulating to
protect employees performing power
transmission and distribution work,
existing § 1926.950(i) exempts
insulating hydraulic fluids from
§ 1926.302(d)(1).
OSHA proposed to continue this
exemption in § 1926.956(d)(1), but was
concerned by several accidents
described in the record that occurred
when insulating hydraulic fluid ignited
and burned employees (Ex. 0002). The
Agency requested information on
whether fire-resistant insulating
hydraulic fluids were available or were
being developed.
OSHA did not receive any
information about the availability or
progress with the development of fireresistant insulating hydraulic fluid;
consequently, OSHA is including the
existing exemption for insulating
hydraulic fluids in the final rule. The
Agency believes that the most serious
hazard faced by an employee
performing work covered by subpart V
is electric shock. The Agency also
reviewed the accidents in the record
(such as Exs. 0002, 0003, 0004, and
0400) and concluded that, although
insulating hydraulic fluid poses a
substantial risk of igniting and burning
workers, the risk of electric shock with
uninsulated hydraulic equipment poses
a greater risk of harm. OSHA encourages
employers and manufacturers to
develop insulating fluid that also is fire-
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resistant and will reexamine this issue
if such fluids become available.
Final paragraph (d)(2) provides that
safe operating pressures may not be
exceeded. This requirement protects
employees from the harmful effects of
tool failure. If hazardous defects are
present, no operating pressure would be
safe, and the tools could not be used. In
the absence of defects, the maximum
rated operating pressure (which may be
specified by the manufacturer or by
hydraulics handbooks) is the maximum
safe pressure. OSHA included a note to
this effect in the final rule.
If a pneumatic or hydraulic tool is
used where it may contact exposed
energized parts, the tool must be
designed and maintained for such use
under final paragraph (d)(3). In
addition, under paragraph (d)(4),
hydraulic systems for tools that may
contact exposed live parts during use
must provide protection against loss of
insulating value, for the voltage
involved, due to the formation of a
partial vacuum in the hydraulic line.
Under paragraph (d)(5), a pneumatic
tool used on energized electric lines or
equipment or used where it may contact
exposed live parts must provide
protection against the accumulation of
moisture in the air supply. These three
requirements protect employees from
electric shock by restricting current flow
through hoses.
OSHA included a note following
paragraph (d)(4) of the final rule
addressing the use of hydraulic lines
that do not have check valves.157 If such
lines are located in such a manner that
the highest point on the hydraulic
system is more than 10.7 meters (35
feet) above the oil reservoir, a partial
vacuum can form inside the line. A
partial vacuum can cause a loss of
insulating value, possibly resulting in
an electrical fault and consequent
hydraulic system failure while an
employee is working on a power line.
During the rulemaking on the 1994
§ 1910.269 final rule, IBEW reported
two accidents that resulted from such an
occurrence (269–DC Tr. 613). Therefore,
OSHA inserted the note when the
Agency adopted existing
§ 1910.269(i)(4)(iii), which is mirrored
in final § 1926.956(d)(4).158
Final paragraphs (d)(6) and (d)(7)
provide work-practice requirements to
protect employees from the accidental
release of pressure and from the
157 A check valve blocks reverse flow of the
hydraulic fluid and prevents the formation of a
partial vacuum.
158 OSHA notes that whether a partial vacuum
will result in the loss of insulating value that
triggers actions to prevent the formation of a partial
vacuum depends on the voltage involved.
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20407
injection of hydraulic oil (which is
under high pressure) through the skin
and into the body. The first of these two
provisions requires the release of
pressure before connections in the lines
are broken, unless quick-acting, selfclosing connectors are used. In the case
of hydraulic tools, the spraying
hydraulic fluid itself, which is
flammable, poses additional hazards.
Final paragraph (d)(7) requires
employers to ensure that employees do
not use any part of their bodies, such as
a finger, to try to locate or stop a
hydraulic leak. This provision in the
final rule has been reworded to clarify
that the employer has responsibility for
compliance.
Final paragraph (d)(8) provides that
hoses not be kinked. Kinks in hydraulic
and pneumatic hoses can lead to
premature failure of the hose and to
sudden loss of pressure. If this loss of
pressure occurs while the employee is
using the tool, an accident could result
in harm to employees. For example, a
hydraulic or pneumatic tool supporting
a load could drop the load onto an
employee on a sudden loss of pressure.
NIOSH suggested that OSHA
‘‘consider an additional safeguard
against the unintentional release of
hydraulic oil—the use of hoses that are
color coded by the [operating pressure]
they can withstand, thus reducing the
hazard of skin absorption or fire’’ (Ex.
0130). NIOSH did not submit any
evidence that employers are using hoses
of improper rating on hydraulic
equipment. Consequently, the Agency is
not adopting a requirement to color
code hydraulic hoses according to safe
operating pressure. However, NIOSH
submitted evidence that an employer
performing maintenance on an
insulating hydraulic tool improperly
replaced a nonconductive hose with a
hose that was conductive because of its
metal reinforcement (Ex. 0139).
Although OSHA is not adopting a colorcoding requirement in the final rule, the
Agency advises manufacturers to clearly
distinguish between conductive and
nonconductive hoses.
Section 1926.957, Live-Line Tools
Final § 1926.957 is equivalent to
existing § 1910.269(j) and contains
requirements for live-line tools (some of
which are commonly called ‘‘hot
sticks’’). This type of tool is used by
qualified employees to handle energized
conductors. The tool insulates the
employee from the energized line. For
example, a wire tong, which is a slender
insulated pole with a clamp on one end,
is used to hold a conductor at a distance
while work is being performed.
Common types of live-line tools include
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wire tongs, wire-tong supports, tension
links, and switch, fuse, and tie sticks.
Mr. Leo Muckerheide of Safety
Consulting Services was concerned that
proposed § 1926.957 did not address all
types of live-line tools, stating:
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There is no definition given for a live-line
tool except in the preamble. It states that
such a tool is used to handle energized
conductors and then gives some examples.
There are other work practices, such as
installing personal protective grounds,
checking for voltage, pulling fuses or cutouts,
removing or installing pins on suspension
insulators, removing or installing jumpers,
etc., where an insulated tool (switch/fuse/hot
stick) is utilized. The insulating
characteristics of these insulated tools
(switch/fuse/hot stick) is critical to the
accomplishment of such activities without
injury to the worker. Any insulated tool
(switch/fuse/hot stick) that is used on an
energized circuit or a normally energized
circuit in a manner that places a part of the
tool inside the minimum approach distance
. . . should be considered a live-line tool.
The worker is depending on the insulating
characteristics of the tool for protection. [Ex.
0180]
He recommended that OSHA expand
this section to include these other
insulated tools (id.).
OSHA notes that the lists of live-line
tools provided here and in the preamble
to the proposal (70 FR 34853) are not
exhaustive. Also, OSHA added some of
Mr. Muckerheide’s examples to the list
in the first paragraph of the summary
and explanation for final § 1926.957.
Final § 1926.957, and its general
industry counterpart, final § 1910.269(j),
cover any tool that is designed to
contact an energized part and insulate
the worker from that part. IEEE Std 516–
2003, IEEE Guide for Maintenance
Methods on Energized Power Lines,
defines ‘‘insulating tool or device’’ as a
tool or device ‘‘designed primarily to
provide insulation from an energized
part or conductor’’ (Ex. 0041).159 This
definition is consistent with OSHA’s
use of the term ‘‘live-line tool.’’ The
Agency believes that the term is well
understood by the regulated community
and that the guidance provided in this
preamble makes the Agency’s meaning
of the term clear. Therefore, OSHA
concludes that it is not necessary to
define ‘‘live-line tool’’ in the final rule.
Paragraph (a), which is being adopted
without change from the proposal,
requires live-line tool rods, tubes, and
poles to be designed and constructed to
withstand 328,100 volts per meter
(100,000 volts per foot) for 5 minutes if
made of fiberglass-reinforced plastic
(FRP), 246,100 volts per meter (75,000
159 IEEE Std 516–2009 contains the same
definition (Ex. 0532).
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volts per foot) for 3 minutes if made of
wood, or other tests that the employer
can demonstrate are equivalent. The
voltage per unit length varies with the
type of material because different
insulating materials are capable of
withstanding different voltages over
equal lengths. For example, a higher
design standard for wood would cause
most wood to fail to meet the
specification, while a lower design
specification would allow substandard
products into service. Since the
withstand voltages in final paragraph (a)
are consistent with the withstand
voltages in existing § 1910.269(j)(1) and
ASTM F711–02 (2007), Standard
Specification for Fiberglass-Reinforced
Plastic (FRP) Rod and Tube Used in
Live-Line Tools, OSHA expects that
tools currently in use in the industry
will continue to be acceptable. A note
in the final regulatory text provides that
tools that meet ASTM F711–02 (2007)
will be deemed to comply with
paragraph (a)(1) of final § 1926.957.
Together with the minimum approach
distances in § 1926.960(c)(1), final
paragraph (a) of § 1926.957 protects
employees from electric shock when
they are using these tools.
Mr. Frank Owen Brockman with
Farmers Rural Electric Cooperative
Corporation recommended that the
standard not contain provisions for liveline tools made of wood (Ex. 0173). He
maintained that these tools are outdated
and should no longer be in service (id.).
OSHA believes that wood live-line
tools likely are no longer in service and
are no longer being manufactured.
However, the Agency has no evidence
in the record that there are no wood
live-line tools currently in service. As
long as they meet the requirements in
final § 1926.957, they can effectively
protect employees from electric shock.
Therefore, OSHA is including in the
final rule without change the proposed
requirements for live-line tools made of
wood.
Paragraph (b) addresses the condition
of tools. The requirements in this
paragraph duplicate the requirements in
existing § 1910.269(j)(2) and will ensure
that live-line tools remain in a safe
condition after they are put into service.
Paragraph (b)(1), which is being adopted
without change from the proposal,
requires live-line tools to be wiped
clean and visually inspected for defects
before each day’s use. Wiping the tool
removes surface contamination that
could lower the insulating value of the
tool. Inspecting the tool will identify
any obvious defects that could also
adversely affect the insulating value of
the tool.
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Paragraph (b)(2), which is being
adopted without change from the
proposal, provides that a tool be
removed from service if any
contamination or defect that could
adversely affect its insulating qualities
or mechanical integrity is present after
the tool is wiped clean. This paragraph
protects employees from the failure of
live-line tools during use. Tools
removed from service must be examined
and tested under final paragraph (b)(3)
before being returned to service.
During the rulemaking on existing
§ 1910.269, OSHA found that, while
there was no evidence in the record of
any injuries related to the failure of a
hot stick, evidence did indicate that
these tools have failed in use (without
injury to employees) and that employees
depend on their insulating value while
using them to handle energized
conductors (59 FR 4378). The Agency
believes that live-line tools are not
typically used to provide protection for
employees in the rain (when work is
normally suspended), which probably
accounts for the lack of injuries in the
record.160 However, live-line tools
might be used under wet conditions, in
which case it is necessary to ensure that
these tools will retain their insulating
qualities when they are wet. In addition,
employee safety is dependent on the
insulating integrity of the tool—failure
of a live-line tool would almost
certainly lead to serious injury or death
whenever the tool is the only insulating
barrier between the employee and a live
part. Therefore, OSHA is adopting rules
on the periodic examination and testing
of live-line tools to ensure that the liveline tools employees use are safe.
Although visual inspection can detect
the presence of hazardous defects and
contamination, the Agency concluded,
on the basis of the 1994 rulemaking
record for existing § 1910.269, that the
daily inspections required by final
paragraph (b)(1) might not detect all
defects and contamination (59 FR 4378).
Referring to live-line tools that had
failed in use, a Georgia Power Company
study submitted to that 1994 rulemaking
record stated: ‘‘Under visual inspection
all the sticks appeared to be relatively
clean with no apparent surface
irregularities’’ (269-Ex. 60). These tools
passed a dry voltage test, but failed a
wet voltage test.161 While the study
160 A contaminated tool will fail more easily
when wet than when dry (Ex. 0532). Tools are
supposed to be wiped before use, in part to remove
moisture.
161 A so-called ‘‘dry test’’ of a live-line tool is an
electrical test performed on the tool after it is stored
under ambient, low-humidity, test conditions for 24
hours. A so-called ‘‘wet test’’ is an electrical test
performed on the tool after the tool is placed in a
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further noted that the surface luster on
the sticks was reduced, apparently the
normal visual inspection alone did not
detect the defects that caused those
tools to fail.
To address these concerns, OSHA is
adopting requirements in paragraph
(b)(3) for the thorough examination,
cleaning, repair, and testing of live-line
tools on a periodic basis. These
provisions are adopted in the final rule
without substantive change from the
proposal. The tools must undergo this
process on a 2-year cycle and whenever
the tools are removed from service on
the basis of the daily inspection.162
The final rule first requires a thorough
examination of the live-line tool for
defects (paragraph (b)(3)(i)). After the
examination, the tool must be cleaned
and waxed if no defects or
contamination are found; if a defect or
contamination that could adversely
affect the insulating qualities or
mechanical integrity of the live-line tool
is found during the examination, the
tool must be repaired and refinished or
permanently removed from service as
specified by final paragraph (b)(3)(ii). In
addition, under final paragraph
(b)(3)(iii), a tool must be tested: (1) After
it has been repaired or refinished,
regardless of its composition; or (2) after
an examination is conducted in
accordance with final paragraph (b)(3)(i)
that results in no repair or refinishing
being performed (although no testing is
required if the tool is made of FRP rod
or foam-filled FRP tube and the
employer can demonstrate that the tool
has no defects that could cause it to fail
in use).
In accordance with final paragraph
(b)(3)(iv), the test method used must be
designed to verify the tool’s integrity
along its full working length and, if the
tool is made of FRP, its integrity under
wet conditions. The performance
criteria specified by final paragraph (a)
are ‘‘design standards’’ that must be met
by the manufacturer. The test voltages
and test duration used during the
manufacturing process are not
appropriate for periodic retesting of the
hot sticks because live-line tools may
sustain damage during such tests.
Accordingly, the in-service tests
required by final paragraph (b)(3)(v) are
designed to assure as much employee
protection as possible without damaging
high-humidity (at least 93-percent humidity)
chamber for 168 hours. After conditioning and
before testing, the tool is wiped with a dry cloth.
Thus, the outside of the tool is dry during both
tests.
162 When an employer removes a tool from
service under final paragraph (b)(2) and inspects
and tests it under final paragraph (b)(3), the 2-year
cycle begins again on the date of the test.
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the tools. For tools with both hollow
and foam-filled sections, the filled
section is typically considered to
constitute the insulating portion of the
tool, which, for the purposes of final
paragraph (b)(3)(iv), is the working
length of the tool.
Under final paragraph (b)(3)(v), the
test voltages must be 246,100 volts per
meter (75,000 volts per foot) for
fiberglass tools or 164,000 volts per
meter (50,000 volts per foot) for wood
tools, and, in both cases, the voltage
must be applied for 1 minute. Other
tests are permitted if the employer can
demonstrate that they provide
equivalent employee protection.
A note to paragraph (b) of the final
rule states that guidelines for the
inspection, care, and testing of live-line
tools are specified in IEEE Std 516–
2009.
Mr. Stephen Frost with Mid-Columbia
Utilities Safety Alliance commented
that the IEEE standard does not contain
test criteria for FRP tools with hollow
sections, but supported OSHA’s
proposal to adopt the same language as
existing § 1910.269 (Ex. 0184).
OSHA reviewed the test procedures in
IEEE Std 516–2009 and found that they
do address hollow, as well as foamfilled, live-line tools. The Agency
believes that these tests can be used by
the employer as appropriate for the
different sections of multiple-section
tools.
Mr. Leo Muckerheide of Safety
Consulting Services commented that
existing § 1910.269(j)(2)(iii) references a
1994 edition of the 2003 IEEE standard
that OSHA referenced in the note to
proposed paragraph (b). He also noted
that the ‘‘wet’’ test procedure in an
ASTM standard differs from the one in
the IEEE standard. Mr. Muckerheide
explained:
[Paragraph (j)(2)(iii)(D) of existing
§ 1910.269 and proposed § 1926.957(b)(3)(iv)]
require the integrity testing of fiberglassreinforced plastic tools under ‘‘wet
conditions’’ but it does not define ‘‘wet
conditions’’. The note for paragraph
1926.957(b)(3)(iv) refers to IEEE Std 516–
2003 while the note for 1910.269(j)(2)(iii)(D)
refers to IEEE Std 978–1984. IEEE Std 978–
1984 is no longer supported by IEEE. There
is also an ASTM standard, F711–02, that
establishes specifications for live-line tools.
Both have a test protocol for ‘‘wet
conditions’’. However, they are not identical.
One specifies a 7 day 93% humidity test and
the other a fine mist of distilled water. [Ex.
0180]
He recommended that both § 1910.269
and subpart V require testing under wet
conditions to conform to the ‘‘current
version of IEEE Std 516.’’
OSHA notes that the test procedure
and criteria in ASTM F711 are design or
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acceptance tests for new live-line tools,
while the tests in the IEEE standard are
in-service tests. As noted earlier, design
and acceptance tests generally are more
severe than in-service tests and can
damage tools if repeated on a regular
basis. A tool in new condition should
perform at an optimal level. Once a tool
has been in service for a while, it will
typically exhibit reduced performance
because the tool deteriorates as it is
handled—it develops microscopic
scratches and becomes contaminated
with creosote and other substances. To
account for this deterioration, in-service
testing frequently uses different test
procedures or test criteria, or both. In
the final standard, the Agency provides
employers flexibility in adopting test
procedures and criteria. Thus, test
procedures and criteria are acceptable as
long as they meet the performance
requirements of the standard, that is,
they ‘‘verify the tool’s integrity along its
entire working length and, if the tool is
made of fiberglass-reinforced plastic, its
integrity under wet conditions.’’ As
explained in detail under the summary
and explanation for final § 1926.97,
earlier in this section of the preamble,
OSHA is adopting performance
requirements rather than incorporating
consensus standards by reference for a
number of reasons, including allowing
greater compliance flexibility and
reducing the need to update the OSHA
standards as frequently.
As explained in the summary and
explanation for Appendix G, later in
this section of the preamble, OSHA is
updating the consensus standards
specified in nonmandatory references
throughout final § 1910.269 and final
subpart V. In this case, the note to final
§ 1910.269(j)(2) includes an updated
reference to IEEE Std 516–2009 to match
the corresponding note to final
§ 1926.957(b). (See the summary and
explanation of § 1926.97, earlier in this
preamble, for a discussion of OSHA’s
approach regarding future updates of
the consensus standards referenced in
this final rule.)
Section 1926.958, Materials Handling
and Storage
Final § 1926.958 is equivalent to
existing § 1910.269(k) and contains
requirements for materials handling and
storage. Final paragraph (a) clarifies that
material-handling and material-storage
requirements in Part 1926, including
those in Subparts N and CC, apply.
Proposed paragraph (a) referenced only
Subpart N.163 However, OSHA recently
163 When subpart V was originally promulgated in
1972, that final rule also added a standard for aerial
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revised its cranes and derricks standard,
former § 1926.550, which was in subpart
N when OSHA published the proposed
rule for subpart V. The recently
published cranes and derricks final rule
moved the requirements for cranes and
derricks into a new subpart, subpart CC
of part 1926 (75 FR 47906, Aug. 9,
2010).164 Consequently, the Agency is
including a reference to this new
subpart in final § 1926.958(a). Work
performed under subpart V is exempt
from certain requirements in subpart
CC. For example, § 1926.1408(b)(5)
exempts cranes and derricks used in
subpart V work from § 1926.1408(b)(4),
which requires employers to adopt one
of several encroachment-prevention
measures for certain work near overhead
power lines. Any exemptions in subpart
CC for subpart V work continue to
apply; those exemptions are not affected
by this final rule.
It should be noted that Subparts H
and O of OSHA’s construction standards
also contain requirements pertaining to
material handling and storage. For
example, § 1926.602 covers materialhandling equipment. These provisions
continue to apply even though they are
not specifically mentioned in final
§ 1926.958(a). (See final
§ 1926.950(a)(2).) To make this clear in
the final rule, OSHA reworded
§ 1926.958(a) in the final rule to require
material handling and storage to
‘‘comply with applicable materialhandling and material-storage
requirements in this part, including
those in subparts N and CC of this part.’’
Paragraph (b) addresses the storage of
materials in the vicinity of energized
lines and equipment. Paragraph (b)(1),
which is being adopted without
substantive change from the proposal,
contains requirements for areas to
which access is not restricted to
qualified employees only. As a general
rule, the standard does not permit
materials or equipment to be stored in
such areas within 3.05 meters (10 feet)
of energized lines or exposed parts of
equipment. This clearance distance
lifts to subpart N. That aerial lift standard, which
originally appeared at § 1926.556, eventually was
redesignated as § 1926.453, in subpart L. It should
be noted that, except for § 1926.453(b)(2)(v), the
aerial lift standard still applies to work covered by
subpart V even though it is not referenced in final
§ 1926.958 or final § 1926.959. (See
§ 1926.950(a)(2).) See, also, the summary and
explanation for final § 1926.954(b)(3)(iii) for a
discussion of why the fall protection requirement
in § 1926.453(b)(2)(v) does not apply to work
covered by Subpart V.
164 Subpart CC applies to power-operated
equipment, when used in construction, that can
hoist, lower, and horizontally move a suspended
load. The discussion of Subpart CC in the preamble
to the Subpart V final rule refers to this equipment
as ‘‘cranes and derricks.’’
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must be increased by 0.10 meters (4
inches) for every 10 kilovolts over 50
kilovolts. The distance also must be
increased to account for the maximum
sag and side swing of any conductor and
to account for the height and movement
of material-handling equipment.
Maintaining these clearances protects
unqualified employees from contacting
energized lines or equipment with
materials being handled. Storing
materials at the required distances also
will facilitate compliance with
provisions elsewhere in the
construction standards that require
material-handling equipment to
maintain specific distances from
energized lines and equipment, such as
§ 1926.600(a)(6).165
The work practices unqualified
workers must use in handling material
stored near energized lines, including in
areas addressed by final
§ 1926.958(b)(1), are addressed
elsewhere in Part 1926, including
subparts K and CC of part 1926. The
general approach taken in this revision
of subpart V is to provide safety-related
work practices for qualified employees
to follow when they are performing
electric power transmission and
distribution work, including work in
areas addressed by final
§ 1926.958(b)(1). (See the summary and
explanation for final
§ 1926.950(a)(1)(ii).)
Mr. Kenneth Brubaker was concerned
that unqualified employees storing
materials near energized lines or
equipment could not determine the
relevant voltage and recommended
specifying clearance distances that did
not require calculations based on
voltage (Exs. 0099, 0100).
OSHA is not adopting Mr. Brubaker’s
recommendation. As noted under the
summary and explanation for final
§ 1926.950(a)(1)(ii), subpart V does not
apply to electrical safety-related work
practices for unqualified employees.
Paragraph (b)(1) of final § 1926.958
specifies minimum clearance distances
165 OSHA’s revised standard for cranes and
derricks at subpart CC requires minimum clearance
distances for cranes and derricks, which, under
certain conditions, are greater than the distances
specified by final § 1926.958(b)(1). Therefore,
employers covered by subpart V must be
knowledgeable about these requirements when they
store materials that are lifted by equipment covered
under subpart CC and may need to adjust the
clearance distances for storing materials away from
energized lines and equipment accordingly. (For
work covered by subpart V, compliance with final
§ 1926.959 is deemed compliance with the relevant
requirements in subpart CC (per § 1926.1400(g)).
However, employers must comply with subpart CC
clearance distances for work performed by
unqualified employees because subpart V does not
contain electrical safety-related work practices for
those workers. See final § 1926.950(a)(1)(ii).)
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between energized lines or exposed
energized parts and stored material or
equipment. The electrical safety-related
work practices used by unqualified
employees handling the stored material
or equipment are addressed in subparts
of part 1926 other than subpart V. In any
event, the employer is responsible for
determining where to store material and
equipment so as to comply with final
§ 1926.958(b)(1), which addresses Mr.
Brubaker’s concern that unqualified
employees will be determining these
distances.
Paragraph (b)(2), which is being
adopted without substantive change
from the proposal, governs the storage of
materials in areas restricted to qualified
employees. If the materials are stored
where only qualified workers have
access to them, the materials may be
safely stored closer to the energized
parts than 3.05 meters (10 feet),
provided that the employees have
sufficient room to perform their work.
Therefore, to ensure that enough room
is available, paragraph (b)(2) prohibits
material from being stored in the
working space around energized lines or
equipment. A note to this paragraph
clarifies that requirements for the size of
the working space are contained in
§ 1926.966(b). (See the discussion of
final § 1926.966(b) later in this preamble
for an explanation of requirements for
access and working space.)
Working space under this provision is
the clear space that must be provided
around the equipment to enable
qualified employees to work on the
equipment. The minimum working
space specifies the minimum distance
an obstruction can be from the
equipment. For example, if a
switchboard is installed in a cabinet that
an employee will enter, the inside walls
of the cabinet must provide sufficient
minimum working space to enable the
employee to work safely within the
cabinet.
The minimum approach distance that
must be maintained from a live part is
the minimum dimension of the space
around the equipment that a qualified
employee is not permitted to enter,
except under specified conditions. Note
that the minimum approach distance a
qualified employee must maintain from
an energized part (covered in final
§ 1926.960(c)(1)) is smaller than the
working space that is required to be
provided around the part. Accordingly,
the employee must enter the working
space and still maintain the minimum
approach distance unless one of the
exceptions specified in § 1926.960(c)(1)
applies. Employers must ensure that
materials are stored outside the working
space so that employees can quickly
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escape from the space if necessary. In
addition, sufficient room must be
available in the working space to allow
employees to move without violating
the minimum approach distance.
Section 1926.959, Mechanical
Equipment
Requirements for mechanical
equipment are contained in § 1926.959.
Paragraph (a) sets general requirements
for mechanical equipment used in the
construction of electric power
transmission or distribution lines and
equipment. Paragraph (a)(1) provides
that mechanical equipment must be
operated in accordance with applicable
requirements in part 1926, including
subparts N, O, and CC, except for one
requirement pertaining to the operation
of mechanical equipment near energized
power lines at § 1926.600(a)(6), which
does not apply to operations performed
by qualified employees. Accordingly,
§ 1926.600(a)(6) continues to apply to
operations performed by unqualified
employees. Final subpart V contains
requirements for the operation of
mechanical equipment by qualified
employees near energized power lines
and equipment. While the final rule
allows qualified employees to operate
equipment closer to energized lines and
equipment than permitted for
unqualified employees by
§ 1926.600(a)(6), the final rule also
contains the relevant safeguards for
protecting these employees. These
safeguards include special training for
qualified employees (see
§ 1926.950(b)(2)) and the use of special
safety procedures for operations
involving mechanical equipment (see
§ 1926.959(d)). Therefore, OSHA
believes that the final rule will provide
more appropriate protection for
qualified electric power transmission
and distribution workers than
§ 1926.600(a)(6). OSHA revised the
language of final § 1926.959(a)(1) from
the proposal to clarify this point and to
be more consistent with final
§ 1926.958(a).
OSHA proposed to exempt subpart V
operations performed by qualified
employees from § 1926.550(a)(15) in
subpart N, which specified minimum
approach distances for cranes and
derricks. As noted earlier, however,
after OSHA published proposed subpart
V, the Agency revised its standard for
cranes and derricks. The revised
requirements for cranes and derricks
were relocated to subpart CC. In the
cranes and derricks rulemaking, OSHA
concluded that the provisions for
operating cranes and derricks near
overhead power lines in subpart CC
were reasonable and appropriate and
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were more protective of employees than
comparable provisions in existing
subpart V. However, the Agency also
concluded that existing § 1910.269(p)
was just as protective of employees as
the requirements for operating cranes
and derricks near power lines adopted
in subpart CC. (See 75 FR 47921, 47930,
47965–47966.) Accordingly, OSHA
deemed compliance with existing
§ 1910.269(p) as compliance with
§§ 1926.1407 through 1926.1411. (See
§ 1926.1400(g).) The exemptions for
subpart V work specified in subpart CC
(or elsewhere in part 1926) continue to
apply; however, as explained later in
this section of the preamble, the Agency
revised several provisions in subpart CC
to incorporate changes to subpart V in
this final rule.
Paragraph (a)(2) of final § 1926.959
requires that the critical safety
components of mechanical elevating
and rotating equipment receive a
thorough visual inspection before use
on each shift. Although the inspection
must be thorough, it is not necessary to
disassemble the equipment. The note
following this paragraph describes what
equipment parts OSHA considers to be
critical safety components, that is, any
part for which failure would result in a
free fall or free rotation of the boom.
These parts are critical to safety because
failure would immediately pose serious
hazards to employees, as can be seen in
several aerial-lift accidents in the record
(Ex. 0004 166). This provision is adopted
as proposed.
Paragraph (a)(3), which is being
adopted without substantive change
from the proposal, prohibits the
operator of an electric line truck from
leaving his or her position at the
controls while a load is suspended,
unless the employer can demonstrate
that no employee, including the
operator, would be endangered if the
operator left his or her position. This
provision ensures that the operator will
be at the controls if an emergency arises
that necessitates moving the suspended
load. For example, due to wind or
unstable soil, the equipment might start
to tip over. Having the operator at the
controls ensures that corrective action
can be taken quickly enough to prevent
an accident.
Paragraph (b) sets requirements for
outriggers. As proposed, paragraph
(b)(1) would have required that mobile
equipment 167 provided with outriggers
166 See, for example, the seven accidents
described at https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=951145&
id=200200137&id=928168&id=908343&
id=837740&id=14244818&id=564765.
167 Paragraphs (p)(1)(ii) and (p)(2) of existing
§ 1910.269 use the term ‘‘vehicular equipment,’’
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20411
be operated with the outriggers
extended and firmly set ‘‘as necessary
for the stability of the specific
configuration of the equipment.’’ The
manufacturer normally provides limits
for various configurations to ensure the
stability of the equipment, but these
limits can also be derived through
engineering analysis.
Mr. Frank Owen Brockman with
Farmers Rural Electric Cooperative
Corporation commented that outriggers
‘‘should be used any time the boom is
out of the cradle’’ (Ex. 0173).
In considering this comment, OSHA
examined accidents in the record
involving overturned mobile equipment.
There were several such accidents in the
record involving equipment that
overturned, and at least two of them
occurred because the outriggers were
not set (Exs. 0002, 0400 168). Based on
these accidents, OSHA believes that,
even if employees setting up mobile
mechanical equipment expect to operate
the equipment within its stability limits,
they may inadvertently go beyond those
limits while operating the equipment.
Consequently, the Agency agrees with
Mr. Brockman that outriggers should
always be set, at least when it is
possible to do so. Therefore, in
paragraph (b)(1) of the final rule, OSHA
is requiring the outriggers of mobile
which is not defined in existing § 1910.269(x).
Existing paragraph (p)(1)(ii) requires reverse-signal
alarms under certain conditions. This paragraph ‘‘is
based on existing §§ 1926.601(b)(4) and
1926.602(a)(9)(ii)’’ (59 FR 4399). Existing
§ 1926.601(b)(4) contains a reverse-signal-alarm
requirement applicable to motor vehicles, and
existing § 1926.602(a)(9)(ii) contains a similar
requirement applicable to earthmoving and
compacting equipment. Because those construction
standards apply to motor vehicles and earthmoving
and compacting equipment, the term ‘‘vehicular
equipment’’ in existing § 1910.269(p)(1)(ii), which
OSHA drew from those construction standards,
means motor vehicles and earthmoving and
compacting equipment.
Existing § 1910.269(p)(2) generally requires
vehicular equipment, if provided with outriggers, to
be operated with the outriggers extended and firmly
set. Thus, ‘‘vehicular equipment’’ in existing
§ 1910.269(p)(2) applies more broadly to mobile
equipment fitted with outriggers.
In the final rule, OSHA is clarifying these two
provisions in § 1910.269 and the provision in
§ 1926.959(b), which corresponds to existing
§ 1910.269(p)(2). First, OSHA is replacing the term
‘‘vehicular equipment’’ in the introductory text to
paragraph (p)(1)(ii) with ‘‘motor vehicle or
earthmoving or compacting equipment’’ to make it
clear that § 1910.269(p)(1)(ii) applies to the same
equipment as §§ 1926.601(b)(4) and
1926.602(a)(9)(ii). Second, the Agency is using the
term ‘‘mobile equipment’’ in final
§§ 1910.269(p)(2)(i) and 1926.959(b)(1) in place of
the term ‘‘vehicular equipment.’’ ‘‘Mobile
equipment,’’ as used in these paragraphs, means
mechanical equipment that is mounted on a body,
such as a truck, that is used to transport the
equipment.
168 See the two accidents described at https://
www.osha.gov/pls/imis/accidentsearch.accident_
detail?id=170872162&id=201403771.
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paragraph (b)(3) in the final rule. The
requirements contained in paragraphs
(b)(1) and (b)(3) will ensure the stability
of the equipment while loads are being
handled, thereby preventing equipment
tipovers, which could harm employees.
Paragraph (c), which is being adopted
without substantive change from the
proposal, requires mechanical
equipment used to lift or move lines or
other material to be operated within its
maximum load rating and other design
limitations for the conditions under
which it is being used. As OSHA
explained in the preamble to the
proposal, it is important for mechanical
equipment to be used within its design
limitations so that the lifting equipment
does not fail during use and harm
employees (70 FR 34858).
In electric-utility operations, contact
between live parts and mechanical
equipment causes many fatalities each
year. A sample of typical accidents
involving the operation of mechanical
equipment near overhead lines is given
in Table 4. Industry practice (Exs. 0041,
0076, 0077), and existing rules in
equipment to be extended and firmly
set, except as permitted in paragraph
(b)(3), which provides for the safe
operation of the equipment when the
work area or terrain precludes the use
of outriggers.
The second sentence of proposed
paragraph (b)(1) would have prohibited
outriggers from being extended or
retracted outside the clear view of the
operator unless all employees were
outside the range of possible equipment
motion. There were no comments on
this provision, and OSHA is including
this requirement as paragraph (b)(2) in
the final rule. This requirement will
prevent injuries caused by extending
outriggers into employees.
If the work area or terrain precludes
the use of outriggers, proposed
paragraph (b)(2) would have permitted
the operation of the equipment only
within the maximum load ratings
specified by the manufacturer for the
particular equipment configuration
without outriggers. There were no
comments on this provision, and OSHA
is including this requirement in
Subpart V (§§ 1926.952(c) and
1926.955(a)(5)(ii)), require that
mechanical equipment be kept from
exposed energized lines and equipment
at distances generally greater than or
equal to those proposed in Table V–2
(AC Live-Line Work Minimum
Approach Distance). However, incidents
involving contact between mechanical
equipment and energized parts still
occur during the hundreds of thousands
of operations performed near overhead
power lines each year (Ex. 0017). If the
equipment operator is distracted briefly
or if the distances involved or the speed
of the equipment towards the line is
misjudged, contact with the lines is
likely to occur, especially when the
minimum approach distances are small.
Because these types of contacts cannot
be totally avoided, OSHA believes that
additional requirements, beyond
provisions for maintaining minimum
approach distances, are necessary for
operating mechanical equipment near
exposed energized lines. Paragraph (d)
of final § 1926.959 addresses this issue.
TABLE 4—ACCIDENTS INVOLVING THE OPERATION OF MECHANICAL EQUIPMENT NEAR OVERHEAD LINES
Number of fatalities
Type of equipment
Grounded
Types of accident
Total
Yes
No
?
Boom Truck/Derrick Truck ............
9
2
............
7
Aerial Lift .......................................
8
............
............
............
............
............
1
............
............
7
............
............
............
............
............
............
Vehicle ...........................................
2
............
............
............
1
............
1
............
Total .......................................
19
2
2
Boom contact with energized line.
Pole contact with energized line.
Boom contact with energized line.
Lower boom contact with energized line.
Employee working on deenergized line when upper boom contacted
energized line.
Electric current arced from a winch on a lift used on an energized
line to nearby ground.
Line fell on vehicle.
Unknown type of vehicle and type of accident.
15
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Source: OSHA accident investigation data (269-Exs. 9–2 and 9–2A).
Mr. Brian Erga with ESCI proposed a
complete revision of proposed
paragraph (d) (Exs. 0155, 0471; Tr.
1249–1253). OSHA decided not to adopt
this proposal. The Agency addresses his
specific concerns and recommendations
in the following discussion of the
individual provisions of proposed
paragraph (d).
Proposed paragraph (d)(1) would have
required that the minimum approach
distances in Table V–2 through Table
V–6 be maintained between the
mechanical equipment and live parts
while the equipment was being operated
near exposed energized lines or
equipment. This provision would
ensure that sufficient clearance is
provided between the mechanical
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equipment and the energized part to
prevent an electric arc from occurring
and energizing the equipment. The
requirement to maintain a minimum
approach distance also lessens the
chance that the mechanical equipment
will strike the lines and knock them to
the ground. (See 70 FR 34858–34859; 59
FR 4400–4401.)
Mr. Brian Erga with ESCI objected to
the prohibition against taking
mechanical equipment inside the
minimum approach distance (MAD),
commenting:
[The proposal] requires that mechanical
equipment can not be allowed within the
minimum approach distance. However, the
electric utility industry routinely works near
MAD, at MAD, and takes mechanical
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equipment into MAD during many industry
accepted work practices many times per day.
[Ex. 0155]
Mr. Erga argued that proper work
methods and grounding would prevent
accidents involving mechanical
equipment contacting overhead power
lines. He expanded on his comments in
his posthearing submission:
During cross examination at the public
hearing on March 2006, speakers from EEI,
NECA, IBEW and others, testified that
qualified workers routinely take mechanical
equipment into the Minimum Approach
Distance (MAD). In cross examination of Mr.
Tomaseski, IBEW Director of Safety, was
asked, ‘‘is mechanical equipment taken
inside the minimum approach distance at
times?’’ Mr. Tomaseski replied ‘‘regularly,’’
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and he further stated ‘‘it could be (the
standard) rewritten to offer a better level of
safety.’’
This standard industry practice of taking
mechanical equipment into MAD occurs
when qualified workers are setting new
poles, installing transformers, installing
equipment and moving conductors with
mechanical equipment. This practice is safe
and effective if [proper work methods are
used].
Table IV–5 ‘‘Accidents Involving the
Operation of Mechanical Equipment Near
Overhead Lines,’’ page 34859 of the Federal
Register, dated June 15, 2005, details
fatalities around mechanical equipment that
were grounded, ungrounded, or not known.
However, the table does not detail how the
equipment was grounded, if proper cover-up
was used or if any safety precaution was
taken. To date there has never been a
documented case of a worker being injured
or killed around properly grounded
mechanical equipment, or when the proper
work methods . . . have been used.
And, as clearly seen in the IEEE paper 91
SM 312–9 PWRD ‘‘Tests Results of
Grounding Uninsulated Aerial Lift Vehicles
Near Energized Lines’’ (Attachment 1),
whether the vehicle was left ungrounded or
grounded to a temporarily driven ground rod,
neither of these two practices provided any
worker protection. However, when the
vehicle was grounded to a proper ground
source, electrical hazards to workers were
greatly reduced to survival levels. Use of
insulated cover-up on the exposed energized
lines and equipment, or the use of insulated
and tested mechanical equipment are
industry accepted and safe work procedures
which should be supported by OSHA. [Ex.
0471]
OSHA does not dispute Mr. Erga’s
evidence regarding the effectiveness of
grounding and addresses that issue in
the discussion of paragraph (d)(3)(iii),
later in this section of the preamble.
Although Mr. Erga maintains that
‘‘qualified workers routinely take
mechanical equipment into the
Minimum Approach Distance’’ (Ex.
0471), OSHA does not consider this a
valid reason for eliminating proposed
paragraph (d)(1) from § 1926.959. Mr.
Erga did not demonstrate that it is
infeasible to comply with proposed
paragraph (d)(1). In fact, when
performing tasks such as installing poles
or equipment, employers can use
temporary arms or other live-line tools
to move the lines far enough away from
mechanical equipment so that the
equipment maintains the required
minimum approach distance (269-Ex. 8–
5). Moreover, insulated aerial lifts
(discussed later in this section of the
preamble) can be used to install
equipment and move conductors (id.)
Mr. Erga also maintains that
grounding mechanical equipment and
other safety precautions, such as
insulating the lines with coverup,
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provide better protection than the
proposed rule. However, he did not
explain how grounding, insulated
coverup, or any of the other practices he
recommended protect employees from
conductors being knocked down as a
result of contact by mechanical
equipment. The practices he
recommended can help protect
employees who contact energized
equipment; however, those practices do
not protect employees from being
injured or killed by energized lines
contacting them directly or energizing
the earth around them.
Proposed § 1926.959(d)(1) was
equivalent to existing
§ 1910.269(p)(4)(i). Mr. Erga was the
only rulemaking participant in either
this rulemaking or the 1994 rulemaking
to object to the prohibition against
taking mechanical equipment into the
minimum approach distance. OSHA
concludes that this provision of
proposed paragraph (d)(1) is reasonably
necessary and appropriate and is
including it in the final rule.
The proposal specified minimum
approach distances in proposed Table
V–2 through Table V–6. However, in the
final rule, § 1926.960(c)(1)(i) requires
the employer to establish minimum
approach distances. (See the summary
and explanation of § 1926.960(c)(1)(i),
later in this section of the preamble.)
Accordingly, final § 1926.959(d)(1)
requires mechanical equipment to
maintain ‘‘the minimum approach
distances, established by the employer
under § 1926.960(c)(1)(i)’’ rather than
‘‘the minimum approach distances of
Table V–2 through Table V–6,’’ as
proposed.
Mr. Erga questioned whether
proposed paragraph (d)(1) allowed a
qualified employee to ‘‘use insulating
protective material to cover the line and
then go into [the minimum approach
distance] with a conductive boom’’ (Ex.
0155). The word ‘‘exposed’’ is defined
in final § 1926.968 as ‘‘[n]ot isolated or
guarded.’’ The word ‘‘isolated’’ is
defined in final § 1926.968 as ‘‘Not
readily accessible to persons unless
special means for access are used.’’ (See
the summary and explanation for final
§ 1926.960(b)(3) for a discussion of this
definition.) The word ‘‘guarded’’ is
defined in final § 1926.968 as covered,
fenced, enclosed, or otherwise
protected, by means of suitable covers
or casings, barrier rails or screens, mats,
or platforms, designed to minimize the
possibility, under normal conditions, of
dangerous approach or inadvertent
contact by persons or objects. A note
following the definition of ‘‘guarded’’
explains that conductors that are
insulated, but not otherwise protected,
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are not guarded. Thus, energized lines
and equipment that are protected only
by rubber insulating equipment are
neither guarded nor isolated from the
mechanical equipment and would,
consequently, still be ‘‘exposed’’ for
purposes of final paragraph (d)(1).
Therefore, under these conditions,
employers must ensure that mechanical
equipment complies with the minimum
approach distance.
Proposed paragraph (d)(1) provided
an exception permitting the insulated
portion of an aerial lift operated by a
qualified employee located in the lift to
breach the minimum approach distance.
The Agency is adopting this exception
in final paragraph (d)(1) with only
minor editorial changes. As OSHA
noted in the preamble to the proposal,
aerial lifts are designed to enable an
employee to position himself or herself
at elevated locations with a high degree
of accuracy (70 FR 34859). The aeriallift operator is in the bucket next to the
energized lines and, therefore, can
easily judge the approach distance. This
requirement minimizes the chance that
the equipment will contact an energized
line and that the energized line will be
struck down should such contact occur.
Furthermore, the employee operating
the lift in the bucket would be protected
under the provisions of final § 1926.960
from the hazards of contacting the live
parts. As the aerial lift is insulated,
employees on the ground are protected
from electric shock in case the aerial lift
contacts the lines, provided that the
contact is made above the insulated
section of the boom. OSHA further
noted in the preamble to the proposal
that § 1926.959(c) 169 and other
provisions would protect employees
against the possibility that the aerial lift
would strike down the power line (id.).
Two commenters requested
clarification of the exception specified
in proposed paragraph (d)(1) for parts of
insulated aerial lifts (Exs. 0186, 0192).
Mr. Anthony Ahern of Ohio Rural
Electric Cooperatives requested
clarification regarding the portion of the
boom of an aerial-lift truck that would
be considered uninsulated (Ex. 0186).
He noted that some aerial devices have
second insulated inserts in the lower
portion of their booms and that some
companies treat these inserts as
secondary protection and do not
regularly dielectrically test them (id.). In
169 Paragraph (c) of final § 1926.959 requires
mechanical equipment used to lift or move lines to
be used within its maximum load rating and other
design limitations. This provision will ensure that
an aerial lift used to move an overhead line
conductor is designed for that purpose and operated
in a manner that will not cause the conductor to
fail.
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addition, an aerial-lift manufacturer,
Altec Industries, offered these
comments:
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It is important to clarify that insulated
aerial lifts have conductive components
located above their insulated sections. The
insulated aerial lift allows a qualified
employee using appropriate PPE to approach
within the minimum approach distance to a
single unguarded energized conductor.
However the minimum approach distance to
other unguarded conductors at different
potentials remain in effect. The qualified
employee may not approach, or take any
conductive object, including conductive
portions of an insulated aerial lift (e.g.,
material handling system) that are located
above its insulated section, into the
minimum approach distance of two
unguarded conductors at different electrical
potential. [Ex. 0192]
Altec recommended that the
exception be worded, in part: ‘‘the
insulated portion of an aerial lift
operated by a qualified employee in the
lift is exempt from this requirement if
the applicable minimum approach
distance ARE maintained between the
CONDUCTIVE PORTIONS OF THE
AERIAL LIFT LOCATED ABOVE
INSULATION, THE uninsulated
portions of the aerial lift and exposed
objects at a different potential’’ (id.;
emphasis in original).
Final paragraph (d)(1) will protect
employees on the ground by ensuring
that the equipment does not become
energized and that the overhead power
lines are not knocked to the ground.
Both of these conditions pose hazards
for ground workers. For the purposes of
final paragraph (d)(1), OSHA considers
‘‘the insulated portion of an aerial lift’’
to be that portion of an insulated aerial
lift that is on the end of the insulated
boom section farthest from the vehicle
supporting the aerial lift. This is the
portion of the aerial device that is
insulated from the vehicle. If contact
with an energized line is made on this
portion of the boom, employees on the
ground are protected.170 The Agency
does not believe that Altec’s
recommended language would further
clarify this requirement. In addition,
OSHA does not consider insulated
inserts that the employer does not deem
to be insulation, or does not maintain,
to be part of the insulated portion of the
aerial lift as specified by final paragraph
(d)(1).
It should be noted that, even if the
exception in final paragraph (d)(1) for
the insulated portions of aerial lifts
applies, the employee must still
170 Requiring the equipment to be operated by an
employee in the aerial lift, who has better control
over the distance between the equipment and the
power line than an operator on the ground, also
ensures that the line is not knocked down.
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maintain the minimum approach
distances to the extent required in final
§ 1926.960(c)(1). In addition, final
§ 1926.959(d)(1) requires the conductive
portions of the boom to continuously
maintain the minimum approach
distances from conductive objects at
potentials different from that on which
the employee is working. It should also
be noted that the insulating portion of
the boom can be bridged by improper
positioning of the boom or by
conductive objects suspended from the
aerial lift platform. For example, the
insulating portion of the boom will be
bridged when it is resting against a
grounded object, such as a utility pole,
or when the employee in an aerial
bucket is holding onto a grounding
jumper. For purposes of final
§ 1926.959(d)(1), OSHA does not
consider any part of the aerial lift to be
insulated when the insulation is
bridged.
Paragraph (d)(2), which is being
adopted without substantive change
from the proposal, requires a designated
employee to observe the operation and
give timely warnings to the equipment
operator before the minimum approach
distance is reached. There is an
exception to this requirement for
situations in which the employer can
demonstrate that the operator can
accurately determine that the minimum
approach distance is being maintained.
As OSHA explained in the preamble to
the proposal, determining the distance
between objects that are relatively far
away from an equipment operator who
is standing on the ground can
sometimes be difficult (70 FR 34859).
For example, different visual
perspectives can lead to different
estimates of the distance, and lack of a
suitable reference point can result in
errors (269-Ex. 8–19). In addition, an
operator may not be in the best position
to observe the clearance between an
energized part and the mechanical
equipment because, for example, an
obstruction may block his or her view.
An aerial-lift operator would not
normally need to judge the distance
between far away objects. In most cases,
an aerial-lift operator is maintaining the
minimum approach distance from
energized parts relatively close to
himself or herself, and it should be easy
for him or her to stay far enough away
from these parts. In such cases, the
employer would normally be able to
demonstrate that the employee can
maintain the minimum approach
distance without an observer. However,
even an aerial-lift operator may have
difficulty maintaining the minimum
approach distances in certain
circumstances. For example, the
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congested configuration of some
overhead power lines may necessitate
maintaining clearance from more than
one conductor at a time, or an aerial-lift
operator may need to judge the distance
between the lower, uninsulated portion
of the boom and a conductor that is
located well below the operator. In these
situations, in which it is unlikely that
an employer could demonstrate that the
operator could accurately determine
that the required distance is being
maintained, an observer is required.
Final paragraph (d)(3) will protect
employees, primarily employees on the
ground, from electric shock in case
contact is made between the mechanical
equipment and the energized lines or
equipment. This paragraph requires
employers to take one of three
alternative protective measures if the
equipment can become energized. The
first option (paragraph (d)(3)(i)) requires
that energized lines or equipment
exposed to contact with the mechanical
equipment be covered with insulating
protective material that will withstand
the type of contact that could be made
during the operation. The second option
(paragraph (d)(3)(ii)) requires the
mechanical equipment to be insulated
for the voltage involved. Under this
option, the mechanical equipment must
be positioned so that uninsulated
portions of the equipment cannot come
within the applicable minimum
approach distance of the energized line
or equipment.171
Mr. Brian Erga with ESCI was
concerned about the requirement in
proposed paragraph (d)(3)(ii) that
insulated equipment be positioned so
that its uninsulated portions cannot
approach energized lines or equipment
closer than the minimum approach
distance, commenting:
OSHA 1910.269(p)(4) is currently being
read word for word that when using the
insulated portion of mechanical equipment,
the un-insulated portion cannot possibly ever
reach into [the minimum approach distance].
This requires the truck to be positioned so far
away that it cannot lift anything, and is often
impractical since the truck may need to be
30 feet from the pole or line to keep the
possibility of the un-insulated portion
entering [the minimum approach distance].
[Ex. 0155]
Paragraph (d)(3)(ii) in the final rule,
which applies to insulated equipment,
requires the mechanical equipment to
be positioned so that the uninsulated
171 This provision contrasts with final paragraph
(d)(1), which prohibits mechanical equipment
(except, in some situations, the insulated portion of
an aerial lift) from being taken closer than the
minimum approach distance to exposed energized
lines and equipment, but allows the equipment to
be positioned so that it is possible to breach that
distance.
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portion cannot approach any closer than
the minimum approach distance. OSHA
understands that this may not always be
practical, depending on the work to be
performed, the location of the energized
lines and equipment, and available
operating positions for the mechanical
equipment. However, the Agency notes
that this paragraph presents one of three
options that employers may take to
comply with final paragraph (d)(3). The
first and third options, in final
paragraphs (d)(3)(i) and (d)(3)(iii),
permit mechanical equipment,
including insulated equipment, to be
positioned more closely to energized
lines and equipment provided that
employers take the precautions
specified in those paragraphs. (Note that
final paragraph (d)(1) still generally
requires mechanical equipment to be
operated so that the minimum approach
distances, established by the employer
under final § 1926.960(c)(1)(i), are
maintained from exposed energized
lines and equipment, regardless of
where the equipment is positioned.)
The third compliance option,
specified in final paragraph (d)(3)(iii), is
for each employee to be protected from
the hazards that could arise from
contact of mechanical equipment with
the energized lines or equipment. The
measures used must ensure that
employees will not be exposed to
hazardous differences in electric
potential. Based on the § 1910.269
rulemaking record, OSHA concluded
that vehicle grounding alone could not
always provide sufficient protection
against the hazards of mechanical
equipment contact with energized
power lines (59 FR 4403). However, the
Agency recognized the usefulness of
grounding as a protective measure
against electric shock when it is used
with other techniques. Therefore,
proposed paragraph (d)(3)(iii), which
was equivalent to existing
§ 1910.269(p)(4)(iii)(C), required:
(1) Using the best available ground to
minimize the time the lines or
equipment remain energized,
(2) Bonding equipment together to
minimize potential differences,
(3) Providing ground mats to extend
areas of equipotential, and
(4) Using insulating protective
equipment or barricades to guard
against any remaining hazardous
electrical potential differences.
To comply with the third compliance
option in final paragraph (d)(3)(iii), the
employer must use all of these
techniques, unless it can show that it is
using other methods that protect each
employee from the hazards that could
arise if the mechanical equipment
contacts the energized lines or
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equipment. The techniques listed in
paragraph (d)(3)(iii): (1) minimize
differences in electrical potential, (2)
minimize the time employees would be
exposed to hazardous electrical
potentials, and (3) protect against any
remaining hazardous electrical
potentials. The performance-oriented
requirements in final paragraph
(d)(3)(iii) assure that employees are
protected from the hazards that could
arise if the mechanical equipment
contacts energized parts. Information in
Appendix C to final subpart V provides
guidelines for employers and employees
that explain various measures for
protecting employees from hazardous
differences in electrical potential and
how to use those measures. A note
referencing this appendix is included
after final paragraph (d)(3)(iii).
Mr. Erga objected to proposed
paragraph (d)(3)(iii). He recommended
that mechanical equipment always be
grounded ‘‘cradle to cradle,’’ that is,
from the time the boom lifts out of the
cradle until it returns (Tr. 1237) and that
it always be grounded when it comes
within 3 meters (10 feet) of energized
lines or equipment (Tr. 1252). He
recommended further that the standard
provide three options to supplement
this grounding requirement: (1) that the
lines or equipment be covered, (2) that
the mechanical equipment be insulated,
or (3) that barricades, ground mats, and
rubber insulating gloves be used (Tr.
1252).
OSHA concludes that it is not always
necessary to ground mechanical
equipment operated near energized
lines or equipment. Under the first
option in final paragraph (d)(3), the
energized lines or equipment are
covered with insulating protective
material that will withstand the type of
contact that could be made during the
operation. This option should prevent
the mechanical equipment from
becoming energized, and the Agency,
therefore, concludes that grounding is
unnecessary for this option. Under the
second option in final paragraph (d)(3),
the uninsulated portion of insulated
mechanical equipment must be
positioned so that it cannot approach
any closer than the minimum approach
distance. This option also should
prevent the mechanical equipment from
becoming energized, and the Agency
concludes that grounding is
unnecessary under this option as well.
The third option in final paragraph
(d)(3) requires that mechanical
equipment be grounded unless the
employer can demonstrate that other
methods in use will protect each
employee from the hazards that could
arise if the mechanical equipment
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contacts the energized lines or
equipment. In his comments, Mr. Erga
referred to an IEEE paper on grounding,
explaining:
IEEE paper 91 SM 312–9 PWRD ‘‘Test
results of grounding un-insulated aerial lift
vehicles near energized distribution lines’’
. . . clearly shows mechanical equipment
grounded to the best available ground
reduces the voltage and current exposed to
the worker by more than 96%. The ESCI staff
knows of no electrical worker ever killed or
injured around properly grounded
mechanical equipment that has become
accidentally energized. [Ex. 0155; emphasis
included in original]
The IEEE paper to which Mr. Erga
referred clearly shows that using the
best available ground provides the most
protection for employees and, therefore,
supports the requirement in final
paragraph (d)(3)(iii)(A) to ground the
mechanical equipment to the best
available ground (Ex. 0472). However,
the paper also demonstrates that this
ground is insufficient by itself to protect
employees fully. With grounding alone,
the current through a resistor of more
than 900 ohms is high enough to injure
and possibly kill an employee. OSHA
has considered the minimum resistance
of an employee to be 500 ohms, not
1,000 ohms, as specified in the paper
(59 FR 4406). As NIOSH states in its
Publication No. 98–131, Worker Deaths
by Electrocution: A Summary of NIOSH
Surveillance and Investigative Findings,
‘‘High-voltage electrical energy quickly
breaks down human skin, reducing the
human body’s resistance to 500 Ohms’’
(Ex. 0141). Using Ohm’s Law, current is
inversely proportional to resistance, and
the current through a 500-ohm resistor
would be nearly twice the current
shown in the IEEE paper. In addition,
the testing for the IEEE paper was
performed with a 7,200-volt power line.
Distribution and transmission lines of
higher voltages, which are not
uncommon, would result in even higher
currents through a resistor. Thus, the
evidence provided by Mr. Erga
demonstrates the need for additional
measures beyond grounding, such as the
measures required by the final rule.
As noted earlier, final paragraph
(d)(3)(iii) requires the employer to take
specified measures unless it can
demonstrate that the methods in use
protect each employee from the hazards
that could arise if the equipment
contacts the energized line or
equipment. Mr. Erga’s proposal would
require only two of those measures:
Grounding and one of three additional
measures, two of which are comparable
to measures required by final paragraph
(d)(3)(iii). OSHA continues to believe
that all of the measures listed in final
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paragraph (d)(3)(iii) will protect
employees from hazardous differences
in electrical potential as explained in
the preamble to the 1994 § 1910.269
final rule (59 FR 4402–4403). Employers
are free to use other protective
measures, including those proposed by
Mr. Erga, but these employers must
demonstrate that the methods in use
protect each employee from the hazards
that could arise if the equipment
contacts an energized line or equipment.
OSHA concludes that it is important for
employers that do not implement all of
the measures required by final
paragraph (d)(3)(iii) to evaluate their
systems, and the alternative measures
they select, to ensure that employees are
protected. Therefore, OSHA is not
adopting Mr. Erga’s recommended
changes to paragraph (d)(3)(iii).
OSHA is including paragraph (d)(3) in
the final rule substantially as proposed.
The Agency has, however, made
technical changes to the proposed
language to clearly distinguish between
references to mechanical equipment and
references to energized equipment.
Several provisions in proposed
paragraph (d)(3) used the word
‘‘equipment’’ without specifying
whether it meant the mechanical
equipment itself or the energized
equipment that the mechanical
equipment could contact. Although the
language was clear from the context, the
final rule consistently states which term
applies. Also, in two places, proposed
paragraph (d)(3) used the term
‘‘energized lines’’ when OSHA meant
‘‘energized lines or equipment.’’ The
final rule corrects these oversights. In
addition, final paragraph (d)(3)(ii)
requires mechanical equipment to
maintain ‘‘the minimum approach
distances, established by the employer
under § 1926.960(c)(1)(i),’’ rather than
‘‘the minimum approach distances
specified in Table V–2 through Table V–
6,’’ as proposed.
11. Section 1926.960, Working on or
Near Exposed Energized Parts
Paragraph (a) specifies the scope of
§ 1926.960 of the final rule. This section
applies to work on exposed live parts
and work near enough to such parts to
expose the employee to any hazard they
present. Many of the provisions in this
section have been taken directly from
existing § 1910.269(l).
Paragraph (b) contains general
requirements for working on or near live
parts. OSHA is adopting paragraph
(b)(1) in this final rule without change
from the proposal. This paragraph
requires employees working on, or with,
exposed energized lines or parts of
equipment (at any voltage), and
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employees working in areas containing
unguarded, uninsulated energized lines
or parts of equipment operating at 50
volts or more, to be qualified employees.
Without proper training in the
construction and operation of the lines
and equipment and in the electrical
hazards involved, workers performing
this type of work are at risk of being
electrocuted and also may expose others
to injury. In areas containing unguarded
live parts energized at 50 volts or more,
untrained employees would not be
familiar with the practices that are
necessary to recognize and avoid
contact with these parts.
Commenting on the language in
proposed paragraph (b)(1), Mr. Tommy
Lucas with TVA questioned what OSHA
means by ‘‘areas containing unguarded,
uninsulated energized lines or parts of
equipment’’ (Ex. 0213). He noted that
the ‘‘area’’ at issue could be the room,
yard, or building in which the
equipment is located.
Paragraph (e) of § 1926.966 of the final
rule contains requirements for guarding
rooms containing electric supply
equipment in substations. Paragraphs
(u)(4) and (v)(4) of existing § 1910.269
contain corresponding requirements for
maintenance work in substations and
generating plants. These provisions
generally require live parts operating at
50 volts or more to be in rooms or
spaces enclosed within fences, screens,
partitions, or walls so as to minimize
the possibility that unqualified persons
will enter. (See existing
§ 1910.269(u)(4)(ii) and (v)(4)(ii) and
final § 1926.966(e)(2).) These are the
areas to which final § 1926.960(b)(1)(ii)
(and the corresponding requirement in
final § 1910.269(l)(1)(ii)) refer.
The definition of ‘‘qualified
employee’’ contains a note to indicate
that employees who are undergoing onthe-job training are considered to be
qualified if they have demonstrated an
ability to perform duties safely and if
they are under the immediate
supervision of a qualified employee.
(See the discussion of this definition
under the summary and explanation of
final § 1926.968.) Therefore, employees
in training, who have demonstrated an
ability to perform duties safely and are
under the direct supervision of a
qualified employee, are permitted to
perform the types of work described in
paragraph (b)(1). OSHA believes that
close supervision of trainees will permit
employers to correct errors before they
cause accidents. Allowing these workers
to perform tasks under workplace
conditions also may better prepare the
employees to work safely.
Paragraph (b)(2), which is similar to
the last sentence of the introductory text
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of existing § 1910.269(l)(1), is being
adopted in the final rule without change
from the proposal. This paragraph
requires lines and equipment to be
considered and treated as energized
unless they have been deenergized
under the provisions of final § 1926.961.
Existing § 1926.950(b)(2) requires
electric lines and equipment to be
considered energized until determined
to be deenergized by tests or other
appropriate means. The existing
standard does not specify what those
appropriate means are. However, even if
the line or equipment is tested and
found to be deenergized, it may become
reenergized through contact with
another source of electric energy or by
someone reenergizing it at its points of
control. So § 1926.961 of the final rule
contains requirements for deenergizing
electric power transmission and
distribution lines and equipment.
Unless the procedures contained in that
section have been followed, lines and
equipment cannot reliably be
considered as deenergized.
Two-Person Rule
If an employee working on or near
energized electric power transmission or
distribution lines or equipment is
injured by an electric shock, a second
employee will be needed to provide
emergency care to the injured employee.
As noted under the summary and
explanation of final § 1926.951(b),
discussed earlier in this section of the
preamble, CPR must begin within 4
minutes after an employee loses
consciousness as a result of an electric
shock. OSHA is requiring the presence
of a second employee during certain
types of work on or near electric power
transmission or distribution lines or
equipment to ensure that CPR begins as
soon as possible and to help ensure that
it starts within the 4-minute timeframe.
(Note that final § 1926.951(b) requires at
least two people trained in first-aid
procedures, including CPR, for field
work involving two or more employees
at a work location.)
OSHA proposed, in paragraph (b)(3)(i)
of § 1926.960, to require the presence of
at least two employees during the
following types of work:
(1) Installation, removal, or repair of
lines energized at more than 600 volts,
(2) Installation, removal, or repair of
deenergized lines if an employee is
exposed to contact with other parts
energized at more than 600 volts,
(3) Installation, removal, or repair of
equipment, such as transformers,
capacitors, and regulators, if an
employee is exposed to contact with
parts energized at more than 600 volts,
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(4) Work involving the use of
mechanical equipment, other than
insulated aerial lifts, near parts
energized at more than 600 volts, and
(5) Other work that exposes an
employee to electrical hazards greater
than, or equal to, the electrical hazard
posed by these operations.
However, OSHA also proposed
exemptions to the two-person
requirement to account for work that the
Agency believed could be performed
safely by a single employee or that must
be performed as quickly as possible for
public-safety purposes. These
exemptions were proposed in paragraph
(b)(3)(ii) for the following operations:
(1) Routine circuit switching, if the
employer can demonstrate that
conditions at the site allow safe
performance of this work,
(2) Work performed with live-line
tools if the employee is in a position
from which he or she is neither within
reach of nor exposed to contact with
energized parts, and
(3) Emergency repairs to the extent
necessary to safeguard the general
public.
OSHA based the proposed two-person
rule on existing § 1910.269(l)(1)(i) and
(l)(1)(ii). OSHA explained in the
preamble to the proposal that the first
four work operations listed in proposed
paragraph (b)(3)(i) were the operations
that expose employees to the greatest
risk of electric shock, as demonstrated
by the 1994 § 1910.269 rulemaking
record (70 FR 34861). OSHA proposed
the fifth and last category in paragraph
(b)(3)(i) to cover additional types of
work that pose equal or greater electrical
hazards. The preamble to the proposal
noted that operations covered under
existing § 1910.269(l)(1)(i) are
performed during construction, as well
as during maintenance (id.). The
preamble further noted that
construction operations are similar to
the operations performed during
maintenance work and that the Agency
believed that these operations involved
the same hazards (id.). For example,
using mechanical equipment near a
7200-volt overhead power line during
construction of a new line poses hazards
that are equivalent to the hazards posed
during the use of mechanical equipment
to replace a damaged pole on an existing
line of the same voltage. Thus, OSHA
proposed to extend the existing general
industry requirement to construction.
The proposed requirement for at least
two employees to be present during
certain operations generally would not
have applied if the voltage of the
energized parts involved was 600 volts
or less. In the proposal, OSHA requested
comments on whether the final rule
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should extend the application of the
two-person rule to any operations
involving work on installations
operating at 600 volts or less.
Most commenters opposed changing
the proposed rule to require two persons
for work on energized lines or parts
operating at 600 volts or less. (See, for
example, Exs. 0175, 0177, 0209, 0210,
0212, 0219, 0224, 0227.) Some of these
rulemaking participants likened this
work to the work performed by
electricians, for which consensus
standards do not require the presence of
two people. (See, for example, Exs.
0175, 0209, 0212.) For instance, Ms.
Salud Layton with the Virginia,
Maryland & Delaware Association of
Electric Cooperatives commented:
We do not see the need for a second person
on the job site for voltages below 600 Volts.
. . . This work is generally easier and less
hazardous. Work below 600 volts is generally
similar to electricians work. Neither the NEC
nor NESC require two employees to be
present when working these voltages. Most
electricians isolate themselves only thru the
use of insulated tools. Utilities commonly
exceed that level of protection by requiring
the use of Class 0 gloves, in addition to the
use of insulated tools. This combination
effectively negates the need for a second
person. The use of insulated tools with Class
0 gloves helps with protection and also
eliminates the need for a second person. [Ex.
0175]
Mr. Allan Oracion with Energy United
EMC similarly commented that work at
voltages of 600 volts and less is less
hazardous than work at higher voltages
and that there is little potential for
injury during ‘‘low-voltage’’ work as
long as other applicable OSHA
standards are followed (Ex. 0219).
Others argued that a requirement for a
second person would be costly and
impractical without substantial benefits.
(See, for example, Exs. 0177, 0224,
0227.) EEI commented:
EEI submits that there is no need for
further precautions to be required for such
work, provided that the required insulated
cover-up materials are used and personal
protective equipment is being worn by
employees while working on lines and
equipment energized at less than 600 volts.
One moderately sized utility forecasts that if
it is required to replace existing one-person
crews with two-person operations due [to] a
revision in this requirement, the cost to the
company would be approximately $ 3.8
million annually. OSHA has shown no data
supporting a change in the requirements for
work at less than 600 volts, including none
showing that the benefit, if any, to be derived
from unspecified additional precautions
would be reasonably related to the cost. [Ex.
0227]
In responding to OSHA’s request for
comments on whether to require two
persons for work at voltages of 600 volts
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20417
or less, Consumers Energy noted that its
accident experience indicated that
employees who work alone have a
significantly lower injury incidence rate
than employees working together (Ex.
0177). Also on this issue, Siemens
Power Generation commented that
‘‘OSHA should allow the employer to
evaluate the hazard and determine
which situations meet the need for a
two person rule’’ (Ex. 0163).
Some commenters maintained that a
second person should be present when
work is performed on equipment
energized at 600 volts or less. (See, for
example, Exs. 0126, 0161, 0197, 0230.)
Mr. Brad Davis of BGE suggested that
‘‘the same care should be taken at all
voltage levels’’ (Ex. 0126). Mr. James
Junga with Local 223 of the UWUA
maintained that two persons should be
required for all work on voltages of 480
volts or more, commenting:
Working on secondary voltage at or above
480 volts should also require two qualified
persons. I believe this voltage is extremely
dangerous and should not be performed by
one person [because of] the quick response
that is necessary for a person who gets in
contact with energized equipment operating
at 480 volts. [Ex. 0197]
IBEW recommended that two-person
crews always be required for
construction work covered by Subpart V
and that § 1910.269 be amended to
include limitations on the work that can
be performed by employees working
alone on voltages of 600 volts or less,
explaining:
First and foremost, contractor crews,
unless assigned only to perform minor
maintenance, should never employ a one
person crew. Contractor crews are generally
performing new construction type work that
usually requires several employees on each
job. For the purposes of 1926 Subpart V,
reference to a one person crew should not be
included.
For the purpose of 1910.269 and
maintenance work, this section should be
clarified. Just because the work involves
voltages under 600 volts, there should be
limitations as to how much a one person
crew can perform. For example, the job
requires open wire 1/0 aluminum secondary
conductors that were burned down by a tree
limb to be reinstalled up a pole. This will
include clearing the downed tree parts,
splicing the conductors, and sagging and
dead-ending the conductors. Some of this
work will even be performed de-energized,
but exposure to other energized conductors is
a possibility. There is no reason to put one
person in this situation. [Ex. 0230]
OSHA does not agree with the
comments suggesting that work on
circuit parts energized at 600 volts and
less is safe. When § 1910.269 was
promulgated in 1994, the Agency
concluded that there was ‘‘insufficient
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evidence in the record as to whether or
not it is safe for qualified employees to
work alone on live parts energized at’’
600 volts or less (59 FR 4381). In
developing the subpart V proposal,
OSHA examined more recent accident
data. Table 5 shows the number of
electrocutions for various voltage ranges
for the years 1991 through 1998. In the
years 1991 to 1994, an average of 3
fatalities occurred per year involving
voltages of 600 volts or less. For the
years 1995 to 1998, when § 1910.269
was fully in effect, the average dropped
slightly to 2.5 fatalities per year.
TABLE 5—FATALITIES BY VOLTAGE AND YEAR
Year
1991
1992
1993
1994
1995
1996
1997
1998
600 V or less
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
.................................................................................................................
601 V to 20
kV
3
5
3
1
2
4
1
3
24
24
23
21
22
16
6
13
100 kV and
higher
20 to 80 kV
2
2
3
2
4
0
3
0
1
0
1
2
5
2
1
1
Source: OSHA database of electric power generation, transmission, and distribution accidents (Ex. 0004). These data include only cases involving electrocution in which the voltage was indicated in the accident abstract.
These data indicate that, in general,
there is a substantial risk of death for
employees working on voltages of 600
volts or less. Although it appears as
though exposures to live parts energized
at 600 volts or less result in relatively
few accidents, OSHA concludes that
these voltages are capable of killing
workers. Consumers Energy’s injury
rates are not relevant here. The primary
purpose of the two-person rule is the
prevention of electrocution.
Electrocutions are the result of electric
shocks, which are a very low probability
event, and have no significant effect on
injury rates even when they occur in
substantial numbers among all
employees performing work addressed
by the final rule.172
In addition, the types of work
commonly assigned to crews of more
than one employee include line
installation and removal and the use of
mechanical apparatus to lift or position
material (59 FR 4380). This heavy type
of work seems more likely to cause
sprains and strains, lacerations,
contusions, and scratches and abrasions,
which form the majority of line worker
injuries, than the lighter type of work
commonly assigned to employees
working alone, such as switching (Ex.
0081). OSHA, therefore, concludes that
it is unlikely that the increased
incidence rates experienced by
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172 Electric
shocks are responsible for a tiny
proportion of the total number of injuries suffered
by workers in the electric utility industry, as shown
in ‘‘Assessment of the Benefits of the Proposed
Standard on Electric Power Generation,
Transmission, and Distribution; Coding Results and
Analysis,’’ which is an analysis of reports of
injuries in the electric utility industry for calendar
year 1989 (Ex. 0081). As this report shows, the
leading categories for nature of injury are sprains
and strains, lacerations, contusions, and scratches
and abrasions, which together accounted for over 70
percent of the injuries. Electric shock accounted for
only 0.7 percent of the injuries.
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Consumers Energy for employees
working together are due to an increased
incidence of electric shock. OSHA does
not believe, and it is illogical to suggest,
that an employee working alone is less
likely to die as the result of an electric
shock than an employee working in an
environment in which another
employee is available to provide
emergency assistance in the event of a
shock incident.
OSHA also disagrees with comments
arguing that requirements for proper use
of electrical protective equipment and
other safety-related work practices make
safe any work performed on circuit parts
energized at 600 volts or less. The use
of personal protective equipment and
compliance with other OSHA-required
work practices may well protect against
hazards posed by these voltages;
however, in the 1994 § 1910.269 final
rule, the Agency adopted the twoperson rule to supplement work practice
and PPE requirements for certain types
of electrical work.
In the rulemaking on the 1994
§ 1910.269 final rule, OSHA examined
the record to determine what operations
posed sufficient residual risk to warrant
the presence of a second person. The
Agency found that some work involving
installations operating at more than 600
volts posed hazards requiring the
presence of a second person, but other
work was safe enough for an employee
to perform alone. In this rulemaking,
OSHA is using the same approach to
examine the need for a second person at
voltages of 600 volts and less. Because
there are relatively few accidents
involving circuit parts energized at 600
volts or less, the Agency believes it is
reasonable to assume, at these voltages,
that there are few types of work that
cannot be safely performed without the
presence of a second person. However,
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OSHA agrees with IBEW that some lowvoltage operations require at least two
persons. There are many types of lowvoltage work in which employees suffer
electric shock, including installation,
repair, and testing. Employees have
sustained low-voltage electric shocks
working on transformers, circuit
breakers, and conductors.
Although the Agency is in general
agreement with IBEW about the need for
two persons for some work involving
parts energized at 600 volts or less,
OSHA decided not to require the
presence of a second person during any
specific types of work at such voltages
because the record does not specifically
indicate which low-voltage operations
are hazardous enough to warrant a
second-person requirement (except
when a worker could contact lines or
circuit parts energized at more than 600
volts while working on parts energized
at less than 600 volts).
IBEW listed the following factors that
limit when a one-person crew performs
work: complexity of the tasks, hot-stick
versus the rubber-glove work method,
voltage-range limitations, limited time
spent on a specific task, maintenance
work only, and other factors (Ex. 0230).
As already noted, with respect to lowvoltage work, the union further
commented:
Just because the work involves voltages
under 600 volts, there should be limitations
as to how much a one person crew can
perform. For example, the job requires open
wire 1/0 aluminum secondary conductors
that were burned down by a tree limb to be
reinstalled up a pole. This will include
clearing the downed tree parts, splicing the
conductors, and sagging and dead-ending the
conductors. Some of this work will even be
performed de-energized, but exposure to
other energized conductors is a possibility.
There is no reason to put one person in this
situation. [Id.].
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IBEW’s comments do not provide the
specificity about hazardous low-voltage
tasks that the Agency determined is
missing from the record. The purpose of
the second-person requirement is to
prevent fatalities from electric shock.
Thus, the complexity of the job and time
spent during the deenergized portion of
the work have no bearing on the
likelihood of an electric shock occurring
and, accordingly, no bearing on whether
OSHA should require a second person.
Finally, in IBEW’s specific example of
low-voltage work, a second person is
already required under the final rule if
the employee is exposed to parts
energized at more than 600 volts.173 The
remaining factors listed by IBEW do not
appear to be related to the causes of
low-voltage electrical accidents in the
record. Although OSHA is not adopting
any two-person requirements for work
exposing employees to contact with
lines or circuit parts energized at 600
volts or less, the Agency anticipates
that, in certain situations, an employer
will need to ensure that at least two
trained persons are present for such
work to satisfy the employer’s
obligations under the general duty
clause of the OSH Act (Section 5(a)(1)).
(See Chapter 4, Section III of OSHA’s
Field Operations Manual (FOM), CPL
02–00–150 (https://www.osha.gov/pls/
oshaweb/owadisp.show_document?p_
table=DIRECTIVES&p_id=4935), for a
discussion of general duty clause
violations.)
IBEW pointed to new construction as
an example of work necessitating the
presence of more than one worker. New
construction involves the installation of
lines and equipment. Final paragraph
(b)(3)(i) requires a second person for
installation of lines or equipment if an
employee is exposed to contact with
other parts energized at more than 600
volts. IBEW’s recommendation would
also require a second person when an
employee is exposed to electric-shock
hazards of 600 volts or less and when
electric-shock hazards are not present at
all. OSHA decided against requiring a
second person for lower voltage work
for the reasons explained previously.
Mr. Junga recommended that the
standard require a second person when
‘‘work is to be performed on electrical
lines operating at primary voltages’’ (Ex.
0197). He stated:
If a person working alone gets in contact
with energized primary voltages and they are
working alone they will die. No one will be
173 Final paragraph (b)(3)(i)(B) requires the
presence of a second employee when an employee
installing deenergized lines is exposed to contact
with parts energized at more than 600 volts. The
operating voltage of the deenergized line has no
bearing on whether a second person is required.
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there to assist, provide CPR, use an AED,
provide first aid or even call for help. [Id.]
OSHA decided not to adopt Mr.
Junga’s recommendation. The Agency
believes that the language adopted in
final § 1926.960(b)(3)(i) adequately
captures work in which employees are
exposed to contact with parts energized
at more than 600 volts (primary voltage).
The exceptions to the two-person rule,
adopted in final § 1926.960(b)(3)(ii),
generally are limited to work that does
not expose the employee to contact with
parts energized at more than 600
volts.174 OSHA believes that final
§ 1926.960(b)(3) ensures that employees
at a substantial risk of electric shock are
protected by the presence of a second
person.
Mr. Daniel Shipp with ISEA
recommended that OSHA require the
presence of a second person whenever
fall hazards are present in combination
with electric-shock hazards (Ex. 0211).
He pointed to risks associated with
prolonged suspension in personal fall
protection equipment, commenting:
In a recent Safety and Health Information
Bulletin, OSHA describes the hazard of
prolonged suspension in a full body harness
following a fall event. OSHA SHIB 03–24–
2004 cites the hazard of orthostatic
intolerance, recommending prompt rescue of
suspended personnel, especially when other
complicating factors may be present. A fall
precipitated by exposure to an energized
electrical source will require immediate
rescue of the incapacitated employee and
removal to a safe working level where
medical aid can be administered. [Id.]
OSHA recognizes the hazards
associated with prolonged suspension
in full body harnesses. Therefore,
§ 1926.502(d)(20), which applies to
personal fall arrest equipment, requires
employers to provide for prompt rescue
of employees in the event of a fall or
assure that employees are able to rescue
themselves. The Agency believes that
final § 1926.960(b)(3) will assure the
rescue of employees exposed to electricshock hazards of more than 600 volts.
Also, as explained previously, under
Section 5(a)(1) of the OSH Act,
employers may need to adopt additional
measures beyond the measures required
in final subpart V to assure prompt
rescue of employees exposed to lower
voltage electric-shock hazards. Because
hazards associated with suspension in
full body harnesses already are covered
in § 1926.502(d)(20), OSHA sees no
need to address them further in subpart
V.
174 Under final § 1926.960(b)(3)(ii)(C), one
employee working alone may perform emergency
repair work involving parts energized at more than
600 volts, but only to the extent necessary to
safeguard the general public.
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For all of these reasons, OSHA
concludes that the evidence in this
rulemaking record does not support
adding a two-person requirement for
any operation that existing
§ 1910.269(l)(1) permits an employee to
perform alone.
Some commenters requested
clarification of the relationship between
the two-person rule in paragraph (b)(3)
and the requirements on minimum
approach distances, which are
discussed later in this section of the
preamble (Exs. 0209, 0230; Tr. 903). Mr.
Thomas Frank of Ameren Corporation
requested that OSHA revise the
language so that the two-person rule
applies only when an employee
performs work within the applicable
minimum approach distance (Ex. 0209).
In addition, Mr. Edwin Hill with IBEW
suggested that there is confusion in the
industry about the applicability of
minimum approach distances to
employees working alone, commenting:
The current language in 1910.269 is many
times misunderstood. [S]ome people believe
that a worker can get closer than the
minimum approach distance to an energized
primary conductor when working alone. This
should not be true. . . .
If the standard is going [to] allow a one
person crew to work around energized
primary conductors of voltages greater than
600 volts, then it should be clear that
minimum approach distances must be
maintained. In the case of underground
distribution equipment, the same detailed
restrictions should be explained. Many times
during an underground circuit outage, a
worker opens the equipment doors and is
within the minimum approach distances of
the energized cables, both ‘‘live front
terminations’’ and ‘‘dead front elbows’’. The
established minimum approach distances
should be maintained at all times, in any
work situation, to ensure worker safety. If
these distances cannot be maintained, rubber
insulating cover-up equipment should be
installed. [Ex. 0230]
In this regard, paragraph (b)(3) does
not excuse compliance with otherwise
applicable minimum approach-distance
requirements. OSHA previously
clarified existing § 1910.269(l)(1), from
which it adopted final paragraph (b)(3),
explaining that an employee is
‘‘exposed to contact’’ for purposes of
§ 1910.269(l)(1) when he or she is in a
working position from which he or she
can reach or take a conductive object
within the electrical component of the
minimum approach distance.175 (See
the summary and explanation for final
§ 1926.960(c)(1) later in this section of
the preamble for a discussion of the
175 See the letter of interpretation dated October
18, 1995, to Mr. Lonnie Bell, https://www.osha.gov/
pls/oshaweb/owadisp.show_document?p_table=
INTERPRETATIONS&p_id=21981.)
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electrical component of the minimum
approach distance.) OSHA notes that an
employee who is ‘‘exposed to contact’’
with an energized part under this
interpretation is still ‘‘exposed to
contact’’ with the energized part even
when insulation covers the part, the
employee, or both. (See final
§§ 1910.269(x) and 1926.968 (defining
‘‘exposed’’ as not isolated 176 or
guarded;177 merely covering a conductor
or an employee with insulation does not
provide guarding or isolation).) 178 The
Agency also notes that a second
employee may be required when
employees can reach or take a
conductive object into the electrical
component of the minimum approach
distance as they are approaching or
leaving their final work positions or
moving from one work position to
another.
Mr. Junga with UWUA Local 223 was
concerned that ‘‘[e]mployers are
176 The proposed rule and existing § 1910.269 did
not define ‘‘isolated.’’ However, existing Subpart V
did define that term in § 1926.960 as ‘‘not readily
accessible to persons unless special means of access
are used.’’ This definition is identical to the
definition of this term in OSHA’s electrical
standards for general industry (§ 1910.399) and
construction (§ 1926.449) and in the 2002 NESC
(Ex. 0077). This definition also is consistent with
the use of the term ‘‘exposed to contact’’ in final
paragraph (b)(3). OSHA believes that defining
‘‘isolated’’ will help clarify the final rule.
Consequently, OSHA included the definition of
‘‘isolated’’ in final §§ 1910.269(x) and 1926.968.
The Agency also included ‘‘exposed to contact’’ as
a synonym in the definition of ‘‘exposed’’ to clarify
that the definition of ‘‘exposed’’ also applies to the
term used in final paragraph (b)(3).
177 Section 1926.968 defines ‘‘guarded’’ as
‘‘[c]overed, fenced, enclosed, or otherwise
protected, by means of suitable covers or casings,
barrier rails or screens, mats, or platforms, designed
to minimize the possibility, under normal
conditions, of dangerous approach or inadvertent
contact by persons or objects.’’ Subpart V
recognizes two methods of guarding: barriers (or
enclosures), which serve to ‘‘minimize the
possibility . . . of . . . inadvertent contact,’’ and
guarding by location, which serves to ‘‘minimize
the possibility . . . of dangerous approach.’’ As
explained in the note to final § 1926.966(f)(1), the
2002 NESC contains guidelines for the dimensions
of clearance distances about electric equipment in
substations. OSHA considers these clearance
distances as minimizing the possibility of
dangerous approach for employees and considers
energized parts conforming to the clearance
distances in the 2002 NESC to be guarded, unless
employees bypass those distances (for example, by
accessing a ‘‘guarded’’ area). (See also the summary
and explanation for final § 1926.966(f)(1) later in
this section of the preamble.)
178 IEEE Std 516 further clarifies the treatment of
insulated cables (Exs. 0041, 0532). For example,
Section 4.9.1 of IEEE Std 516–2009 states:
The following are considered to be live parts at
their normal operating voltage unless they are
properly grounded:
* * * * *
—Conductors—insulated unless they have solidly
grounded and tested shields (The condition of the
conductor insulation exposed to weather is
unknown and may be damaged or defective.) [Ex.
0532]
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pushing for more one-person crews and
asking [them] to do more [of] the work
that historically has been performed by
two or more qualified persons’’ (Ex.
0197).
In response, OSHA reiterates that the
exceptions from the two-person rule,
which are specified in final paragraph
(b)(3)(ii) and are based on existing
§ 1910.269(l)(1)(ii), will be interpreted
and applied narrowly. Paragraph
(b)(3)(ii)(A) permits an employee to
work alone to perform routine circuit
switching, as long as the employer can
demonstrate that conditions at the site
allow safe performance of this work.
Employees have been injured during
switching operations when unusual
conditions, such as poor lighting, bad
weather, or hazardous configuration or
state of repair of the switching
equipment, were present (269-Ex. 9–2).
If there is poor lighting, for example, the
employer may be unable to demonstrate
that the operation can be performed
safely by one employee; the employer
could, however, elect to provide
supplemental lighting adequate to make
it safe for an employee to work alone.
Paragraph (b)(3)(ii)(B) permits one
employee to work alone with live-line
tools if the employee is positioned so
that he or she is neither within reach of,
nor otherwise exposed to contact with,
energized parts. Accidents involving
hot-stick work have typically occurred
only when the employee was close
enough to energized parts to be
injured—either through direct contact or
by contact through conductors being
handled (269-Ex. 9–2).
Finally, paragraph (b)(3)(ii)(C) permits
one employee to work alone on
emergency repairs necessary to
safeguard the general public. OSHA will
generally consider situations in which
there is a downed energized power line,
an energized power line on an occupied
vehicle, or a service outage to lifesupport equipment to be emergency
situations for which an employee can
work alone to safeguard the public.
Whether outages to street lights, traffic
lights, or homes are emergency
situations for purposes of final
paragraph (b)(3)(ii)(C) depends on many
factors, including the extent and
expected duration of the outage and the
availability of alternative means of
protecting the public, such as the
availability of police or other officials to
manage or stop traffic at intersections in
the absence of working stoplights.
Because hospitals and similar patientcare facilities usually have backup
generators, outages of circuits supplying
these facilities will not generally be
deemed to fall under final paragraph
(b)(3)(ii)(C).
PO 00000
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Minimum Approach Distances
Paragraph (c)(1) in the final rule sets
requirements for minimum approach
distances. Paragraph (c)(1)(i) requires
employers to establish minimum
approach distances no less than the
distances computed by the equations set
in Table V–2 for ac systems or Table V–
7 for dc systems. (The equations in
Table V–2 in the final rule are described
and explained later in this section of the
preamble.) Paragraph (c)(1)(iii) of the
final rule requires the employer to
ensure that no employee approaches, or
takes any conductive object, closer to
exposed energized parts than the
employer’s established minimum
approach distance, except as permitted
in paragraphs (c)(1)(iii)(A), (c)(1)(iii)(B),
and (c)(1)(iii)(C) (as explained later in
this section of the preamble).
Table V–2 provides equations for the
employer to use to compute minimum
approach distances under paragraph
(c)(1)(i). The equations vary depending
on voltage and, for phase-to-phase
voltages of more than 72.5 kilovolts, on
whether the exposure is phase-to-phase
or phase-to-ground.
Paragraph (c)(1)(ii) in the final rule
provides that, no later than April 1,
2015, for voltages over 72.5 kilovolts,
the employer determine the maximum
anticipated per-unit transient
overvoltage, phase-to-ground, through
an engineering analysis or assume a
maximum anticipated per-unit transient
overvoltage, phase-to-ground, in
accordance with Table V–8. The
employer must make any engineering
analysis conducted to determine
maximum anticipated per-unit transient
overvoltage available upon request to
affected employees and to the Assistant
Secretary or designee for examination
and copying. When the employer uses
portable protective gaps to control the
maximum transient overvoltage, final
paragraph (c)(1)(ii) also requires that the
value of the maximum anticipated perunit transient overvoltage, phase-toground, must provide for five standard
deviations between the statistical
sparkover voltage of the gap and the
statistical withstand voltage
corresponding to the electrical
component of the minimum approach
distance.
Under Appendix B to existing
§ 1910.269, employers use engineering
analyses to determine any reductions in
maximum transient overvoltages below
the maximum values listed in Table R–
7 and Table R–8. Also under Appendix
B to existing § 1910.269, when an
employer is using portable protective
gaps, it determines minimum approach
distances using a specific methodology
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that provides for five standard
deviations between the statistical
sparkover voltage of the gap and the
statistical withstand voltage
corresponding to the electrical
component of the minimum approach
distance at the worksite. OSHA
incorporated both of these performance
requirements in final paragraph
(c)(1)(ii). To explain terms used in final
paragraph (c)(1)(ii), OSHA also added
definitions of ‘‘statistical sparkover
voltage’’ and ‘‘statistical withstand
voltage’’ to final § 1926.968. Statistical
sparkover voltage is a transient
overvoltage level that produces a 97.72percent probability of sparkover (in
other words, two standard deviations
above the voltage at which there is a 50percent probability of sparkover).
Statistical withstand voltage is a
transient overvoltage level that produces
a 0.14-percent probability of sparkover
(in other words, three standard
deviations below the voltage at which
there is a 50-percent probability of
sparkover). OSHA based both
definitions on definitions in IEEE Std
516–2009 (Ex. 0532).
Table V–7 contains minimum
approach distances for dc systems. In
Table V–7, the applicable minimum
approach distance depends on the
maximum anticipated per-unit transient
overvoltage and the maximum line-toground voltage. In accordance with final
paragraph (c)(1)(ii) and Table V–8, an
employer using Table V–7 must
determine the maximum anticipated
per-unit transient overvoltage through
an engineering analysis that is made
available upon request to affected
employees and to the Assistant
Secretary or designee for examination
and copying or must assume a
maximum per-unit transient overvoltage
of 1.8.
Paragraph (c)(1)(i) makes it clear that
the required minimum approach
distances are based on engineering
principles that OSHA adopted in the
final rule. The Agency is adopting the
equations and the engineering
principles behind the minimum
approach distances rather than just
setting distances as it did when it
promulgated § 1910.269 in 1994. This
paragraph also ensures that the
minimum approach distance
maintained by each employee is
appropriate for the workplace rather
than for the industry in general. OSHA
believes that this approach will better
protect each employee than existing
§ 1910.269 and the proposed rule.
The minimum approach distances set
by Table V–2 for phase-to-phase system
voltages of 72.5 kilovolts and less do not
vary based on worksite conditions
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provided the altitude is 900 meters
(3,000 feet) or less above sea level.
Therefore, OSHA calculated the
minimum approach distances for these
voltages and listed them in Table V–5 in
the final rule. Note 1 in Table V–2
provides that, for voltages up to 72.5
kilovolts, employers may use the
precalculated minimum approach
distances in Table V–5 provided the
worksite is at an elevation of 900 meters
or less.
Minimum approach distances for
phase-to-phase system voltages of more
than 72.5 kilovolts will vary depending
on conditions present at the worksite
and possibly the work practices used by
employees. Parameter C in the equation
for these voltages varies depending on
whether an insulated tool or conductive
object is in the approach distance (gap)
between the employee and the
energized part (if the employee is at
ground potential or at the potential of a
different energized part) or between the
employee and ground (if the employee
is at the potential of the energized part).
For phase-to-ground exposures, if the
employer can demonstrate that there is
only air in this gap, then C equals 0.01.
For phase-to-phase exposures, if the
employer can demonstrate that no
insulated tool spans the gap and that no
large conductive object is in the gap,
then C equals 0.01. In all other cases, C
equals 0.011. When an employee is
climbing on a structure or performing
live-line barehand work, OSHA expects
that there normally will only be air
present in the gap, and the equation will
produce a smaller minimum approach
distance than if the employee is using
an insulated tool to work on energized
parts.179
The saturation factor, a, in the
equation for system voltages of more
than 72.5 kilovolts varies depending on
whether the exposure is phase-toground or phase-to-phase. For phase-toground exposures, the saturation factor
will be reduced slightly, resulting in
smaller minimum approach distances.
As explained in Note 3 in Table V–2,
unless the employer can demonstrate
that no insulated tool spans the gap and
that no large conductive object is in the
gap, the employer must calculate the
saturation factor using the phase-toground equations (with the peak voltage
for phase-to-phase exposures), even for
phase-to-phase exposures.
179 Live-line barehand work is work performed
with the employee at the same potential as one of
the phase conductors. The employee is insulated,
by air or another insulating medium, from the other
phase conductors and from ground.
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Finally, T 180 in the equation for
phase-to-phase system voltages of more
than 72.5 kilovolts represents the
maximum phase-to-ground anticipated
per-unit transient overvoltage, which
can vary from worksite to worksite.
For voltages over 72.5 kilovolts,
employers may use the minimum
approach distances in the tables in
Appendix B provided the worksite is at
an elevation of 900 meters or less. The
tables in Appendix B contain minimum
approach distances for various values of
T. In accordance with final paragraph
(c)(1)(ii), the employer must determine
T through engineering analysis or use
the maximum T from Table V–8.
For phase-to-phase system voltages of
more than 5,000 volts, the altitudecorrection factor applies when the
worksite is at an elevation of more than
900 meters above sea level. When the
worksite is at these higher elevations,
the employer must use the appropriate
altitude correction factor from Table V–
4 when calculating minimum approach
distances. Table V–2 explains how to
apply the altitude correction factors in
computing minimum approach
distances.
As noted earlier, paragraph (c)(1)(i)
requires employers to establish
minimum approach distances. Because
the elevation and maximum transient
overvoltage may vary from worksite to
worksite, each minimum approach
distance established by the employer
must be appropriate for the worksite
involved. Employers can avoid
establishing separate distances for every
worksite by using worst-case values for
elevation and T or by grouping
worksites by ranges for elevation and T.
Paragraph (c)(1) of proposed
§ 1926.960 would have required
employers to ensure that employees
maintain minimum approach distances
from exposed energized parts. Proposed
Table V–2 through Table V–6 specified
the minimum approach distances. This
proposed provision was borrowed from
existing § 1910.269(l)(2), although, as
described later, OSHA proposed to
make minor changes to the minimum
approach distances listed in the existing
§ 1910.269 tables.
Electric power systems operate at a
given nominal voltage. However, the
actual voltage on a power line varies
above and below that nominal voltage.
For brief periods, the instantaneous
voltage on a line can be 3 or more times
its nominal value (Ex. 0532).
The safe minimum approach distance
assures that an electric arc will not
180 T is the ratio of the 2-percent statistical
switching overvoltage expected at the worksite to
the nominal peak line-to-ground voltage of the
system.
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form, even under the most severe
transient overvoltages that can occur on
a system and even when the employee
makes errors in maintaining the
minimum approach distance. To
determine what this distance is for a
specific voltage, OSHA must first
determine the size of the air gap that
must be present to prevent arc-over
during the most severe overvoltage that
can reasonably be expected to occur on
the system. This gap is the electrical
component of the minimum approach
distance. To determine the minimum
safe approach distance, OSHA must add
extra distance to account for ergonomic
considerations (that is, human error).
The electrical component depends on
five factors:
(1) The maximum voltage,
(2) The wave shape of this voltage,
(3) The configuration of the
‘‘electrodes’’ forming the end points of
the gap,
(4) The insulating medium in the gap,
and
(5) The atmospheric conditions.
In existing § 1910.269, and in the
proposal for this rulemaking, OSHA
borrowed its approach for setting
minimum approach distances from a
consensus standard, namely the NESC.
OSHA based the minimum approach
distances in existing § 1910.269 on the
1993 edition of the NESC. In this
rulemaking, OSHA proposed to adopt
slightly revised minimum approach
distances for both § 1910.269 and
subpart V; the revised minimum
approach distances in the proposal were
drawn from the updated, 2002 edition of
the NESC.
To develop the minimum approach
distance tables for the 1993 standard,
NESC Subcommittee 8 adopted the
following principles:
• ANSI/IEEE Std 516 was to be the
electrical basis of the NESC Rules for
approach distances for alternating- and
direct-current voltages above 72.5
kilovolts.181 Distances for lower voltages
were to be based on ANSI/IEEE Std 4.
The application of ANSI/IEEE Std 516
included the formula used by that
standard to derive electrical clearance
distances.
• Altitude correction factors were to
be in accordance with ANSI/IEEE Std
516.
• The maximum design transientovervoltage data to be used in the
181 ANSI/IEEE Std 516–1987 (the edition in effect
when NESC Subcommittee 8 revised the minimum
approach distances for the 1993 NESC) listed values
for the electrical component of the minimum
approach distance, both for air alone as an
insulating medium and for live-line tool sticks in
air, that were accepted as being accurate when the
standard was adopted (by IEEE) in 1987.
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development of the basic approach
distance tables were:
• 3.0 per unit for voltages of 362
kilovolts and less
• 2.4 per unit for 500 to 550 kilovolts
• 2.0 per unit for 765 to 800 kilovolts
• All phase-to-phase values were to
be calculated from the EPRI
Transmission Line Reference Book for
115 to 138 kilovolts.
• An ergonomic-movement factor
(inadvertent component) that accounted
for errors in judging the approach
distance was to be added to all basic
electrical approach distances (electrical
component) for all voltage ranges. A
distance of 0.31 meters (1 foot) was to
be added to all voltage ranges for the
ergonomic component. An additional
0.3 meters (1 foot) was to be added to
voltage ranges below 72.6 kilovolts.
• The voltage reduction allowance for
controlled maximum transient
overvoltage was to be such that the
minimum allowable approach distance
was not less than the approach distance
specified for the highest voltage listed
for the given range.
• The transient overvoltage tables
were to be applied only at voltage
ranges inclusive of 72.6 to 800 kilovolts.
All tables were to be established using
the higher voltage of each separate
voltage range.
After publication of OSHA’s proposed
rule in 2005, the IEEE technical
committee responsible for revising
Standard 516 identified what in its view
was an error in calculating the
minimum approach distances in the
IEEE standard that potentially affected
the validity of the minimum approach
distances in the 2002 NESC and OSHA’s
proposed rule. IEEE Std 516 was revised
in 2009 to address the issue identified
by the technical committee. (The error
identified by the IEEE committee is
discussed, at length, later in this section
of the preamble.) In light of the IEEE
revision process, OSHA twice reopened
the record on subpart V, first in October
2008 and again in September 2009, to
solicit additional comments on
minimum approach distances. (See 73
FR 62942, Oct. 22, 2008; 74 FR 46958,
Sept. 14, 2009.) The Agency requested
information on whether there was an
error in the method OSHA used to
calculate the proposed minimum
approach distances and on what basis
OSHA should set minimum approach
distances. A public hearing was held on
these issues in October 2009.
In response to the issues OSHA raised
about the minimum approach distances,
EEI, IBEW, and the NESC urged the
Agency to delay issuing revised
minimum approach distances until after
IEEE approved the next update of the
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NESC in 2012.182 (See, for example, Exs.
0545.1, 0551.1, 0552.1; Tr2. 40–41, 72–
75, 151–154.) The commenters
maintained that, in writing the
respective standards, the NESC
subcommittees give greater weight to
the practical effects of its rules than
does the IEEE subcommittee responsible
for IEEE Std 516. The commenters also
maintained that an OSHA standard
setting minimum approach distances
that turn out to be different from the
distances in the 2012 NESC could cause
confusion.
The chair of Subcommittee 8 of the
NESC, Mr. James Tomaseski, testified
that the NESC serves as the authority on
safety requirements for electric power
systems, that (at the time of his
testimony) the NESC had yet to act on
the revised methodologies in IEEE Std
516–2009 for calculating minimum
approach distances, and that NESC
Subcommittee 8 would transcribe the
engineering information contained in
the 2009 IEEE 516 standard into a userfriendly format (Tr2. 34–41).183 He
stated:
NESC’s Subcommittee 8 has the task of
trying to make sense of and keep up with this
evolving problem [of adopting adequate
minimum approach distances]. Simply put,
the IEEE 516 MAD Tables as they are
published today in that [2009] guide are
confusing.
This takes us to the point what
Subcommittee 8 recommends to OSHA for
this Rule making. The agency should realize
this is a difficult issue, not only for the
Technical Subcommittee responsible for the
different Codes, but most importantly for the
users of the Rules. The MAD concept has
been around for a long time. Even though
new engineering principles continue to be
developed, industry performance associated
with these rules [has] to be considered.
*
*
*
*
*
When OSHA revise[s] this Rule, these
changes are somewhat permanent. This rule
will probably not be revised again for a long
time. Subcommittee 8 wants to do their part
to make sure the MAD [c]oncepts get fixed
correctly this time. The NESC Subcommittee
8 recommends that OSHA leave the record
open until the time the Subcommittee has the
opportunity to review public comments as to
what MAD values should be in the NESC.
[Tr2. 39–41]
IBEW also maintained that the OSHA
standard should be consistent with the
2012 NESC (Tr2. 151–152). Testifying
on behalf of IBEW, Mr. Donald Hartley
stated:
182 IEEE approved the 2012 NESC on April 14,
2011, and ANSI approved the 2012 NESC as an
American National Standard on June 3, 2011.
183 The 2012 NESC adopts the 2009 IEEE Std 516
distances for certain voltage ranges and values of T
and permits an engineering determination of
minimum approach distances as an alternative.
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The IBEW believes the responsibility for
developing [minimum approach distances
resides with] the NESC. Technical
Subcommittee 8 on Work Rules, the body
responsible for writing Part IV of the NESC
where MAD Rules and Tables are located,
should [set the rules] for OSHA to follow.
The NESC is adopted by many states in the
U.S. The U.S. [Rural] Electric Service
requires member cooperatives to follow the
NESC if they receive government loans.
Many public power utilities, municipalities
are not covered by OSHA. The NESC in these
instances becomes the rule to follow.
*
*
*
*
*
The IBEW strongly recommends that
OSHA keep this record open until
Subcommittee 8 has the opportunity to
review public comment on this issue and
develop final Code Language on the MAD
principles and Rules. [Id.]
EEI argued that, if OSHA failed to
follow NESC action on minimum
approach distances, the final rule could
differ from the 2012 NESC and create
confusion for the electric utility
industry (Ex. 0545.1). Mr. Stephen
Yohay, counsel for EEI, described the
potential for confusion over differing
standards as follows:
The other question you asked is whether
[there is] confusion in the industry [resulting
from the fact that there are currently
differences between the minimum approach
distances in the existing OSHA standards
and the distances in the consensus
standards], and I am going to answer this
anecdotally based on my experience in
representing employers in this industry.
I have often, not often, but more than
occasionally heard confusion expressed as to
which standards are the applicable
standards, whether they are the OSHA
standards, whether they are the NESC
standards. And as you heard Mr. Tomaseski
say various companies adopt different
[distances] for their own work practices.
Now when you throw in the element of
State plans, you further confuse the mix. So
I think there is some confusion and I think
you all heard him say here earlier, and I
think we all agree it is time for there to be
consistency. [Tr2. 102–103]
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EEI also pointed out that Section
6(b)(8) of the OSH Act requires OSHA
to explain deviations from national
consensus standards (Ex. 0545.1). Mr.
Charles Kelly testified to this point on
behalf of EEI, as follows:
Section 6(b)(8) of the Act expresses that
OSHA standards should not deviate from
National Consensus Standards without an
adequate statement of reason.
The NESC Committee may or may not
adopt the precise distances stated in the IEEE
documents. Therefore, if OSHA incorporates
the IEEE distances in a final standard that is
promulgated in the next year or so, OSHA
[may] soon find its final standard at odds
with even the newest version of the NESC.
The NESC, however, is well recognized as
the preeminent National Consensus Standard
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on clearance distances for electric utility
work on high voltage lines and equipment.
Such a result could only create confusion in
the industry. [Tr2. 73]
Mr. Kelly also maintained that the NESC
gives greater weight to the practical
application of its rules than does IEEE
and that OSHA should adhere to its past
practice of basing its rules for minimum
approach distances on the NESC,
testifying:
[B]y virtue of the nature of its membership
and the mission of its Subcommittee 8, we
daresay with due respect to IEEE Committee
516, that the NESC’s final standards on Work
Rules tend to give more attention to the
practical impact that its Rules will have in
the workplace than do IEEE Technical
Standards.
[T]he 516 Standard is basically an
engineering standard and built that way on
the technical issues whereby the NESC
Subcommittee 8 Standard; it deals with the
Work Rules and Worker Protection more
specifically.
*
*
*
*
*
The usual cycle, and as I mean the
historical cycle that OSHA has followed, is
that the IEEE 516 Standard develops its
standard, ballots it and publishes the
standard over a period of time.
The NESC Subcommittee 8 reviews 516,
develops their standard, tables, ballots, and
publishes it in that order. Then OSHA
usually comes in and reviews the
documented proof by both groups, and
incorporates the NESC document into its
particular Rule.
The above scenario reflects the past
practices used by OSHA in its development
of standards affecting electric power
generation, transmission, and distribution
work. [Tr2. 73–74]
Although the Agency considered the
commenters’ suggestion to hold the
record for this rulemaking open until
IEEE approved the 2012 NESC, OSHA
concludes that it is unnecessary to
reopen the record to consider the 2012
NESC in this rulemaking. First, OSHA
does not agree that adopting minimum
approach distances that differ from the
distances in the 2012 NESC will
produce widespread confusion or lead
to additional risk for employees in the
electric power industry. As
acknowledged by some of the
rulemaking participants, the distances
in existing § 1910.269 and Subpart V
differed from the 2009 edition of the
NESC. (See, for example, Tr2. 53, 102–
103.) In fact, Mr. Tomaseski presented
slides showing that there were many
differences between the NESC, IEEE Std
516, and the OSHA standards (Ex.
0568). Rulemaking participants testified
that they were not aware of any specific
safety problems arising in the industry
by virtue of these discrepancies. (See,
for example, Tr2. 58, 102, 104). Also,
counsel for EEI admitted that
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20423
‘‘[e]mployers are at least following
OSHA standards. . . . Some are
exceeding the values that are in the
OSHA standards and adopting more
conservative standards’’ (Tr2. 104). In
any event, evidence in the record
indicates that consensus standards are
constantly evolving (see for example,
Tr2. 39–40, 142–143); therefore, if the
Agency were to adopt the minimum
approach distances from the 2012
NESC, it is likely that there would be
differences between the OSHA standard
and subsequent editions of the NESC.
OSHA does not believe there is merit
to the commenters’ suggestion that the
existence of State plan programs will be
an additional source of confusion for
employers. As noted in Section XI,
State-Plan Requirements, later in this
preamble, States with OSHA-approved
occupational safety and health plans
must adopt standards that are
equivalent to, and at least as protective
as, this final rule within 6 months of its
promulgation. Thus, States with State
plans will adopt provisions on
minimum approach distances that are at
least as protective as the provisions in
this final standard. On a technical issue
such as minimum approach distances,
OSHA expects that most States with
State plans will choose to incorporate
the federal provision as promulgated in
this final rule, although it is possible
that one or more of these States will
adopt more protective provisions. Even
if some States do adopt more protective
standards, OSHA does not believe that
the resultant differences will result in
any significant confusion for employers.
Public electric utilities in States with
State occupational safety and health
plans, including plans that cover only
State and local government employees,
will be required to comply with the
applicable State plan standards. Public
electric utilities in other States are not
covered by a State plan or by the
Federal OSHA standard and may choose
to adhere to the NESC. Private-sector
electric utilities must comply with the
Federal or State plan OSHA standards
that cover their worksites. This scheme
is well established, and OSHA does not
believe that employers will have
difficulty determining the applicable
requirements.
As noted earlier, IBEW suggested that
a conflict between the OSHA and the
2012 NESC minimum approach
distances could be problematic for loan
recipients in the United States
Department of Agriculture’s (USDA)
Rural Development Electric Programs
because, according to the union, utilities
receiving USDA loans must comply
with the NESC as a condition of their
loans (Tr2. 151). These USDA programs
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provide loans for electric services that
meet certain standards, and IBEW is
correct that the NESC is among the
standards that these services must meet
(7 CFR 1724.50). However, even if the
loan programs require compliance with
the minimum approach distances in the
NESC, employers can meet both the
OSHA and USDA loan-program
requirements simply by adopting the
more conservative (that is, larger)
minimum approach distances.
Therefore, differences between the
minimum approach-distance provisions
in this final rule and the minimum
approach distances in the 2012 NESC
should not be a problem for participants
in the USDA programs.
Second, the Agency does not believe
that considering public input on the
2012 NESC will result in a standard that
is more protective than the final rule.
The NESC minimum approach distances
are based on the minimum approach
distances in IEEE Std 516–2009, on
which OSHA already solicited public
comment and provided opportunity for
additional input at a public hearing (74
FR 46958). The 2012 NESC does not
include any additional support for the
IEEE minimum approach distances,
which, as explained later in this section
of the preamble, OSHA rejected. In
addition, reopening the record for this
rulemaking would further delay the
final rule. Therefore, OSHA concludes
that reopening the record to gather
additional public comment on the 2012
NESC minimum approach distances is
unwarranted.
Finally, in response to the
commenters’ references to Section
6(b)(8) of the OSH Act the Agency
concludes that, with respect to
minimum approach distances, this final
rule ‘‘will better effectuate the purposes
of [the] Act’’ than the 2012 edition of
the NESC. (See the discussion under the
heading OSHA’s requirements on
minimum approach distances better
effectuate the purpose of the OSH Act
than the national consensus standard,
later in this section of the preamble.)
Some commenters maintained that
the minimum approach distances in the
2005 proposed rule, which were based
on the 2002 NESC, were safe despite
any technical errors potentially made in
calculating those distances. (See, for
example, Ex. 0545.1; Tr2. 79–82.) The
commenters argued that industry
experience establishes the safety of the
existing minimum approach distances
in § 1910.269. (See, for example, Exs.
0545.1, 0551.1.)
American Electric Power argued
against adopting minimum approach
distances different from the minimum
approach differences in OSHA’s
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proposal, relying on calculations they
made that were taken from a paper by
Vaisman et al.184 (Ex. 0550.1). American
Electric Power described this method as
follows:
The method is based on calculating V50%
(critical flashover[185] voltage—CFO) and
determining distances from the V50% value of
conductor-to-conductor gap test data. The
V50% is derived from the required VW
(withstand voltage), using the line-to-line
overvoltage factor, TL-L. The required
distance for [minimum air insulation
distance] and MAD is then taken from . . .
Figure 13 in an IEEE paper by Vaisman
[footnote omitted] et al., 1993, which
represents conductor-to-conductor gap test
data from five different laboratories. The test
data is based on a = 0.50 (ratio between the
negative impulse crest and the phase to
phase voltage) which provides more
conservative results for V50% than a = 0.33
(Figure 12 of the aforementioned Vaisman
paper). [Id.]
American Electric Power calculated
V50% to be 2421 kilovolts for an 800kilovolt power line (id.). From Figure 13
of the Vaisman paper, American Electric
Power determined that the
corresponding minimum air-insulation
distance (the electrical component of
the minimum approach distance) was
6.52 meters (21.4 feet) and that the
minimum approach distance (with the
ergonomic component included as
explained later in this section of the
preamble) was 6.82 meters (22.4 feet).
American Electric Power contrasted this
with the corresponding 7.91-meter (26foot) minimum approach distance
proposed by OSHA and concluded that
the proposed value was adequately
protective (id.). (See, also, Ex. 0545.1, in
which EEI makes a similar argument
based on the Vaisman paper.)
As explained in greater detail later in
this section of the preamble, OSHA
concludes that the proposed minimum
approach distances do not provide
adequate safety for employees. In
184 Vaisman, R., Fonseca, J. R., Andrade, V. H. G.,
Almeida, M. A., Hattori, H. K., Melo, M. O. B. C.,
Teivelis, F., Fernandes, J. H. M., Silva, J. T. S., Dias,
L. E. N., Esmeraldo, P. C. V., and Samico, R. A. M.,
‘‘Switching Impulse Strength of Compact
Transmission Lines,’’ IEEE Transactions on Power
Delivery, Vol. 8, No. 3, July 1993 (Ex. 0555).
185 IEEE Std 516–2009 defines ‘‘flashover’’ as ‘‘[a]
disruptive discharge through air around and over a
surface of solid or liquid insulation, between parts
at different potential or polarity, produced by
application of voltage wherein the breakdown path
becomes sufficiently ionized to maintain an electric
arc’’ (Ex. 0532). That standard defines ‘‘sparkover’’
as ‘‘[a] disruptive discharge between preset
electrodes in either a gaseous or a liquid dielectric’’
(id.). Thus, the more technically correct term for an
electrical discharge across an air gap is ‘‘sparkover.’’
However, the term ‘‘flashover’’ has been used
historically for either event, and this preamble uses
these terms interchangeably. The critical flashover
distance, V50 or V50%, is the distance that will
flashover 50 percent of the time at a given voltage.
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addition, OSHA finds that there are two
basic problems with American Electric
Power’s comparison of the proposed
800-kilovolt minimum approach
distance and what it considers to be a
safe approach distance. First, as is clear
from the Vaisman paper (Ex. 0555), the
distances in Figure 13 of that paper
(which correspond to a = 0.50) are less
conservative than the distances in
Figure 12 of that paper (corresponding
to a = 0.33).186 The air-insulation
distance from Figure 12 appears to be
about 7.8 meters (25.6 feet). Adding the
0.31-meter (1-foot) ergonomic
component yields a comparable
minimum approach distance of 8.11
meters (26.6 feet), which is clearly more
protective than the 7.91-meter (26-foot)
minimum approach distance proposed
by OSHA in 2005.187
Second, the testing that serves as the
basis for Figures 12 and 13 of the
Vaisman paper determined the
switching impulse strength of two
conductors in parallel (Ex. 0555). From
the paper’s description of the test
procedure, OSHA concludes that the
testing did not account for different
configurations that could be present
during live-line work or for the presence
of workers and the tools and equipment
they would be using to perform this
work. As explained later in this section
of the preamble, different electrode
configurations and the presence of
workers and other conductive objects in
the gap between them can reduce the
electrical strength of the air gap
substantially. Thus, although American
Electric Power’s and EEI’s approach
may validly estimate the strength of a
power line while no work is being
performed, OSHA concludes that this
approach fails to represent employee
exposure adequately.
For reasons described later in this
section of the preamble, the Agency
concludes that there is a significant risk
to employees from the minimum
approach distances contained in
existing § 1910.269 and Subpart V. In
addition, OSHA concludes that it has
enough information in the rulemaking
record to set appropriate minimum
approach-distance requirements.
186 American Electric Power commented that an
a of 0.50 ‘‘provides more conservative results for
V50% than a = 0.33’’ (Ex. 0550.1). This comment
may be true, but it is irrelevant. For a given V50%,
an a of 0.33 produces a more conservative (that is,
greater) minimum approach distance, as is the case
here.
187 The quality of Figures 12 and 13 in the
original Vaisman paper is poor, and it is difficult
to accurately determine the distance (Ex. 0555). The
figures included in American Electric Power’s and
EEI’s exhibits, which apparently recreated Figure 13
from the Vaisman paper, were of much better
quality (Exs. 0550.1 and 0545.1).
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Consequently, the Agency decided that
it is necessary and appropriate to
include revised minimum approachdistance provisions in this final rule.
The ergonomic component of MAD.
The ergonomic-movement component of
the minimum approach distance is a
safety factor designed to ensure that the
employee does not breach the electrical
component of the minimum approach
distance in case he or she errs in judging
and maintaining the minimum approach
distance. In developing the minimum
approach distance tables for its 1993
standard, the NESC subcommittee based
the ergonomic-movement factor (the
ergonomic component of MAD) on
relevant data, including a typical arm’s
reach of about 610 millimeters (2 feet)
and a reaction time to a stimulus
ranging from 0.2 to more than 1.0
second (269-Ex. 8–19). As OSHA
explained in the preamble to the
proposal, the ergonomic-movement
factor must be sufficient for the
employee to be able to recognize a
hazardous approach to an energized line
and withdraw to a safe position so that
he or she does not breach the air gap
required for the electrical component of
the minimum approach distance (70 FR
34862). Thus, the ergonomic-movement
distance should equal the response time
multiplied by the average speed of an
employee’s movement plus the stopping
distance.188 The maximum reach (or
range of movement) may place an upper
bound on the ergonomic component.
The NESC subcommittee developing the
1993 standard used this information as
a basis for selecting appropriate
distances for two major voltage ranges:
1.1 to 72.5 kilovolts and 72.6 kilovolts
and more.
For system voltages up to 72.5
kilovolts, phase-to-phase, much of the
work is performed using rubber gloves,
and the employee is working within
arm’s reach of energized parts. The
ergonomic component of the minimum
approach distance must account for this
condition since the employee may not
have time to react and position himself
or herself out of danger. A distance of
0.61 meters (2 feet) for the ergonomic
component appears to meet this
criterion and was, therefore, adopted by
the NESC subcommittee developing the
1993 standard. This ergonomic
component remained the same in the
2007 NESC, except that the standard
applied it to voltages as low as 751 volts
188 This
calculation is comparable to the
calculation of total braking distance for a motor
vehicle. This distance equals the initial speed of the
vehicle times the driver’s reaction time plus the
stopping distance of the vehicle after the driver
applies the brakes.
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instead of 1100 volts (Ex. 0533).189
OSHA used this value in existing
§ 1910.269 for voltages of 1.1 to 72.5
kilovolts and proposed to use it in
Subpart V for voltages of 751 volts to
72.5 kilovolts. There were no objections
to this distance on the record.190
Therefore, for voltages of 751 volts to
72.5 kilovolts, the final rule adopts a
0.61-meter (2-foot) ergonomicmovement component of the minimum
approach distance, as proposed.
As OSHA explained in the preamble
to the proposed rule, the applicable
work practices change for operations
involving lines energized at voltages
over 72.5 kilovolts (70 FR 34862; 269Exs. 64, 65). Generally, live-line tools
are employed to perform the work while
equipment is energized. These tools
hold the energized part at a fixed
distance from the employee, ensuring
that the minimum approach distance is
maintained during the work operation.
Even when live-line tools are not used,
as during live-line barehand work,
employees use work methods that more
tightly control their movements than
when they perform rubber glove work,
and it is usually easier to plan how to
keep employees from violating the
minimum approach distance. For
example, employees planning a job to
replace spacers on a 500-kilovolt
overhead power line can circumscribe
an envelope (or bounds) of anticipated
movement for the job and ensure that
the working position they select keeps
this envelope entirely outside the
minimum approach distance. Thus, all
the employees’ movements during the
job can easily be kept within the
envelope. Additionally, there is limited
or no exposure to conductors at a
potential different from the one on
which work is being performed because
the distance between conductors is
much greater than the distance between
conductors at lower voltages and higher
voltage systems do not present the types
of congestion that are found commonly
on lower voltage systems. Consequently,
a smaller ergonomic component is
appropriate for higher voltages. The
NESC subcommittee developing the
1993 standard accepted a value of 0.31
meters (1 foot) for this component. This
ergonomic component also remained
the same in the 2007 NESC (Ex. 0533).
189 At all voltages, the values for the ergonomic
component of the minimum approach distance are
the same in the 2012 NESC as they are in the 2007
NESC.
190 EEI did, however, object to what it mistakenly
believed was a proposed increase in the ergonomic
component over what was adopted in existing
§ 1910.269 (Exs. 0227, 0501; Tr. 1056–1082). OSHA
discusses these comments later in this section of the
preamble.
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OSHA used this value in existing
§ 1910.269 and proposed it in this
rulemaking. There were no comments
on this issue in this rulemaking,
therefore, OSHA is adopting the
proposed ergonomic-movement
component of 0.31 meters (1 foot) for
voltages over 72.5 kilovolts.191
EEI misconstrued OSHA’s proposal as
increasing the ergonomic-movement
component in existing § 1910.269 by
0.61 meters (2 feet), for a total
ergonomic component of 1.22 meters (4
feet) for voltages up to 72.5 kilovolts
(Exs. 0227, 0392; Tr. 1056–1082).
Testifying on behalf of EEI, Mr. Clayton
Abernathy of OG&E Energy Corporation
described how increasing the minimum
approach distance by 0.61 meters would
restrict some of the work performed by
his company’s employees (Tr. 1056–
1082).
The ergonomic components of the
minimum approach distances in
OSHA’s proposal were the same as the
ergonomic components used for the
minimum approach distances in
existing § 1910.269 for voltages over
1,000 volts. The ergonomic component
for voltages between 751 volts and 72.5
kilovolts (the voltages addressed by
EEI’s comments) is 0.61 meters. The
ergonomic component of the proposed
minimum approach distances for those
voltages was not, contrary to EEI’s
suggestion, greater than that value. It
appears that EEI’s objections were
aimed at two other proposed
requirements: (1) Proposed
§ 1926.960(c)(2)(ii), which provided
that, when using rubber insulating
gloves or rubber insulating gloves with
sleeves for insulation against energized
parts, employees put on and take off
their rubber insulating gloves and
sleeves when they are in positions from
which they cannot reach into the
minimum approach distance, and (2)
proposed § 1926.960(d)(2), which
provided that employees performing
work near exposed parts energized at
601 volts to 72.5 kilovolts either work
from positions from which they cannot
reach into the minimum approach
distance or use specified protective
measures or work methods. OSHA
addresses EEI’s concerns with these
proposed provisions later in this section
of the preamble.
Finally, OSHA addresses some
confusion expressed by commenters
during the rulemaking about whether
191 In the 1994 § 1910.269 rulemaking, OSHA
adopted an ergonomic-movement factor based on
English units of 1 foot or 2 feet, depending on
voltage. It should be noted that, to three significant
digits, 0.305 meters is 1.00 foot and 0.610 meters
is 2.00 feet. In this final rule, OSHA used metric
units and rounded 0.305 meters up to 0.31 meters.
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the ergonomic component of the
minimum approach distance should be
used in determining whether a line
worker is exposed to phase-to-phase or
phase-to-ground voltage (Tr. 1060–1061,
1076–1077).
As noted earlier in this section of the
preamble, under the summary and
explanation for final § 1926.97(c)(2)(i)
and Table E–4, the final rule permits
insulating protective equipment to be
rated for phase-to-ground voltage if
‘‘[t]he electric equipment and devices
are insulated . . . so that the multiphase
exposure on a grounded wye circuit is
removed’’ (Table E–4, Note 1).192
Existing § 1910.137 and Table I–5
contain the same provisions. OSHA
policy with regard to whether there is
multiphase exposure under existing
§ 1910.137 is discussed in a September
27, 2005, letter of interpretation to Mr.
Edwin Hill, IBEW President.193 This
letter explains how to determine
whether multiphase exposure exists:
192 Note that the word ‘‘exposure’’ in the note
relates to the maximum voltage that can appear
across the insulation, and not to whether an
energized part is ‘‘exposed.’’ The definition of
‘‘exposed’’ in final § 1926.968 applies only to the
use of that term in Subpart V. It does not apply to
final § 1926.97.
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Phase-to-phase exposure exists whenever it
is foreseeable that an employee or the longest
conductive object he or she may handle can
simultaneously breach the electrical
components of the MADs of live parts
energized at different phase potentials, taking
into account such factors as: The nature of
the work being performed, the physical
configuration and spacing of the conductors,
the proximity of grounded objects or other
circuit conductors, the method of approach
to the conductors, the size of the employee,
the tools and equipment being used, and the
length of the conductive object. In addition,
the employer must always consider
mechanical loads and other conditions, such
as wind and ice, that could cause a conductor
to move or a support to fail. Notably, the
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determination of whether or not multiphase
exposure exists is made without regard to
insulation that may be covering the live part
or the employee. This is because the
exposure determination must be made prior
to the selection of insulation in order to
ensure that the insulation selected is
adequate to protect employees from the
electrical hazard. Moreover, it must be noted
that phase-to-phase exposure involves not
only the hazard of electric shock to the
employee, but also arc flash and arc blast
hazards from phase-to-phase contact of
conductive objects, such as could occur if an
employee dropped a conductive object onto
or within the electrical components of the
MADs of live parts energized at different
phase potentials. [Figures] illustrating when
phase-to-phase exposure exists can be found
at the conclusion of this letter. . . .
Figure 3 and Figure 4 are the figures
from that letter:
193 This letter is available on OSHA’s Web site at:
https://www.osha.gov/pls/oshaweb/owadisp.show_
document?p_table=INTERPRETATIONS&p_
id=25133.
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The 0.61-meter ergonomic component
of the minimum approach distance is
labeled ‘‘2 feet’’ in these figures. As can
be seen from the explanation and figures
in the letter of interpretation, the
ergonomic component of the minimum
approach distance has no bearing on
whether there is multiphase exposure.
The rating required for the insulating
protective equipment installed on the
phase conductors depends on the
electrical component of the minimum
approach distance (which, in turn,
depends on the voltage on the power
line, as discussed later in this section of
the preamble), the distance between the
phase conductors, and the reach of the
employee and any conductive object he
or she may handle while working. As
noted in the letter to Mr. Hill, when
multiphase exposure exists, the
insulating protective equipment used to
remove multiphase exposure must be
rated for the phase-to-phase voltage at a
minimum.194 In addition, the preamble
to the 1994 § 1910.269 rulemaking noted
that ‘‘until the multiphase exposure has
actually been removed, the phase-tophase voltage remains the maximum use
voltage’’ (59 FR 4328). After the
insulating protective equipment
covering the conductors not being
worked on is in place, the rubber
insulating gloves and sleeves need only
be rated for the phase-to-ground voltage.
This is current OSHA policy under
existing §§ 1910.137 and 1910.269 and
194 It should be noted that the insulating values
of two insulating materials in series are not additive
(Exs. 0041, 0532; 269-Ex. 60). At least one layer of
insulation must be rated for the maximum voltage
for the exposure.
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will continue to be the policy of the
Agency under this final rule.
The electrical component of MAD—
general. The differences between the
minimum approach distances under
existing § 1910.269 and the minimum
approach distances under this final rule
are the result of changes in the way the
Agency is calculating the electrical
components of the minimum approach
distances. As described previously, this
final rule adopts the ergonomic
components of the minimum approach
distances used in existing § 1910.269. In
addition, as explained later in this
section of the preamble, the number of
variables (such as elevation, maximum
transient overvoltage, type of exposure,
and type of insulating medium)
involved in determining the appropriate
minimum approach distance in any
particular set of circumstances makes
setting minimum approach distances
exclusively by means of tables
unmanageable. This approach would
require one set of tables for each
potential set of variables. Consequently,
the final rule requires the employer to
establish an appropriate minimum
approach distance based on equations
that OSHA is adopting in Table V–2.
The final rule also contains a table,
Table V–5, that specifies alternative
minimum approach distances for work
done at elevations not exceeding 900
meters (3,000 feet) for system voltages of
72.5 kilovolts and less. Finally,
Appendix B to final subpart V contains
tables of minimum approach distances,
for varying maximum transient
overvoltages for system voltages above
72.5 kilovolts, that employers may use
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20427
for work done at elevations not
exceeding 900 meters.
Some rulemaking participants
questioned the need for any changes to
the minimum approach distances in
existing § 1910.269. (See, for example,
Exs. 0227, 0545.1, 0551.1, 0552.1; Tr2.
71.) For instance, Mr. Charles Kelly with
EEI testified:
[U]nder Sections 3(8) and 6(b) of the
Occupational Safety and Health Act, as long
interpreted by the Supreme Court, OSHA [is]
required to show that the change[s] in the
clearance distances are, as a matter of
substantial evidence, reasonably necessary to
protect employees, and that they would
reduce or eliminate a significant risk for
employees.
As several people have stated previous to
our testimony, we are not aware that the
existing MAD distances, even though they
may have been mathematically incorrect for
decades, have shown to be unsafe in that
they have contributed to accidents or placed
employees at substantial risk of harm. We
doubt seriously that a desire to make a
technical mathematical correction is enough
to satisfy this requirement. [Tr2. 71–72]
IBEW also maintained that the
minimum approach distances in
existing § 1910.269 are adequate:
It is important to look at how the use [of]
MAD values, regardless of the origin and year
of publication, have protected workers
performing tasks in the vicinity of energized
power lines. The IBEW regularly reviews
accidents occurring in the electric utility
industry. We cannot remember a single
accident caused by inadequate MAD values.
OSHA 1910.269 MAD values have proven to
protect workers as they were intended to do.
The obvious question then is why change
successful MAD values? Based on industry
performance, we do not see why changes are
necessary. [Ex. 0551.1]
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As OSHA explained in Section II.D,
Significant Risk and Reduction in Risk,
earlier in this preamble, the Agency
need not make hazard-specific or
provision-specific risk findings. In any
event, the Agency concludes that the
electric-shock hazards faced by
employees performing electric power
generation, transmission, and
distribution work are serious and
significant and that the changes to the
minimum approach-distance provisions
in this final rule are reasonably
necessary and appropriate to reduce a
significant risk to employees.
OSHA finds that employees are being
injured by the dielectric failure of air
(that is, sparkover) between them (or a
conductive object they are handling)
and conductive objects at a different
potential. It is widely recognized that
electric current can arc over distances
and that it is necessary only to come too
close to, rather than contact, an
energized object to sustain an electric
shock. In fact, some of the accidents in
the record occurred when an employee
brought a conductive object or himself
or herself too close to an energized part
and electric current arced to the object
or employee (Exs. 0002,195 0003 196).
The Agency does not believe that it is
necessary to show that the specific
minimum approach distances in the
existing standards have led to accidents.
Instead, it is only necessary to show that
the probability of sparkover at the
worksite, given the existing minimum
approach distances, is significant. The
sparkover voltage between two objects
at different potentials is recognized as
following a normal distribution (Ex.
0532). The withstand voltage for an air
gap between two objects at different
potentials is three standard deviations
below the statistical mean sparkover
voltage. This represents approximately a
1 in 1,000 probability that the air gap
will fail dielectrically and spark over.197
The withstand distance is the distance
between two objects corresponding to a
given withstand voltage. (In other
words, the withstand distance is the
shortest distance between two objects
that will spark over at a given voltage
approximately one time in 1,000.)
Consensus standards have based the
electrical component of the minimum
approach distance on the withstand
195 See, for example, the five accidents described
at https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=908012&id=
170220602&id=564740&id=
14496384&id=14418321.
196 See, for example, the three accidents described
at https://www.osha.gov/pls/imis/
accidentsearch.accident_detail?id=200000453&id=
201350485&id=596304.
197 The probability of sparkover at the withstand
voltage is 0.14 percent or 1.4 in 1,000.
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distance corresponding to the maximum
voltage that can occur at the worksite.
(See, for example, Exs. 0076, 0077,
0532, 0533.) When the electrical
component of the minimum approach
distance is less than the withstand
distance for the maximum voltage at the
worksite, the probability of sparkover is
greater than 1 in 1,000. OSHA,
therefore, concludes that employees are
at significant risk of injury whenever the
electrical component of the minimum
approach distance is less than the
withstand distance for the maximum
voltage that can occur at the worksite.
As explained in detail later in this
section of the preamble, several of the
minimum approach distances contained
in the existing OSHA standards and in
the proposed rule represent a significant
risk of injury under this criterion.
The electrical component of MAD—
tools and conductive objects in the air
gap. The methodology used to develop
the proposed minimum approach
distances, which were based on the
2002 NESC, did not account for tools in
the air gap. As noted in the 2009
reopening notice, the presence of an
insulated tool in the air gap reduces the
air gap’s dielectric strength (74 FR
46961). IEEE Std 516–2009 (Ex. 0532)
generally provides two values for the
electrical component of the minimum
approach distance: One in air (called
MAID 198) and one with a tool in the air
gap (called MTID 199). However, that
consensus standard does not provide
minimum tool-insulation distances for
either: (1) Any exposures (phase-toground or phase-to-phase) at voltages of
72.5 kilovolts or less or (2) phase-tophase exposures at voltages of more
than 72.5 kilovolts. In the 2009
reopening notice, the Agency requested
comments on whether any of the
minimum approach distances in the
final rule should be based on minimum
tool-insulation distances rather than
minimum air-insulation distances. A
similar question was raised in the 2008
reopening notice.
Scenario 1—exposures at 72.5
kilovolts and less. Rulemaking
participants generally opposed basing
minimum approach distances for
voltages of 72.5 kilovolts and less on
minimum tool distances. (See, for
example, Exs. 0543.1, 0545.1, 0548.1,
0550.1; Tr2. 88.) For instance, Pike
Electric commented, ‘‘Pike utilizes
proper rubber protective cover-up at
. . . voltages [of 72.5 kilovolts and
lower]. This technique would eliminate
the hazard of employee exposure to
198 MAID
199 MTID
is the minimum air-insulation distance.
is the minimum tool-insulation
distance.
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energized lines and equipment, so there
is no need to utilize a MAD approach
using tool insulation distances’’ (Ex.
0543.1). EEI and Southern Company
argued that only one set of minimum
approach distances is necessary for
work on systems operating at voltages of
72.5 kilovolts and less because, based
on IEEE Std 516–2009, minimum tool
distances and minimum air distances
are the same at those voltages (Exs.
0545.1, 0548.1). American Electric
Power maintained that, for voltages at or
less than 72.5 kilovolts, MAD has not
been based on minimum tool distances
in the past, so doing so now could
potentially confuse workers (Ex.
0550.1).
IEEE Std 516–2009 defines MTID as
‘‘the required undisturbed air insulation
distance that is needed to prevent a tool
flashover at the worksite during a
system event that results in the
maximum anticipated TOV’’ (Ex. 0532).
Although the specified minimum tool
distances in IEEE Std 516–2009 are the
same as the corresponding minimum
air-insulation distances for voltages of
72.5 kilovolts and less, the consensus
standard includes the following
disclaimer in Section 4.5.2.1: ‘‘The
MTID for ac and dc line-to-line voltages
at and below 72.5 kV has not been
determined. Industry practices normally
use an MTID that is the same as or
greater than the MAID’’ (id.; emphasis
added). Thus, IEEE Std 516–2009 does
not indicate that the minimum air- and
tool-insulation distances are the same,
nor does it contain tables with
minimum tool-insulation distances for
voltages of 72.5 kilovolts and less.
According to IEEE Std 516–2009,
electrical testing at higher voltages
indicates that the dielectric strength of
an air gap is lower when an insulating
tool is present across the gap or when
a conductive object is present within the
gap (id.). OSHA concludes that
minimum approach distances for
voltages of 72.5 kilovolts and less
should be conservative enough so that
the gap will withstand the electric
potential across it even if a tool bridges
the gap or a conductive object is present
within it. As explained later in this
section of the preamble, the final rule
specifies minimum approach distances
that meet this criterion. Because the
final rule does not adopt separate
minimum approach distances for
exposures with and without tools at
72.5 kilovolts and less, the concerns
about confusion at these voltages are
unfounded.
Scenario 2—phase-to-ground
exposures at more than 72.5 kilovolts.
Some commenters maintained that the
final rule should follow the practice of
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the 2007 NESC and base minimum
approach distances for phase-to-ground
exposures at voltages of 72.6 kilovolts
and higher on the minimum tool
distance. (See, for example, Exs. 0519,
0521, 0528, 0543.1.) For instance, Mr.
Brian Erga with ESCI commented:
The MAD for voltages above 72.6 kV
should be based on the minimum tool
distance as published in the 2007 NESC. Live
line work is conducted with tools, workers
and equipment within the electrical field of
energized lines and equipment[,] and the
minimum tool distance is correct information
to be provided to the industry. [Ex. 0521]
Others suggested that the final rule
include two sets of minimum approach
distances for phase-to-ground exposures
at voltages exceeding 72.5 kilovolts: One
each for work performed with and
without tools in the air gap. (See, for
example, Exs. 0545.1, 0548.1, 0575.1;
Tr2. 88.) For instance, Mr. Charles Shaw
with Southern Company commented:
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In the proposed rule, OSHA is using
minimum air insulation distances when a
line worker is using a tool in the air gap.
Allowing the minimum air insulation
distance plus an inadvertent movement
factor to be used as the live-line tool distance
is an incorrect interpretation of the science
behind the IEEE method. At a minimum, the
note in the [Subpart] V and [§ 1910.269]
tables that states that the referenced distances
are for ‘‘live-line tool distances’’ should be
removed since they are not.
However, we recommend that OSHA
include two sets of minimum approach
distances for phase to ground work on
voltages above 72.5 kV, one for work
performed without tools in the air-gap and
one for work performed with tools in the air
gap. These distances should be based on
MAID and MTID respectively using the
method shown in IEEE 516–2009. [Ex.
0548.1]
Some commenters suggested that
separate sets of air and tool minimum
approach distances might be necessary
for phase-to-ground exposures above
72.5 kilovolts because basing minimum
approach distances solely on minimum
tool distances could prevent employees
from performing activities such as
climbing and inspection with lines or
equipment energized. (See, for example,
Ex. 0549.1, 0573.1; Tr2. 54–55.)
EEI submitted evidence that
approximately 23 percent of the
insulators installed on transmission
systems, and 25 percent of insulators
installed on systems operating at 345
kilovolts and more, would be too short
to accommodate the IEEE standard’s
minimum approach distances for tools
(Ex. 0575.1). EEI noted that ‘‘there have
been no reported safety events or
flashovers with the current insulator
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lengths’’ 200 and maintained that using
MAD for tools would force employers to
perform routine inspections under
deenergized conditions (id.).
Minimum approach distances in the
2007 NESC and IEEE Std 516–2009 are
generally based on a substantial body of
electrical tests run on air gaps with and
without objects in them (Ex. 0532; Tr2.
38).201 A 1968 IEEE Committee Report
entitled ‘‘Recommendations for Safety
in Live Line Maintenance,’’ and a 1973
IEEE Committee Report entitled ‘‘LiveLine Maintenance Methods,’’ presented
a formula, based on that testing, for
calculating minimum safe distances for
energized power line work (Exs. 0556,
0558). This formula, which is given later
in this section of the preamble,
generally provides for a 10-percent
increase in distance to account for the
presence of tools across the air gap. 202
IEEE Std 516–2009, in Section 4.7.9.2,
recognizes the effect that a large floating
object has on minimum approach
distances:
When a large floating object, not at ground
or the conductor potential, is in the air gap,
additional compensation may be needed to
provide for the size and location of the
floating object in the air gap. [Ex. 0532]
IEEE Std 516–2009 accounts for this
effect by reducing the withstand voltage
by 10 percent for phase-to-phase
exposures on systems operating at more
than 72.5 kilovolts (id.). This approach
effectively increases the minimum
approach distance by at least 10 percent.
Although IEEE Std 516–2009 applies a
floating-object correction factor only to
phase-to-phase exposures, the effect (as
noted in the quoted passage) also
applies to phase-to-ground exposures.
In light of the comments received and
the other information in the record,
OSHA concludes that, for phase-toground exposures at voltages of more
than 72.5 kilovolts, basing minimum
approach distances on minimum airinsulation distances will not provide
sufficient protection for employees
when insulated tools or large
conductive objects are in the air gap.
Minimum air-insulation distances are
based on testing air gaps with only air
between the electrodes, which does not
account adequately for the presence of
tools (Ex. 0532). Therefore, the
200 OSHA is unsure what EEI meant by ‘‘safety
event,’’ but assumes that it means accident or near
miss.
201 As noted later in this section of the preamble,
the 2012 NESC distances are identical to
corresponding minimum approach distances in
IEEE Std 516–2009.
202 The equation included a factor, C , equal to
2
‘‘1.1, composed of 1.06 for live-line tool-to-air
withstand distance ratio plus intangibles’’ (Ex.
0556).
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provisions adopted in the final rule
ensure that minimum air-insulation
distances are applied only when air
alone serves as the insulating medium
protecting the worker. For phase-toground exposures at voltages of more
than 72.5 kilovolts, Table V–2 requires
employers to establish minimum
approach distances that are based on the
minimum air-insulation distance ‘‘for
phase-to-ground exposures that the
employer can demonstrate consist only
of air across the approach distance.’’
Otherwise, the minimum approach
distances for these exposures must be
based on the minimum tool-insulation
distance.
Scenario 3—phase-to-phase
exposures at more than 72.5 kilovolts.
The third and final scenario the Agency
has to address is the presence of tools
or other insulation across a phase-tophase air gap at voltages of more than
72.5 kilovolts. Rulemaking participants
maintained that, for voltages of more
than 72.5 kilovolts, minimum approach
distances based on minimum toolinsulation distances are unnecessary
because the phase-to-phase air gap is
rarely, if ever, bridged by an insulated
tool. (See, for example, Exs. 0545.1,
0548.1, 0550.1, 0551.1; Tr2. 89, 157).
For instance, Dr. Randy Horton,
testifying on behalf of EEI, stated:
[EEI is] unaware of any live-line working
scenario situations above 72.5 kV where the
phase-to-phase air gap is bridged by live-line
tool. Most work practices are developed to
work on only one phase at a time per
structure, phase to ground. [Tr2. 89]
Thus, the rulemaking record indicates
that, for voltages over 72.5 kilovolts,
tools or other objects infrequently, if
ever, bridge the gap between two
phases. Considering how rare the
practice of spanning the air gap is,
OSHA decided against adopting
generally applicable minimum approach
distances that account for tools in the
gap for phase-to-phase exposures at
these voltages. However, there is still a
need to account for conductive bodies
in the air gap in the limited
circumstances in which they are
present, for example, when an employee
is moving between phases in an aerial
lift. Therefore, OSHA is including
provisions in the final rule ensuring that
the phase-to-phase minimum approach
distance for voltages over 72.5 kilovolts
takes account of any objects that will be
present in the air gap. Table V–2
requires the employer to establish
minimum approach distances that are
based on the minimum air-insulation
distance as long as ‘‘the employer can
demonstrate that no insulated tool spans
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the gap and that no large conductive
object is in the gap.’’203
The electrical component of MAD—
maximum transient overvoltages.
Existing § 1910.269 and OSHA’s 2005
proposal specified maximum transient
overvoltages of 3.0 per unit for voltages
up to 362 kilovolts, 2.4 per unit for
voltages in the 550-kilovolt range (500
to 550 kilovolts, nominal204), and 2.0
per unit for voltages in the 800-kilovolt
range (765 to 800 kilovolts, nominal).
These are known as ‘‘industry-accepted
values’’ of maximum per-unit
overvoltage (Ex. 0532). The IEEE
committee and the electric utility
industry, as evidenced by the 1993
through 2002 NESC and pre-2003
editions of IEEE Std 516, believed that
these were the highest transient
overvoltages possible. However, the
2007 NESC and IEEE Std 516–2009
recognize that even higher maximum
per-unit transient overvoltages can exist
(Exs. 0532, 0533).205 Therefore, OSHA
requested comments on how, if at all,
the final rule should address the
possibility of higher maximum transient
overvoltages.
No rulemaking participants disputed
that overvoltages beyond those
accounted for in the proposed standard
were possible. Pike Electric
recommended that minimum approach
distances be calculated for the highest
possible transient overvoltage (Ex.
203 Two variables in the equation for minimum
approach distances account for tools or large
conductive bodies in the air gap. The variable C is
0.01 for exposures that the employer can
demonstrate are with air only between the
employee and the energized part if the employee is
at ground potential or between the employee and
ground if the employee is at the potential of the
energized part, or 0.011 otherwise. Because it is rare
that tools or large conductive bodies are in the air
gap between phases, employers should not have
difficulty making this demonstration for phase-tophase exposures. The second variable, the
saturation factor, a, is calculated differently when
an insulated tool spans the gap or a large
conductive object is in the gap. For phase-to-phase
exposures, the final rule requires this factor
generally to be based on air only in the gap.
204 Table R–7 and Table R–8 in existing
§ 1910.269 and Table V–1 and Table V–2 in existing
subpart V list the upper bound of this voltage range
as 552 kilovolts. Table R–6 in existing § 1910.269
lists the upper bound of this voltage range as 550
kilovolts, which is the correct value (Ex. 0532). The
final rule uses 550 kilovolts as the upper bound of
this voltage range.
205 Table 441–2 of the 2007 NESC contains
minimum approach distances with maximum
transient overvoltages higher than the industryaccepted values, though the higher values do not
apply when certain conditions are met (Ex. 0533).
Section 4.7.4.3 of IEEE Std 516–2009 lists the
industry-accepted values for maximum transient
overvoltages. However, it also states that, if certain
assumptions about the operation of the system are
not met, ‘‘the values listed in the table may not be
valid, and an engineering evaluation should be
performed to determine [the maximum per-unit
transient overvoltage]’’ (Ex. 0532).
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0543.1). IBEW suggested that, if the
higher per-unit overvoltage factors are
included, specific instructions for using
those higher factors also should be
included in the final rule (Ex. 0551.1;
Tr2. 158).
Electric utility representatives argued
that, even though higher overvoltages
are possible, their industry does not
widely recognize that higher
overvoltages exist. (See, for example,
Exs. 0545.1, 0548.1, 0549.1, 0550.1; Tr2.
90–93.) These rulemaking participants
urged OSHA to base the final standard
on the existing industry-accepted values
upon which the proposal was based
(id.). For example, Southern Company
stated, ‘‘Although IEEE 516–2003 and
IEEE 516–2009 recognize the possibility
of higher surge values, the concept that
such surges exist is not widely accepted
in the Industry’’ (Ex. 0548.1).
Dr. Randy Horton, testifying on behalf
of EEI, explained this position as
follows:
Over the years, none of the field-measured
over-voltages on actual operating systems has
produced results which exceed the industry
accepted T values (transient overvoltage
values). The documentation of these
measurements and of numerous simulations,
encompassing all current transmission
operating voltages, and the results have
consistently supported the accepted T values.
[Tr2. 90]
However, Dr. Horton acknowledged
that one utility (Bonneville Power
Administration, or BPA) measured
overvoltages above 3.0 per unit on one
of its 230-kilovolt circuits (id.). As he
noted, BPA tested that circuit in
response to sparkovers on rod gaps
placed on the circuit to protect it from
lightning strikes (Tr2. 90–91). Dr.
Horton argued that the measured
overvoltages on that circuit were
unrealistic because: (1) The gaps on the
circuit flashed over at overvoltages less
than 3.0 per unit during testing; (2) the
circuit breaker characteristics and
performance, including pole-closing
spans and breaker current, were
unrealistic; and (3) monitoring
inaccuracies could have occurred,
leading to measurements that were too
high. (See, for example, Exs. 0546.1,
0575.1; Tr2. 90–92.) EEI recommended
adhering to the industry-accepted
overvoltage values. However, it noted
that, if OSHA elected to account for the
values of maximum per-unit overvoltage
from the BPA measurements, the final
rule should just include a footnote
similar to that contained in IEEE Std
516–2009, noting: ‘‘At 242 kV, it is
assumed that automatic instantaneous
reclosing is disabled. If not, the values
shown in the table may not be valid,
and an engineering evaluation should be
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performed to determine ‘T’ ’’ (Ex.
0545.1; Tr2. 93).
In its posthearing submission, EEI
offered evidence suggesting that the
industry-accepted values of maximum
per-unit transient overvoltage are
reasonable (Ex. 0575.1). In this
submission, EEI reported results of
testing on several other systems of
varying voltages, none of which
exceeded the industry-accepted values.
EEI explained:
The field tests were conducted for
energization, reclosings and with or without
shunt reactors. Attempts were made to obtain
the worst possible overvoltages during the
field tests. For all cases, listed above, the
expected overvoltages, now, would be lower
since the system has matured and at each
bus, the source strength has increased
considerably. . . .
The IEEE Transactions Papers on the
aforementioned information are provided
below. Additional IEEE Transactions Papers
references are attached for switching
overvoltage field tests on system voltage
levels of 220 kV, 345 kV and 500 kV by
various power companies, including
American Electric Power. All papers show
that:
• Without breaker closing resistors, the
maximum switching overvoltages do not
exceed 3.0 pu.
• With closing resistor, the maximum
switching overvoltages are near 2.0 pu. And,
with control closings the maximum
switching overvoltages do not exceed 1.6 pu.
• Calculated overvoltages are generally
much higher than those by the field
measured values . . . [Id.]
EEI also pointed to an excerpt from
International Electrotechnical
Commission (IEC) Standard 61472 as
evidence that higher maximum transient
overvoltages are possible, but unlikely
(id.). This IEC excerpt reads as follows:
B.2.2 Overvoltages under abnormal
conditions.
Among the possible abnormal conditions
which can lead to very high overvoltages,
restrikes between the contacts of circuit
breakers during opening is considered, and
in particular the following conditions may be
of concern:
–single or three-phase opening of no load
lines;
–three-phase clearing of line-to-earth fault.
Such abnormal behaviour may lead to
overvoltage amplitudes of the same order or
even higher than those under three-phase
reclosing.
However, the restrike probability of circuit
breakers is normally low, and is very low for
the modern circuit breaker. So the low
probability of these events is not such as to
influence the probability distribution of the
family considered (opening or fault clearing)
and thus the relevant Ue2 value. [Id.]
OSHA understands that the
information in the record pertaining to
maximum transient overvoltages applies
basically to voltages over 72.5 kilovolts.
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IEEE Std 516–2009 does not include
separate overvoltage factors for voltages
of 72.5 kilovolts and less (Ex. 0532). For
voltages of 72.5 kilovolts and less, IEEE
Std 516–2009 relies on a maximum
transient overvoltage of 3.0 per unit and
does not recognize the possibility of
higher values. Section 4.8.1d of IEEE
Std 516–2009 states, ‘‘Shunt-connected
devices, such as transformers, and
reactors will tend to reduce the trapped
charge on the line and, therefore, limit
the overvoltages due to reenergization’’
(id.). Such shunt-connected devices are
not only pervasive on systems of 72.5
kilovolts and less, but are a necessary
part of the distribution systems that
form the overwhelmingly predominant
portion of these systems (see, for
example, 269-Ex. 8–13). Even for the 45and 69-kilovolt systems that are
sometimes used in transmission
circuits, there is no evidence in the
record that maximum transient
overvoltages exceed 3.0 per unit.
Consequently, the final rule adheres to
a maximum transient overvoltage of 3.0
per unit for systems with a nominal
phase-to-phase voltage of 72.5 kilovolts
or less. OSHA calculated the values in
Table V–3, which are the electrical
components of the minimum approach
distances, using a maximum transient
overvoltage of 3.0 per unit.
For voltages of more than 72.5
kilovolts, no rulemaking participant
disputed the fact that maximum
transient overvoltages based on
engineering calculations can exceed
those on which the proposed rule was
based. (See, for example, Exs. 0532,
0575.1.) It also is clear that maximum
transient overvoltages exceeding
industry-accepted values are possible as
IEEE Std 516–2009, IEC Standard 61472,
and the BPA report show. (id.) The
evidence in the record indicates that
most systems do not, however, exceed
the industry-accepted values on which
the proposal was based. (See, for
example, Exs. 0545.1, 0549.1, 0575.1;
Tr2. 90–93.) This is the major argument
relied on by the commenters that urged
OSHA to base the final rule on industryaccepted values of maximum transient
overvoltage (id.).
The Agency considered all of the
comments and record evidence on this
issue and concluded that the arguments
against relying on BPA’s report are not
strong enough to justify ignoring it for
purposes of this final rule. First, EEI
argued that, in the BPA scenario, during
testing the gaps on the circuit flashed
over at overvoltages less than 3.0 per
unit (see, for example, Tr2. 91). The
magnitude of the overvoltage during
these gap sparkovers is irrelevant. In
one series of tests, the measured
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overvoltages for two of the tests in
which three gaps arced over were lass
than 3.0 per unit. However, measured
overvoltages on at least one phase
exceeded 3.0 per unit during 10 of the
tests, including both tests involving
sparkovers.206 For this circuit, the
testing found overvoltages as high as 3.3
per unit. The BPA report explained:
Rod gap flashovers occurred . . . during
the last two tests of [one test series]. . . .
[S]ignificantly higher overvoltages were
measured on [the] phases [with flashovers]
during other tests in the series, but the gaps
did not flash over. This demonstrates the
highly statistical nature of . . . gap flashover
. . . . [Ex. 0575.1]
Thus, that the measured overvoltages for
the sparkovers were less than 3.0 per
unit has no bearing on whether
overvoltages exceeding 3.0 per unit are
possible.
Second, EEI’s argument that the
circuit breaker characteristics were
unrealistic are unpersuasive. EEI argued
that, because ‘‘[t]he field tests were
conducted with individual phase
breaker pole control,’’ the pole-closing
span 207 was exceedingly large and
unrealistic (id.). Although BPA
controlled the opening and closing of
the circuit breakers during testing to
‘‘measure overvoltage levels that can
occur on a long transmission line during
high speed reclosing,’’ there is no
indication in the BPA report that it
varied the closing spans for the
individual poles on the circuit breakers
(id.). The report states:
[The relevant test series] involved threephase reclosing into trapped charge on the
Big Eddy-Chemewa 230-kV line. Breaker
opening was controlled and synchronized to
generate the same polarity and magnitude
trapped charge on each phase for each test
shot. Testing began by switching from the Big
Eddy end, varying the closing time of the
breaker uniformly over a complete 60 Hz
cycle by increments of 18 electrical degrees
(1⁄20 cycle). After these 20 tests, 4 additional
tests were performed in an attempt to
generate a maximum possible overvoltage.
This same procedure was then repeated from
the Chemewa end of the line. [Id.]
Thus, it appears that BPA took measures
to synchronize the switching of the
poles in each circuit breaker. The report
mentioned that the circuit breaker at the
Big Eddy end was ‘‘constructed with
206 The measured overvoltages on the phases with
gap sparkovers were under 3.0 per unit, but the
measured overvoltages on the phases without gap
sparkovers during the same tests exceeded 3.0 per
unit. For example, during test 5–25, the overvoltage
on the phase with the gap sparkover was 2.83 per
unit, and the overvoltage on one of the other two
phases was 3.30 per unit.
207 The circuit-breaker pole-closing span is the
maximum closing time difference between the
phases.
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20431
each phase in its own tank’’ (id.). The
pole-closing span for this circuit breaker
was 3.7 milliseconds. The circuit
breaker at Chemewa was ‘‘constructed
with all three contacts in a single tank’’
(id.). The pole-closing span for this
circuit breaker was 0.24 milliseconds,
significantly shorter than the poleclosing span for the Big Eddy circuit
breaker. Measured overvoltages
exceeded 3.0 per unit during tests with
switching performed at both locations.
Thus, OSHA concludes that poleclosing spans did not contribute to
measured overvoltages exceeding 3.0
per unit during BPA testing. BPA did
not indicate that the pole-closing span
for either circuit breaker was unusual,
and EEI did not submit any evidence
that would demonstrate that circuit
breakers of any type of construction
generally have shorter pole-closing
spans. Consequently, the Agency
concludes that, even if the pole-closing
span did contribute to the measured
overvoltages in BPA’s testing, circuit
breakers in other installations could
have similarly long pole-closing spans
with correspondingly high maximum
transient overvoltages.
Furthermore, although the difference
in time taken for each pole to close
might affect the phase-to-phase
overvoltage, that value was not
measured during the BPA tests. Because
pole-closing spans only affect the offset
between phases and should have no
substantial effect on the behavior of the
transient voltage on a single phase, long
pole-closing spans should have little
effect on phase-to-ground overvoltages
(that is, the overvoltage on a single
phase). As explained later, the report
clearly states that the main cause of the
unexpectedly high maximum transient
overvoltages was ‘‘prestrike.’’ OSHA,
therefore, concludes that prestrike, not
pole-closing spans, were the primary
cause of the high maximum transient
overvoltages.
EEI, through Dr. Horton, also
expressed concern about the
performance of the circuit breakers in
the BPA report, because the circuit
breaker current showed evidence of
prestrikes (Tr2. 91). Restrike and
prestrike may occur during the opening
of circuit breakers. The current and
voltage across the contacts of a circuit
breaker vary with time. When the
contacts are closed, the voltage across
them is very close to zero, and the
current oscillates at 60 cycles per
second. When the contacts are open, the
voltage oscillates, and the current is
zero. As the contacts of a circuit breaker
open or close, current can arc across
them. When the current drops to zero,
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the arcing stops. However, if the voltage
across the contacts from reflected
traveling waves exceeds the dielectric
strength of the gap between the contacts,
arcing can recur. Arcing that occurs
after the initial arc is extinguished as
the circuit breaker is opening is called
‘‘restrike.’’ Arcing that occurs as the
contacts close, but before they are
touching, is called ‘‘prestrike.’’
Whether a circuit breaker is subject to
restrikes or prestrikes is dependent on
the design of the circuit breaker,
maintenance of the circuit breaker, and
the characteristics of the circuit to
which the breaker is connected.
Prestrikes and restrikes can lead to high
transient overvoltages that can damage
equipment. Therefore, manufacturers
design circuit breakers to resist restrikes
and prestrikes. However, the probability
that these events will occur can be
affected by maintenance and circuit
design. Poor circuit breaker
maintenance can lead to longer poleopening times and can increase the
probability that prestrike or restrike will
occur. Similarly, circuit designs can
shorten the time in which traveling
waves reach the breaker contacts, which
also can increase the probability of
prestrikes or restrikes.
The circuit breakers that were the
subject of BPA’s testing exhibited
prestrikes during testing (Ex. 0575.1).
Commenting on this, Dr. Horton stated:
The line breaker performance appears
suspicious. The breaker current shows prestrikes with abrupt interruptions and
subsequent re-ignitions [Tr2. 91]
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However, the BPA report explained why
the prestrikes occurred:
During Test Series V, it was found that the
sending end can experience significant
overvoltages that were previously assumed to
occur only out on the line or at the receiving
end. During breaker prestrike, a current wave
(initiated by arcing across the contacts)
travels down the line to the receiving (open)
end where it is reflected. As the reflected
wave travels back toward the sending end of
the line, it reduces the current to near zero
along the line. When the reflected current
wave reaches the sending end of the line, it
creates a current zero and allows the
prestrike arc between the breaker contacts to
extinguish, isolating the line voltage from the
bus voltage. After the arc extinguishes, the
line voltage often increases due to traveling
voltage waves that continue to be reflected
from the receiving end. The voltage across
the breaker then builds up until another
prestrike occurs. The next prestrike occurs at
a lower breaker cross voltage because the
breaker contacts are closer together. In Test
Series V, the majority of breaker closings
resulted in only a single prestrike. However,
in a few tests, up to four prestrikes occurred
on one phase during a single closing
operation. [Ex. 0575.1]
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BPA found this information useful,
explaining:
This field test has also provided a
considerable amount of data on 230-kV SF6
breaker prestrikes. Typical characteristics of
the dielectric strength across the breaker
contacts have now been developed and can
be used for statistical switching surge
studies. Additional information has also been
obtained about another property of 230-kV
SF6 breakers—where the prestrike arc is
extinguished by the traveling current wave
during line switching. The test results show
that when the prestrike arc extinguishes, the
voltage at the sending end of a line reaches
values that are much higher than were
previously expected. [Id.]
In light of this explanation in the BPA
report itself, OSHA concludes that the
existence of prestrikes does not
invalidate the BPA report’s findings. In
fact, the prestrikes were the cause of the
unexpectedly high maximum transient
overvoltages. The Agency anticipates
that any workplace where prestrikes
occur during switching operations,
particularly during reclosing, can
experience similarly high maximum
transient overvoltages.
EEI’s third and final concern about
the BPA report was that ‘‘inaccuracies
in the monitoring system and in the
waveform calibration [could have
resulted] in unrealistic over-voltage
readings’’ (Tr2. 91). However, there is
no evidence in either BPA’s report or in
OSHA’s rulemaking record that such
inaccuracies existed during the BPA
tests.
For the foregoing reasons, OSHA does
not accept EEI’s criticism of the BPA
report and finds that it provides
substantial evidence of the existence of
maximum transient overvoltages higher
than industry-accepted values.
IEEE Std 516–2009 does not account
for the possibility of circuit-breaker
restrikes. In Section 4.7.4.3, IEEE Std
516–2009 explains its approach for
addressing maximum transient
overvoltages, as follows:
(a) At all voltage levels, it is assumed that
circuit breakers are being used to switch the
subject line while live work is being
performed. This further assumes that the
restrike probability of a circuit breaker is low
and consequently extremely low while a
worker is near the MAD and that it can,
therefore, be ignored in the calculation of T.
If devices other than circuit breakers are
being utilized to switch the subject line while
live work is being performed, then the values
listed in the table may not be valid, and an
engineering evaluation should be performed
to determine T.
(b) At 242 kV, it is assumed that automatic
instantaneous reclosing is disabled. If not,
the values shown in the table may not be
valid, and an engineering evaluation should
be performed to determine T. [Ex. 0532]
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OSHA has serious concerns about the
validity of the assumptions on which
this IEEE standard relies to support its
general application of the industryaccepted values for maximum transient
overvoltages. Indeed, with all the
caveats in these paragraphs of the IEEE
standard, it is clear that even the
drafters of that standard did not believe
in the universal applicability of its key
assumptions. IEEE Std 516–2009
recognizes that switching can be
performed using devices other than
circuit breakers and recommends an
engineering analysis if such devices are
used. The Agency concludes that the
prestrike experience reported by BPA
demonstrates that the occurrence of
prestrikes is likely to be a consequence
of the design of the circuit breaker and
the circuit involved, rather than a low
probability event for each circuit
breaker on every circuit. The BPA report
explained that the occurrence of
prestrikes was influenced heavily by the
magnitude of the trapped charge on the
line and the speed of the initial and
repeated reflected traveling wavefronts
(Ex. 0575.1). Because the cause of
prestrikes and restrikes are the same, the
Agency believes that restrikes are
similarly influenced. In this regard,
prestrikes and restrikes are the same
type of event, with prestrikes occurring
during circuit breaker opening and
restrikes occurring during circuit
breaker closing. Thus, although the
overall probability that circuit breakers
in general will restrike or prestrike may
be low, OSHA concludes that the
probability that a particular circuit
breaker will restrike or prestrike may be
high enough that it cannot be ignored.
Additionally, neither the IEEE
standard nor Dr. Horton explained why
the IEEE committee chose to base
maximum transient overvoltage on the
2-percent statistical switching
overvoltage expected at the worksite,
which is a probability-based assessment,
while ignoring the probability of
restrikes (Ex. 0532).208 After all, if the
probability is low enough, then the
potential for restrikes will not have a
significant effect on the 2-percent
statistical switching overvoltage. On the
other hand, if it is high enough, then the
2-percent statistical switching
overvoltage will increase.
In response to EEI’s recommendation
to permit employers to use industryaccepted values in accordance with
IEEE Std 516–2009, OSHA concludes
208 Section 4.7.4.2 of IEEE Std 516–2009 reads, in
part, ‘‘The line-to-ground maximum anticipated
per-unit TOV (T) for live work is defined as the
ratio of the 2% statistical switching overvoltage
expected at the worksite to the nominal peak lineto-ground voltage of the system.’’
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that this alternative does not adequately
account for higher maximum transient
overvoltages. Section 4.7.4.3b of IEEE
Std 516–2009 indicates that the
industry-accepted values are valid only
when reclosing is blocked at 242
kilovolts (Ex 0532). Although the BPA
testing was performed on a 242-kilovolt
circuit, there is no evidence in the
record indicating that maximum
transient overvoltages higher than the
industry-accepted values are limited
only to this voltage. In addition, the
IEEE standard, in Section E.2 of
Appendix E, notes:
If restriking of the switching device is
included [in the determination of maximum
transient overvoltage], then the resulting
overvoltages are essentially the same as those
of reclosing into a trapped charge. The only
difference is the probability of occurrence.
[Id.]
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Consequently, even if reclosing is
blocked, the maximum transient
overvoltage may still exceed industryaccepted values.
OSHA concludes that it is not in the
interest of worker safety to adopt
minimum approach-distance provisions
based on the conditions expected to be
present in the workplaces of most, but
not all, employers covered by this final
rule. Basing the rule on industryaccepted values of maximum transient
overvoltage, as EEI and other
commenters recommended, would
result in some employees not receiving
adequate protection. In the extreme
case, in which the maximum transient
overvoltage is 3.5 instead of the
industry-accepted value of 3.0, the
electrical component of the minimum
approach distance would sparkover
nearly 50 percent of the time, rather
than 0.1 percent of the time, at the
maximum overvoltage. OSHA designed
the minimum approach-distance
provisions in this final rule to protect
employees from the conditions that are
present in their specific workplaces.
Under the final rule, employers must
select and adhere to minimum approach
distances based on the maximum
transient overvoltages present at their
workplaces or base minimum approach
distances on the highest maximum
transient overvoltage.
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EEI and other commenters noted that
IEEE recently established a working
group to examine maximum transient
overvoltages and recommended that
OSHA rely on industry-accepted values
for these overvoltages until the
committee reports its findings. (See, for
example, Exs. 0545.1, 0548.1; Tr2. 92–
93.) For instance, Dr. Horton, testifying
on behalf of EEI, stated:
In order to address the possibility of higher
surge values, the General Systems
Subcommittee of the IEEE Transmission and
Distribution Committee has recently created
a working group entitled ‘‘Field Measured
Over-Voltages and Their Analysis’’ to
determine if higher surge values actually
exist, and if so, what is their upper limits.
This working group is chaired by myself (Dr.
Randy Horton of Southern Company) and is
co-chaired by Dr. Albert Keri of American
Electric Power. Numerous experts and
utilities from around the world are involved
in this work, and initial findings of the
working group will likely be available in the
next 3 to 4 years. Until such time, it is
recommended that the industry accepted
values (in other words T equal to 3 per unit,
2.4 per unit, and 2.0 per unit, corresponding
to 362 kV and below, 363 kV to 550 kV, and
551 kV to 800 kV respectively) be used as the
maximum per unit transient over-voltage
values. [Tr2. 92–93]
The Agency concludes that it is not
necessary to wait for the findings of the
new IEEE working group before
proceeding with new minimum
approach-distance provisions. The
Agency does not believe that it is
necessary to delay action on minimum
approach distances until the IEEE or any
other standard-setting organization
produces additional information on this
subject. OSHA believes that there is
sufficient information in the record,
described earlier in this discussion of
maximum transient overvoltages, to
form the basis of a final rule on
minimum approach distances that
accurately accounts for the presence,
magnitude, and effect of maximum
transient overvoltages. The Agency
concludes that BPA’s experience proves
the existence of maximum transient
overvoltages higher than the industryaccepted values; and, although the
consensus standards do not fully
account for potentially higher values in
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20433
their minimum approach distances, the
2007 NESC and the 2003 and 2009
editions of IEEE Std 516 recognize the
existence of such overvoltages (Exs.
0041, 0532, 0533, 0575.1).
Consequently, for purposes of Table V–
6, and Table 7 through Table 14 in
Appendix B to subpart V, the Agency is
adopting maximum per-unit transient
overvoltages of 3.5 for systems operating
at 72.6 to 420 kilovolts, 3.0 for systems
operating at 420.1 to 550.0 kilovolts,
and 2.5 for systems operating at 550.1 to
800 kilovolts. These values are the same
values as the highest maximum
transient overvoltages recognized in the
2007 NESC and IEEE Std 516–2009 (Exs.
0532, 0533).
The electrical component of MAD—
calculation methods for voltages up to
72.5 kilovolts. OSHA based the
minimum approach distances in
existing § 1910.269 for voltages up to
72.5 kilovolts on ANSI/IEEE Std 4 (59
FR 4383). Existing § 1910.269 specifies
‘‘avoid contact’’ as the minimum
approach distance for voltages between
51 and 1,000 volts. To make the revised
standards consistent with the 2002
NESC, OSHA proposed in the 2005
proposal to adopt minimum approach
distances of 0.31 meters (1 foot) for
voltages between 301 volts and 750
volts and 0.65 meters (2 feet, 2 inches)
for voltages between 751 volts and 15
kilovolts. The proposal specified ‘‘avoid
contact’’ as the minimum approach
distance for 51 to 300 volts.
Two commenters objected to the
requirement for employees to ‘‘avoid
contact’’ with lines energized at 50 to
300 volts (Exs. 0169, 0171). Mr. Brooke
Stauffer with NECA commented, ‘‘The
‘avoid contact’ requirement on lines
energized at 50 to 300 volts is infeasible
for line construction and maintenance,
because linemen must contact these
energized lines on a routine basis while
doing their work’’ (Ex. 0171). Quanta
Services similarly asserted, ‘‘The ‘avoid
contact’ requirement on lines energized
at 50 to 300 volts presents a problem
because linemen will contact those lines
on a routine basis while doing their
work’’ (Ex. 0169).
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safety rule book and training curriculum in
the industry, including among line
contractors, as well as related retraining of
line workers. The established clearance
distances are well-known to employees in the
transmission and distribution industry, and
changing them for the sake of an additional
inch or two can only lead to confusion, with
no significant safety benefit. As a practical
matter, it is not clear that such a small
change will make a significant difference in
the safety of line workers. [Ex. 0227]
For the sake of an inch or two, OSHA
ought not to change the existing MAD tables.
Such changes could require revising every
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These comments do not indicate how
employees are contacting electric
conductors and other circuit parts
energized up to 300 volts.209 It is well
recognized that these voltages are
potentially lethal. Exhibit 0002 alone
describes at least 25 accidents in which
employees were killed because of
contact with circuit parts energized at
120 volts to ground.210 OSHA believes
that, in the past, the practice was for
power line workers to use leather gloves
rather than rubber insulating gloves to
handle these voltages, and it is possible
that these commenters are
recommending that the standard permit
that practice. However, leather gloves
do not insulate workers from energized
parts (Ex. 0002).211 Perspiration can
saturate these gloves during use, making
them conductive. One of the accidents
in the record involved an employee
handling a 120-volt conductor with
leather gloves (id.). Therefore, the final
rule requires employees to avoid contact
with circuit parts energized at 50 to 300
volts.212 If it is necessary for employees
to handle exposed parts energized at
these voltages, they must do so in
accordance with final
§ 1926.960(c)(1)(iii)(A), (c)(1)(iii)(B), or
(c)(1)(iii)(C); and any insulating
equipment used must meet the electrical
protective equipment requirements in
final § 1926.97.
There were few comments on the
minimum approach distances proposed
in 2005 for voltages of 301 volts to 72.5
kilovolts. Some commenters objected to
the small changes in minimum
approach distances from existing
§ 1910.269 that were specified in the
2005 proposal. (See, for example, Exs.
0227, 0543.1.) EEI maintained that the
safety benefit of slight changes was
outweighed by the practical
implications of implementing revised
minimum approach distances:
For ac and dc line-to-line and line-toground work between 300 V and 5.0 kV,
sufficient test data are not available to
calculate the MAID,[213] which is less than 2
cm or 0.07 ft. For this voltage range, it is
assumed that MAID is 0.02 m or 0.07
ft . . . . [Ex. 0532]
209 In the proposed rule, the lowest voltage in the
avoid-contact range was 51 volts, not 50 volts as
indicated by the two commenters.
210 See the 25 accidents described at https://
www.osha.gov/pls/imis/accidentsearch.accident_
detail?id=660118&id=817114&id=14307003&id=
14311666&id=982645&id=14327944&id=894584
&id=14351076&id=14525430&id=201360062&id=
601468&id=14251771&id=14251987&id=
14257034&id=14371751&id=14523591&id=
14383376&id=695437&id=514547&id=
170080238&id=14400782&id=14219851&id=
764365&id=14505366&id=778332.
211 See, for example, the two accidents described
at https://www.osha.gov/pls/imis/accidentsearch.
accident_detail?id=14371751&id=660118.
212 OSHA proposed 51 volts as the low end of the
avoid-contact range. The final rule adopts 50 volts
as the low end for consistency with Table R–6 in
existing § 1910.269 and IEEE Std 516–2009.
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OSHA understands that changing
minimum approach distances, even
slightly, may require employers to
adjust their safety rules and training.
The Agency accounted for the cost of
changing these safety rules and training
because of differences between existing
§ 1910.269 and the final rule, including
the revised minimum approach
distances (see Section VI, Final
Economic Analysis and Regulatory
Flexibility Analysis, later in this
preamble).
Ignoring evidence that small increases
in the electrical component of the
minimum approach distances are
necessary would result in shrinking the
ergonomic component of the minimum
approach distance, thereby making work
less safe for employees than if the
ergonomic component remained
constant. As explained previously,
OSHA designed this final rule to ensure
that the ergonomic component of the
minimum approach distance remains at
least 0.31 meters (1 foot) or 0.61 meters
(2 feet), depending on the voltage.
OSHA proposed a minimum approach
distance of 0.31 meters (1 foot) for
voltages of 301 through 750 volts.
Although there were no comments on
this minimum approach distance, the
Agency is adopting a slightly larger
distance. In Section 4.7.1.1, IEEE Std
516–2009 explained its approach to
setting the electrical component of the
minimum approach distance, as follows:
Using this approach for voltages of 301
to 750 volts, OSHA added the 0.31meter (1-foot) ergonomic component of
the minimum approach distance to the
0.02-meter (0.07-foot) electrical
component, for a total minimum
approach distance of 0.33 meters (1.07
feet) in the final rule.
213 IEEE Std 516–2009 assumes that MAID and
MTID have the same value in this voltage range.
Using this approach, the electrical component of
the minimum approach distance would be the same
in air or along the length of an insulated tool.
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As noted earlier, OSHA based the
methodology for calculating the
electrical component of the minimum
approach distance for voltages from 751
volts to 72.5 kilovolts in the 2005
proposal on IEEE Std 4. Table 6 lists the
critical sparkover distances from that
standard as listed in IEEE Std 516–2009.
TABLE 6—SPARKOVER DISTANCE FOR
ROD-TO-ROD GAP
60 Hz Rod-to-rod
sparkover
(kV peak)
Gap spacing from
IEEE Std 4–1995
(cm)
25 ..................................
36 ..................................
46 ..................................
53 ..................................
60 ..................................
70 ..................................
79 ..................................
86 ..................................
95 ..................................
104 ................................
112 ................................
120 ................................
143 ................................
167 ................................
192 ................................
218 ................................
243 ................................
270 ................................
322 ................................
2
3
4
5
6
8
10
12
14
16
18
20
25
30
35
40
45
50
60
Source: IEEE Std 516–2009 (Ex. 0532).
To use the table to determine the
electrical component of the minimum
approach distance, the employer would
determine the peak phase-to-ground
transient overvoltage and select a gap
from the table that corresponds to that
voltage as a withstand voltage rather
than a critical sparkover voltage. For
voltages between 5 and 72.5 kilovolts,
the process for using Table 6 to
calculate the electrical component of the
minimum approach distance, starting
with the phase-to-phase system voltage,
was described generally as follows in
Draft 9 of the 2009 revision to IEEE Std
516 (Ex. 0524):
1. Divide the phase-to-phase voltage
by the square root of 3 to convert it to
a phase-to-ground voltage.
2. Multiply the phase-to-ground
voltage by the square root of 2 to convert
the rms value of the voltage to the peak
phase-to-ground voltage.
3. Multiply the peak phase-to-ground
voltage by the maximum per-unit
transient overvoltage, which, for this
voltage range, is 3.0, as discussed earlier
in this section of the preamble. This is
the maximum phase-to-ground transient
overvoltage, which corresponds to the
withstand voltage for the relevant
exposure.214
214 The withstand voltage is the voltage at which
sparkover is not likely to occur across a specified
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4. Divide the maximum phase-toground transient overvoltage by 0.85 to
determine the corresponding critical
sparkover voltage. (The critical
sparkover voltage is 3 standard
deviations (or 15 percent) greater than
the withstand voltage.)
5. Determine the electrical component
of the minimum approach distance from
the table through interpolation.215
These steps are illustrated in Table 7.
TABLE 7—CALCULATING THE ELECTRICAL COMPONENT OF MAD 751 V TO 72.5 KV
Maximum system phase-to-phase voltage (kV)
Step
15
1. Divide by √3 ............................................................................................
2. Multiply by √2 ..........................................................................................
3. Multiply by 3.0 .........................................................................................
4. Divide by 0.85 .........................................................................................
5. Interpolate from Table 6 .........................................................................
Electrical component of MAD (cm) .............................................................
36
46
72.5
8.7 ...................
12.2 .................
36.7 .................
43.2 .................
3+(7.2/10)*1 ....
3.72 .................
20.8 .................
29.4 .................
88.2 .................
103.7 ...............
14+(8.7/9)*2 ....
15.93 ...............
26.6 .................
37.6 .................
112.7 ...............
132.6 ...............
20+(12.6/23)*5
22.74 ...............
41.9
59.2
177.6
208.9
35+(16.9/26)*5
38.25
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This method is consistent with the
method OSHA used to develop the
minimum approach distances for
voltages of 751 volts to 72.5 kilovolts in
the 2005 proposal. Although OSHA
received no comments on this approach,
the methodology contained in final IEEE
Std 516–2009 added one additional step
(Ex. 0532). The distances in IEEE Std 4–
1995 result from 60-Hz impulse rod-torod tests. The extra step in IEEE Std
516–2009 divides the phase-to-ground
maximum transient overvoltage by 1.3
to account for the difference between
the strength of an air gap under 60-hertz
voltages and the strength under
transient voltages.216 The IEEE
committee relied on two papers that are
not in the current OSHA record to
develop the 1.3 factor.217
OSHA is not adopting this part of the
method that IEEE Std 516–2009 uses to
calculate the electrical components of
the minimum approach distances for
voltages from 751 volts to 72.5 kilovolts.
First, the Agency does not believe that
there is sufficient information in this
record to support the 1.3 conversion
factor, which was not used in earlier
editions of IEEE Std 516 and was not
used in any version of the NESC
through the 2007 edition.218 Second,
although OSHA raised this issue in its
September 2009 reopening notice, no
commenters voiced support for such a
change in the OSHA rule. Finally, as
previously noted, for voltages of 72.5
kilovolts and lower, IEEE Std 516–2009
assumes that the electrical component
of the minimum approach distance is
the same with tools in the air gap as it
is for air alone. The dielectric strength
of an air gap is less with a tool in the
gap than it is when the gap is air,
however (see, for example, Exs. 0556,
0558). Thus, an increase in the electrical
component of the minimum approach
distance is necessary to account for
tools. OSHA does not believe that a 60hertz-to-transient conversion factor
(which reduces MAD values) is
appropriate when no counterbalancing
distance is added to account for tools in
the air gap. For these reasons, the
Agency is adopting the proposed
methodology for determining the
electrical component of the minimum
approach distance for voltages of 751
volts to 72.5 kilovolts. As noted earlier,
OSHA also is adopting the proposed
ergonomic component for this voltage
range. Thus, the final rule incorporates
minimum approach distances for these
voltages generally as proposed.
However, Table V–5 in the final rule
breaks the proposed voltage range of 751
volts to 15 kilovolts into two ranges—
751 to 5,000 volts and 5.1 kilovolts to
15 kilovolts.
For the reasons described earlier
under the discussion of the 301- to 750volt range, IEEE Std 516–2009 sets the
electrical component of the minimum
approach distance at 0.02 meters for
voltages of 301 to 5,000 volts.219 As can
be seen from Table 6, this is the
sparkover distance for the smallest
transient overvoltage listed in the table.
There is no evidence in the record that
lower voltages will produce larger
sparkover distances. Consequently,
there is no reason to believe that the
electrical component of the minimum
approach distance will be greater for
voltages of 5,000 volts or less. In
addition, rounding the electrical
component of the minimum approach
distance to the nearest 25 millimeters
(1.0 inch) results in a minimum distance
of 25 millimeters. As explained earlier,
OSHA concludes that this value is
reasonable and, therefore, adopts 0.02
meter (1 inch) as the electrical
component of the minimum approach
distance for this voltage range.
The electrical component of MAD—
calculation methods for voltages over
72.5 kilovolts. As noted earlier, OSHA
based its proposed minimum approach
distances on criteria adopted by NESC
Subcommittee 8 in 1993. The NESC
based its criteria, at least in part, on
IEEE Std 516–1987. As noted in
Appendix B to proposed Subpart V,
OSHA used the following equation,
which was based on IEEE Std 516–1987,
to calculate the electrical component of
the minimum approach distance for
voltages of 72.6 to 800 kilovolts in the
proposed rule:
distance. It is the voltage taken at the 3s point
below the sparkover voltage, assuming that the
sparkover curve follows a normal distribution.
215 Draft 9 of IEEE Std 516 used curve-fitted
equations rather than interpolation to determine the
distance. The two methods result in nearly
equivalent distances.
216 A 60-hertz voltage cycles through its
maximum, or peak, voltage 60 times each second,
and the value of the voltage forms a sine wave. A
transient overvoltage does not cycle, but generally
increases quickly as a single pulse.
´
217 These documents are (1) CIGRE/SC 33,
‘‘Phase-to-Phase Insulation Coordination,’’
ELECTRA, no. 64, 1979; and (2) Esmeraldo, P. C. V.,
and Fonseca, C. S., ‘‘Evaluation of the Phase-toPhase Overvoltage Characteristics due to Switching
Surges for Application on Risk of Failure Statistical
Methods in Non- Conventional Power Design,’’
Paper 34.01, 6th ISH, New Orleans, 1989.
218 The 2012 NESC adopts minimum approach
distances from IEEE Std 516–2009, which, as noted,
uses the 1.3 conversion factor.
219 The electrical component of MAD is 0.02
meters (1 inch) for all voltages from 301 volts to 5.0
kilovolts. However, the ergonomic component of
MAD is 0.305 meters (1 foot) for voltages up to 750
volts and 0.61 meters for higher voltages as
explained earlier.
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Where:
D = Electrical component of the minimum
approach distance in air in feet
C = 0.01 to account for correction factors
associated with the variation of gap
sparkover with voltage
a = A factor relating to the saturation of air
at voltages 220 of 345 kilovolts or higher
pu = Maximum anticipated transient
overvoltage, in per unit (p.u.)
Vmax = Maximum rms system line-to-ground
voltage in kilovolts—this value is the
true maximum, that is, the normal
highest voltage for the range (for
example, 10 percent above the nominal
voltage).
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220 This voltage is the maximum transient
overvoltage.
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0.01 for the minimum air-insulation
distance and 0.011 for the minimum
tool-insulation distance. OSHA
concludes that these values of C are
reasonable because they are supported
by scientific evidence (Exs. 0556, 0558)
and because there were no other values
recommended in the rulemaking record
for the proposal. Therefore, these values
are incorporated in Table V–2 in the
final rule.
There is one other minor issue that
requires resolution before the electrical
components of the minimum approach
distances for phase-to-ground exposures
can be calculated—that is, the
determination of the saturation factor, a.
The proposed rule and IEEE Std 516–
1987, which formed the original basis
for the calculation of phase-to-ground
minimum approach distances in
existing § 1910.269, relied on Figure 2
in ‘‘Recommendations for Safety in Live
Line Maintenance’’ to determine the
saturation factor (269-Ex. 60; Ex. 0558).
That figure plotted the saturation factor
against crest voltage. In preparing IEEE
Std 516–2009, the IEEE committee
decided to use equations to represent
the saturation factor rather than reading
it from the figure (Ex. 0532). The
committee used a curve-fitting program
to develop the following equations for
the saturation factor for calculating the
electrical components of the minimum
approach distances for phase-to-ground
exposures: 221
221 These equations calculate the saturation
factor, a, for any exposure for which Equation 1 is
used to calculate the electrical components of the
minimum approach distances. However, as
Phase-to-ground exposures. For
phase-to-ground exposures, rulemaking
participants agreed that the proposal’s
methodology for calculating minimum
approach distances was generally
appropriate unless insulated tools were
present across the air gap. (See, for
example, Exs. 0521, 0527.1, 0529,
0575.1.) For instance, EEI commented,
‘‘The existing MAID formula, based on
rod-to-rod gap data, is acceptable for all
line-to-ground applications [through
800 kilovolts with a maximum per-unit
overvoltage of 2.44 per unit]’’ (Ex.
0527.1).
Therefore, the final rule requires
employers to set minimum approach
distances based on Equation 1 for phaseto-ground exposures at voltages of more
than 72.5 kilovolts. Here is the full
equation contained in Table V–2, with
the part that is equivalent to Equation 1
highlighted:
MAD = 0.3048(C + a)VL-GTA + M
The equation in Table V–2 is identical
to Equation 1 except that it: (1)
Incorporates an altitude correction
factor, A, as described later in this
section of the preamble, (2) converts the
result to meters through multiplication
by 0.3048, and (3) adds the ergonomic
component of MAD, M to the electrical
component of MAD given in Equation 1.
In addition, the table uses slightly
different variable designations: VL-G for
Vmax and T for pu.
As explained earlier in this section of
the preamble, OSHA decided to specify
minimum approach distances that
account for the presence of tools in the
air gap unless the employer can
demonstrate that there is only air
between the employee and the
energized part or between the employee
and ground, as appropriate. (The air gap
would be between the employee and the
energized part if the employee is at
ground potential, or at the potential of
another energized part, or between the
employee and ground if the employee is
at the potential of the energized part
during live-line barehand work.)
Consequently, in the equation for phaseto-phase system voltages of more than
72.5 kilovolts in Table V–2, the term C
must be adjusted depending on whether
the minimum tool-insulation distance or
the minimum air-insulation distance
will be used as the electrical component
of the minimum approach distance.
According to IEEE Std 516–2009, C is
explained later in this section of the preamble, the
committee chose to apply Equation 1 only to phaseto-ground exposures.
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The value for pup was to be used for
pu in Equation (1) for calculating the
phase-to-phase MADs.
Until approximately 2007, the
technical committees responsible for
IEEE Std 516 and the NESC calculated
minimum approach distances based on
these equations. Because OSHA was
using the same methodology, the
Agency relied on the technical
committees’ calculations as they
appeared in IEEE Std 516–2003 and the
2002 NESC and proposed to include
those distances in § 1910.269 and
subpart V.
During the revision cycle for IEEE Std
516–2009, the IEEE technical committee
responsible for revising that standard
identified what, in the committee’s
view, was an error in the calculations of
phase-to-phase minimum approach
distances for nominal voltages 230
kilovolts and higher. At these voltages,
the saturation factor, a, which appears
in Equation (1), varies depending on the
voltage; that is, the value of a increases
with increasing voltage. The NESC
subcommittee calculated the phase-tophase minimum approach distances for
the 1993 NESC using a value for the
saturation factor, a, corresponding to the
maximum phase-to-ground transient
overvoltage, rather than the maximum
phase-to-phase transient overvoltage.224
Because, in its proposal, OSHA
borrowed the minimum approach
distances from IEEE Std 516–2003 and
the 2002 NESC, the Agency twice
solicited comments on whether changes
to its rule were necessary in light of the
222 Through an apparent oversight, the IEEE
equations for a fail to cover 635.0 kilovolts.
223 The quality of the graph is poor, and the
underlying data is no longer available (Ex. 0532).
224 ANSI/IEEE Std 516–1987 did not contain
distances for phase-to-phase exposures. The NESC
subcommittee derived them by applying the IEEE
equation, Equation (1), to the phase-to-phase
temporary overvoltages calculated using Equation
(2).
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ER11AP14.005
transient overvoltages (VPeak) as high as
1,600 kilovolts.
Phase-to-phase exposures. For phaseto-phase exposures, OSHA based the
proposal on the 2002 NESC approach,
which used the maximum phase-tophase transient overvoltage in Equation
1 for calculating the electrical
components of minimum approach
distances for phase-to-phase exposures.
As noted in Appendix B to proposed
Subpart V, OSHA used the following
equation to determine the phase-tophase maximum transient overvoltage
based on a system’s per-unit nominal
voltage phase-to-ground crest:
ER11AP14.004
exposures, except for the 1,600-kilovolt
limitation for the last voltage range. As
explained later in this section of the
preamble, the Agency concluded that
extrapolating the saturation factor
beyond the 1,600-kilovolt maximum
switching impulse used during the
experimental testing used to support the
IEEE method is reasonable and will
better protect employees than
alternative approaches. For phase-toground exposures, this limit would have
no practical effect as the Agency
anticipates that few, if any, systems will
have maximum phase-to-ground
Where:
pup = p.u. phase-to-phase maximum transient
overvoltage, and
pug = p.u. phase-to-ground maximum
transient overvoltage.
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OSHA concludes that adopting IEEE’s
method of calculating the saturation
factor is reasonable because that method
will lead to more accurate and
consistent determinations of minimum
approach distances for phase-to-ground
exposures on system voltages of more
than 72.5 kilovolts than approximating
the saturation factor by reading it
directly from the graph, as was done to
calculate the minimum approach
distances in existing § 1910.269.223
Consequently, the Agency is adopting
these equations for calculating the
saturation factor in Table V–2 in the
final rule for phase-to-ground
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errors identified by the IEEE committee
(73 FR 62942, 74 FR 46958).
The consensus among rulemaking
participants was that the proposed
rule’s minimum approach distances for
phase-to-phase exposures at maximum
transient overvoltages exceeding
approximately 630 kilovolts involved a
mathematical error. (See, for example,
Exs. 0521, 0524, 0526.1, 0528, 548.1;
Tr2. 122–123, 139.) Draft 9 of the 2009
revision of IEEE Std 516 derived
formulas for the saturation factor, a,
using a curve-fitting program (Ex. 0524).
When maximum phase-to-phase
transient overvoltages are less than 630
kilovolts, a is 0.0, and the mathematical
error is not present (id.). For higher
maximum transient overvoltages, a is a
function of the peak voltage, which is
higher for phase-to-phase exposures
than it is for phase-to-ground exposures
(id.)
Because the proposed rule used an
approach for calculating phase-to-phase
minimum approach distances that
commenters generally agreed was in
error, OSHA decided to make changes
in this final rule to account for that
mistake.
To determine the increased risk to
employees, OSHA compared the
probability of sparkover for the
electrical component of the largest
proposed minimum approach distance
with the probability of sparkover for the
electrical component of the corrected
minimum approach distance.225 For
systems operating at 800 kilovolts, the
probability of sparkover with the
maximum phase-to-phase transient
overvoltage at the corrected electrical
component of the minimum approach
distance is approximately 1 in 1,000.
The probability of sparkover at the
proposed electrical component of the
minimum approach distance is 64 in
100. Clearly, the proposed minimum
approach distance poses significant risk
to employees when the phase-to-phase
transient overvoltage is at its maximum.
Because, for systems operating at 800
kilovolts, the minimum approach
distance in the existing standard is the
same as the distance in the proposed
rule, the existing standard also poses a
substantial risk to employees.
OSHA calculated the probabilities of
sparkover at the proposed electrical
component of the minimum approach
distance and the corrected minimum
approach distance in the following
225 The corrected minimum approach distance is
the minimum approach distance calculated with an
extrapolated saturation factor for the maximum
phase-to-phase transient overvoltage in place of the
maximum phase-to-ground transient overvoltage.
This is the method used in IEEE Std 516 Draft 9
(Ex. 0524).
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manner. The minimum approach
distance proposed in Table V–2 for this
exposure was 7.91 meters, and the
electrical component of this distance
was 7.60 meters (7.91 meters ¥ 0.31
meters). The phase-to-phase maximum
transient overvoltage at 800 kilovolts is
2,352 kilovolts.226 Draft 9 of the 2009
revision of IEEE Std 516 derived
formulas for the saturation factor, a,
using a curve-fitting program. Equation
59 in that draft standard provided the
following equation for a for maximum
transient overvoltages of more than
1,485 kilovolts:
a = (TOV ¥ 1,485) × 0.00000491 +
0.0055704,
where TOV is the maximum transient
overvoltage (Ex. 0524).
This equation extrapolates a beyond
the 1,600-kilovolt upper limit on
available rod-gap test data. Using this
equation to determine a and using that
value in Equation 1, the withstand
voltage corresponding to 7.60 meters is
1,966 kilovolts. The critical sparkover
voltage for a 7.60-meter gap is 1,966 ÷
0.85, or 2,312, kilovolts. (See Step 4 in
the explanation of how to use Table 6
to determine the electrical component of
clearance earlier in this section of the
preamble.) The probability of sparkover
for this distance at the maximum
transient overvoltage of 2,352 kilovolts
is 64 percent.227 This percentage means
that the electrical component of the
proposed minimum approach distance
at 800 kilovolts has a probability of 64
percent of sparking over at the industryaccepted maximum per-unit transient
overvoltage of 2.0.
There were three basic methods
submitted to the record for calculating
minimum approach distances for phaseto-phase exposures. The first method
was the one OSHA used in developing
the proposed rule. As described earlier
in this section of the preamble, that
226 Using Equation 2, the phase-to-phase
maximum per-unit transient overvoltage is 2.0 +
1.6, or 3.6, times the peak phase-to-ground voltage.
The peak phase-to-ground voltage is the maximum
system phase-to-phase voltage times √2 divided by
√3. Thus, the maximum transient overvoltage for a
phase-to-phase exposure for a maximum system
voltage of 800 kilovolts (the highest system voltage)
is 3.6 × 800 × √2 ÷ √3, or 2,352, kilovolts.
227 The probability of sparkover is determined by
normalizing the mean (average) sparkover voltage
and the standard deviation and looking up those
two normalized parameters in standard distribution
tables. The critical sparkover voltage (that is, the
mean voltage that will spark over) is 2,312 kilovolts.
The standard deviation is 5 percent of this value,
or 115.6 kilovolts. The maximum transient
overvoltage corresponding to the industry-accepted
value of 2.0 per unit at 800 kilovolts is 2,352
kilovolts, or 0.346 standard deviations above the
mean voltage at sparkover. The probability of
sparkover can be determined from normal
distribution tables for a Z of 0.346.
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method used Equation (1) and Equation
(2) to determine the minimum approach
distance, but without adjusting the
saturation factor, a, in Equation (1) to
account for the increase between the
phase-to-ground and phase-to-phase
maximum transient overvoltage. For the
reasons already explained, OSHA
concludes that this method is invalid
and would expose employees to an
unreasonable increase in risk for phaseto-phase exposures at maximum
transient overvoltages higher than 630
kilovolts. Consequently, the Agency
decided against adopting this method in
the final rule.
The second method, adopted by IEEE
Std 516–2009, uses equations based on
the paper by Vaisman,228 and two
papers by Gallet,229 to determine
minimum approach distances (Ex.
0532). OSHA refers to this method as
the ‘‘IEEE method’’ in the following
discussion.
The formula used in IEEE Std 516–
2009 for calculating phase-to-phase
minimum approach distances for
voltages of 72.6 kilovolts and higher is
derived from testing that replicates line
configurations rather than live-line
work. Accordingly, the underlying
formula in IEEE Std 516–2009 originally
was intended for determining
appropriate conductor spacing rather
than for determining minimum
approach distances appropriate for
employees performing live-line work.
To account for the presence of an
employee working in an aerial lift
bucket within the air gap between the
two phase conductors, the IEEE
committee incorporated the concept of a
floating electrode in the air gap. The
committee’s approach to determining
the electrical component of the
minimum approach distance can be
summarized as follows:
1. Start with a formula to calculate the
critical sparkover voltage for the
distance between two conductors.
2. Modify the formula to account for
a 3.3-meter floating electrode
representing an employee working
within an aerial lift bucket between the
phase conductors.
3. Modify the formula to convert the
critical sparkover voltage to a withstand
voltage.
228 Vaisman,
op cit.
G., Leroy, G., Lacey, R., and Kromer, I.,
‘‘General expression for positive switching impulse
strength valid up to extra line air gaps,’’ IEEE
Transaction on Power Apparatus and Systems, vol.
PAS–94, pp. 1989–1993, Nov./Dec. 1975 (Ex. 0560);
and Gallet, G., Hutzler, B., and Riu, J–P., ‘‘Analysis
of the switching impulse strength of phase-to-phase
air gaps,’’ IEEE Transactions on Power Delivery, vol.
PAS–97, no. 2, Mar./Apr. 1978 (Ex. 0553).
229 Gallet,
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4. Determine the maximum transient
overvoltage on the line, and substitute
that value for the withstand voltage.
5. Rearrange the equation to solve for
distance.
In more technical detail, this
approach is described as follows:
1. The equation for calculating the
critical sparkover voltage for a given
distance between two conductors
includes a gap factor, k. This factor
depends on several variables:
alpha = the proportion of the negative
switching impulse voltage to the
total phase-to-phase impulse
voltage,
Ddesign L-L = the design phase-to-phase
clearance, and
H = the average height of the phase
above the ground.
Table 8 shows the values
recommended by IEEE Std 516–2009 for
these variables and the resultant gap
factors.
TABLE 8—IEEE STD 516–2009 GAP FACTORS (k)
Phase-to-phase voltage
alpha
≤ 242 kV ..............................................................................................................
> 242 kV ..............................................................................................................
IEEE Std 516–2009 uses the following
equation to calculate the critical
sparkover voltage for the designed gap
between two phase conductors:
Where:
V50 = the critical sparkover voltage in
kilovolts,
k = the gap factor from Table 8, and
Dl-l = the sparkover distance in meters.
2. When an employee performs liveline barehand work, the employee
typically is positioned between two or
more phase conductors. The employee
could be working, for example, from an
aerial lift platform or a conductor cart.
These devices and the worker are both
0.33
0.41
L-L/H
k
0.8
0.8
1.451
1.530
conductive. The presence of a
conductive object in the air gap between
the two electrodes (which, in this case,
are the two conductors) reduces its
dielectric strength. IEEE Std 516–2009
introduces a constant, KF, to account for
the presence of the employee and other
conductive objects in the air gap. In that
consensus standard, KF equals 0.9 to
accommodate a 3.3-meter conductive
object in the air gap. This value is
equivalent to a 10-percent reduction in
the dielectric strength of the gap.
With this factor included, the
equation for the critical sparkover
voltage is:
3. IEEE sets the withstand voltage at
a level that is 3s lower than the critical
sparkover voltage, as indicated in the
following equation:
VW = (1¥3s)V50
TL-G = the phase-to-ground maximum
transient overvoltage in per unit.
equations for distance, IEEE Std 516–
2009 uses the following equations to
calculate the minimum air-insulation
distance:
5. Substituting the values of the
various constants and solving these
Where:
VW = the withstand voltage,
V50 = the critical sparkover voltage, and
s = 5 percent for a normal distribution.
4. To solve for the electrical
component of the clearance, the
maximum transient overvoltage is
substituted for the withstand voltage.
The IEEE committee used the following
equation to calculate the maximum
transient overvoltage on the line:
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Where:
TL-L = the phase-to-phase maximum transient
overvoltage in per unit, and
Ddesign
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Where:
DL-L = the minimum air-insulation distance
(the minimum distance needed to
prevent sparkover with air alone as the
insulating medium),
TL-G = the phase-to-ground maximum
transient overvoltage in per unit, and
VL-L = the rms phase-to-phase system voltage.
Testifying on behalf of EEI, Dr. Horton
explained the IEEE method as follows:
is well recognized that the dielectric
strength of a given electrode geometry is
different for line-to-ground surges than
for line-to-line surges. A phase-to-phase
surge between two phases is the voltage
difference between the phase-to-ground
surges which may be of opposite
polarity and displaced in time, (and
many times are) whereas a maximum
phase-to-ground surge is considered
uni-polar.
*
*
*
*
*
[The surges from the two phases] are
displaced by some amount of time. . . .
The resulting line-to-line surge . . . will
stress a given air gap geometry differently
than either of the line-to-ground surges that
the resulting waveform is comprised of.
Unlike line-to-ground insulation
characteristics of a given electrode geometry,
which depend primarily on the gap spacing,
line-to-line insulation characteristics . . . are
more complex because one of the surges has
a positive polarity with respect to ground
while the other has a negative polarity with
respect to ground.
The resulting insulation strength is a
function of alpha, which again, is the ratio
of the negative surge to the sum of the
negative and positive surge.
The IEEE recently tried to address this
limitation [in IEEE Std 516–2009] by
developing a method based on a modified
version of the Gallet equation. The upper
voltage limit of the resulting equation is 3500
kV peak or air gap distances of up to 15
meters. This limitation is well within the
typical range of live-line working scenarios
in the United States.
Historically, IEEE Standard 516 has used
rod-to-rod electrode geometry data for
determining line-to-ground MAID. One
reason for this is that the test data that the
method is based on represents a rod-to-rod
electrode configuration.
In addition, the line-to ground [testing] that
was performed showed that the rod-to-rod
results were in the middle range for a wide
range of conductor configurations. The rodto-rod data presented neither the worst case
nor the best. Thus, it was chosen as a
reasonable representation of all the possible
gap configurations to which a line worker
might be exposed while performing tasks,
which are characterized as line-to-ground.
When considering line-to-line minimum
air insulation distances, a rod-to-rod gap may
not be the most appropriate. Typically, the
worker will bond onto one phase and will
not need to bridge the gap to the other phase.
Since the shape of the adjacent electrode
remains unchanged during the task, (in other
words it remains a conductor) the resulting
air gap geometry more closely resembles that
of a conductor-to-conductor. The effect of the
change in geometry of the phase to which the
worker is bonded is dealt with in the new
IEEE method by introducing an additional
factor that accounts for the effect of large
conductive objects floating in the air gap.
[Tr2. 83–86]
No rulemaking participant
recommended that OSHA adopt the
IEEE method for calculating minimum
air-insulation distances for phase-tophase exposures at more than 72.5
kilovolts. In addition, the Agency has
several concerns with the approach
taken in that consensus standard. First,
the IEEE method relies on test data for
an electrode configuration that is not
comparable to the rod-to-rod gap used
for phase-to-ground exposures on which
OSHA based the minimum approach
distances in existing § 1910.269.
Second, the choices for some of the
parameters used in the equations for the
electrical component of the minimum
approach distance appear to be
arbitrary. Third, the IEEE method is
based on papers that explore the
dielectric strength of electric power
lines rather than the dielectric strength
of circuit parts configured as they would
be when employees are performing liveline barehand work.
(1) Conductor-to-conductor-based
method does not accurately model
employee exposure. OSHA considered
the evidence in the record and
concludes that the IEEE method, which
is based on testing on conductor-toconductor electrodes, does not
accurately model employee exposure.
As noted by Dr. Horton, the approach
taken by existing § 1910.269 and earlier
editions of IEEE Std 516 based the
calculation of minimum air-insulation
distances for both phase-to-ground and
phase-to-phase exposures on phase-toground testing of rod-to-rod electrodes
(Tr2. 85).230 By adopting the approach
taken in IEEE Std 516–1987 in
promulgating existing § 1910.269,
OSHA deemed it reasonable to rely on
rod-to-rod gap data (59 FR 4383–4384).
The record in this rulemaking contains
reports of tests on a variety of electrode
configurations, showing clearly that the
dielectric strength of air varies with the
configuration (269-Ex. 60; Exs. 0553,
0554). In reviewing the record, OSHA
has again concluded that phase-toground rod-to-rod gap test data forms a
reasonable basis for the determination of
minimum approach distances because it
falls in the middle range of various
electrode configurations (that is, it is
neither the best case nor the worst). In
addition, OSHA believes that employees
performing work on energized lines are
rarely exposed to the worst-case
configuration, rod-to-plane electrodes,
or to the best-case configuration, sphereto-sphere electrodes. Thus, an exposure
representing the middle range of various
electrode configurations is reasonable
for a model based on phase-to-ground
testing.
A paper by Gallet 231 reports on a
variety of phase-to-phase gap factors,
including supported busbars and
asymmetrical geometries, as shown in
the following table (Ex. 0553):
Electrode geometry
alpha = 0.5
Rings or large, smooth electrodes ..........................................................................................................
Crossed conductors .................................................................................................................................
Rod-rod or conductor-conductor ..............................................................................................................
Supported busbars ..................................................................................................................................
Asymmetrical geometries ........................................................................................................................
1.80
1.65
1.62
1.50
1.45
alpha = 0.33
1.70
1.53
1.52
1.40
1.36
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Table reprinted with permission from the Institute for Electrical and Electronics Engineers (IEEE). OSHA revised the table from IEEE’s original.
Although the performance during
phase-to-phase tests are the same for
rod-to-rod and conductor-to-conductor
electrodes, OSHA concludes that phase-
to-phase exposures are more likely to
correspond to asymmetrical geometries,
which, as can be seen from the table in
the Gallet paper, have a lower dielectric
strength than rod-to-rod or conductor-
230 Typical configurations include rod-rod, rodplane, and conductor-plane. The terminology refers
to the configuration of the two electrodes. For
example, in a rod-plane configuration, one of the
electrodes is a rod perpendicular to an electrode in
the shape of a plane.
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231 Gallet,
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to-conductor electrodes.232 Employees
performing live-line barehand work face
a wide variety of exposure conditions
reflecting a number of different
electrode configurations. Several of
these electrode configurations are not
equivalent to conductor-to-conductor
electrodes. Employees working on
energized supported busbars could
experience phase-to-phase exposures.
Additionally, during live-line barehand
work on energized conductors,
employees are working on the
conductors, and the installation may be
configured differently when maintained
or installed. For example, a damaged
portion of a bundled conductor may
protrude from the bundle, or an
employee may be holding an armor rod
perpendicular to the conductor. The
equipment used to position the
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232 Dielectric strength is proportional to the gap
factor. Thus, a smaller gap factor yields a lower
dielectric strength.
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employee also can affect the shape of
one of the electrodes. The Agency
believes that these examples may more
closely resemble asymmetrical
geometries. Consequently, the gap factor
for those electrode configurations, as
shown in the table, would be lower than
the gap factor used in IEEE Std 516–
2009. The IEEE standard reduced the
gap factor by accounting for a
conductive object in the gap. However,
the Agency believes that such a
reduction also would be necessary when
another conductive object is in the air
gap while an employee is working on an
energized conductor, which could occur
as equipment is transferred to the
employee or if a second worker is in the
air gap. Thus, OSHA concludes that a
model based on phase-to-phase testing
should be based on asymmetrical
electrode geometries and that the IEEE
committee’s choice of a conductor-toconductor gap is not appropriate.
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20441
(2) The values of some of the
parameters used in the IEEE method
appear to be arbitrary. The ratio of the
negative switching impulse voltage to
the total phase-to-phase impulse voltage
is designated as alpha. Dr. Horton
described this parameter, and its
importance, as follows:
A phase-to-phase surge between two
phases is the voltage difference between the
phase-to-ground surges which may be of
opposite polarity and displaced in time, (and
many times are) whereas a maximum phaseto-ground surge is considered uni-polar.
[Figure 5] shows how two separate phaseto-ground surges combine to form a line-toline surge. . . .
[W]e have one [transient] for phase 1 and
we have . . . one for phase 2, and . . . they
are displaced by some amount of time. The
resulting transient overvoltage or surge that
would be across the air gap, which would be
the line-to-line air gap, would be . . . a
combination of the [two] curve[s]. [Tr2. 83–
84]
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The IEEEcommittee used an alpha of
0.33 for system voltages up to 242
kilovolts. However, the committee used
a value of 0.41 for higher system
voltages. It described the rationale for
this latter decision with a quote from
the Vaisman paper:
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In [extra-high voltage] systems, where there
is efficient overvoltage control and hence the
overvoltage factor a tends to lie in the range
of 0.41 to 0.50, the ratio between the line-toline (D1) and the line-to-ground (D) clearance
equal to 2.0 is the one which provides a more
233 Figure 5, which is a copy of Figure 4 from Ex.
0545.1, was included in the presentation by Dr.
Horton at the October 28, 2009, public hearing.
(See, also, Ex. 0567.) EEI identified the source of
this figure as EPRI Transmission Line Reference
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balanced distribution of flashovers between
the two gaps. [Ex. 0532]
OSHA has two concerns about this
choice. First, the paper does not
indicate that an alpha of 0.41 is the
smallest expected for these systems. A
smaller value of alpha will produce a
smaller value for the gap factor, k, and,
consequently, a larger electrical
component of the minimum approach
distance.234 Second, it is not clear why
efficient overvoltage control has any
effect on alpha. Overvoltage control
Book: 115–345-kV Compact Line Design, 2007 (Blue
Book).
234 In the IEEE method, the critical sparkover
voltage, V50, is directly proportional to k, and the
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limits the maximum transient
overvoltage on each individual phase,
but it does not necessarily limit the
delay between the peak transient
overvoltage on each phase, which
appears as DTcr in Figure 5. The
Vaisman paper also explored the effect
of DTcr, which is not accounted for in
the IEEE method:
In other tests, where only the negative
wave was displaced, the observed reductions
were:
minimum air-insulation distance (the electrical
component of the minimum approach distance) is
inversely proportional to V50. Thus, the electrical
component of the minimum approach distance is
inversely proportional to k.
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20443
TABLE 2—REDUCTION IN [V50] WHEN DISPLACING THE NEGATIVE WAVE
[alpha]
Desired
0.33
0.50
0.33
0.50
......................................................................................................................
......................................................................................................................
......................................................................................................................
......................................................................................................................
Nevertheless, under these conditions,
besides the shift between impulses, there was
also a decrease of [alpha].
From all the results a maximum reduction
of 8.7% in the value of U50 can be observed
when the positive and negative components
of phase-to-phase overvoltage are not
synchronized [Ex. 0555].
0.28
0.43
0.22
0.36
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From Figure 5, it is clear that the
maximum overvoltage occurs when the
positive and negative transient waves
are synchronized, that is, when DTcr =
0. In addition, it is clear from the BPA
report that the poles of a circuit breaker
do not trip simultaneously (Ex. 0575.1).
In addition, circuit characteristics also
may contribute to the size of DTcr. The
DTcr range shown in the Vaisman paper
does not seem unreasonable. Thus, from
this paper, on which the IEEE
committee relied, it appears that the
maximum phase-to-phase transient
overvoltage should be calculated, as
shown by Table 2 in the Vaisman paper,
by using an alpha of 0.50 and reducing
the critical sparkover voltage by 8.7
percent. In this case, the peak
overvoltage on each phase has the same
value, which seems reasonable if the
phases are identical in most respects,
but displaced by 2 milliseconds, which,
based on the BPA report, also seems
reasonable.
(3) The IEEE method is based on
papers on the design of lines rather than
employee safety during maintenance.
Finally, OSHA has a concern that the
IEEE method is based almost
exclusively on papers that explore the
dielectric strength of lines. Employees
perform work on energized lines and
equipment. In addition, the lines on
which employees work during
maintenance and repair may not be in
the same condition as the lines were
when they were first installed. The
Agency believes that it is appropriate to
base minimum approach distances for
workers on papers and scientific data
derived from actual working conditions.
The Agency agrees with Dr. Horton
and EEI that phase-to-phase
overvoltages are more complicated than
phase-to-ground overvoltages. However,
the Gallet formula on which the IEEE
method is based models phase-toground, as well as phase-to-phase,
critical sparkover voltages. In addition,
the IEEE committee chose not to use it
for phase-to-ground exposures,
presumably because the papers
supporting the method for phase-toground exposures examined the safety
of employees performing live-line
maintenance.235 OSHA believes that
these papers support the method used
in the final rule to calculate minimum
approach distances for phase-to-phase
exposures, as well as phase-to-ground
exposures. Therefore, for all the
foregoing reasons, OSHA concludes that
the IEEE approach does not reasonably
represent the range of overvoltages or
the dielectric strength of air gaps that a
worker will encounter during phase-tophase exposures.
The third method, described in Drafts
9 and 10 of IEEE Std 516 and
incorporated in this final rule, uses
Equation (3) 236 to determine the
maximum per-unit transient
overvoltage, calculates the saturation
factor, a, based on the maximum phaseto-phase transient overvoltage, and uses
Equation (1) 237 to determine the
minimum approach distance (Exs. 0524,
0525). The calculation of the saturation
factor uses a curve-fitted equation,
235 IEEE Std 516–2009 listed three papers that
supported the method used for phase-to-ground
exposures:
Elek, A., and Simpson, J. W., ‘‘Safe clearance and
protection against shocks during live-line work,’’
AIEE Transaction on Power Apparatus and
Systems, vol. 80, pt. III, pp. 897–902, Feb. 1962.
IEEE Committee Report, ‘‘Live-line maintenance
methods,’’ IEEE Transactions on Power Apparatus
and Systems, vol. PAS–92, pp. 1642–1648, Sept./
Oct. 1973.
IEEE Committee Report, ‘‘Recommendations for
safety in live-line maintenance,’’ IEEE Transactions
on Power Apparatus and Systems, vol. PAS–87, no.
2, pp. 346–352, Feb. 1968.
All three of these papers examined minimum
approach distances for live-line work (Ex. 0532).
236 T
L-L = 1.35TL-G + 0.45. OSHA is adopting this
equation in Table V–2. Drafts 9 and 10 of IEEE Std
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DTcr
(ms)
[alpha]
Obtained
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(%)
1
1
2
2
1.5
3.1
4.0
8.7
which extrapolated the value for that
factor beyond the 1,600-kilovolt
limitation on the test data noted earlier.
OSHA refers to this method as the
‘‘extrapolation method’’ in the following
discussion. In comments responding to
the 2008 reopening notice, Mr. Brian
Erga with ESCI supported the adoption
of this method because it corrects the
calculation error present in the 2003
edition of IEEE Std 516 (Ex. 0521).
Other rulemaking participants
objected to the extrapolation of the
saturation factor. (See, for example, Exs.
0545.1, 0548.1; Tr2. 77–79.) These
rulemaking participants maintained that
there was no test data to support
extrapolating this factor and argued that
other methods of estimating the
dielectric strength of air demonstrated
that extrapolating the saturation factor
would result in minimum approach
distances that are ‘‘dangerously
inaccurate’’ (Ex. 0548.1). The Southern
Company explained its objections as
follows:
[T]here are at least two methods of
estimating the dielectric strength of air gaps
that show that extrapolating the saturation
factor, ‘‘a’’, beyond the test data [reference
omitted] for which it was based is not valid.
A comparison of the MAID values computed
using the [extrapolation] formula and those
of Gallet and CRIEPI [238] [references omitted]
show that extrapolating test points beyond
the 1650 kV range is dangerously inaccurate.
[Id.]
The Southern Company described how
it ‘‘manipulated’’ the formulas and
plotted the results, comparing the
extrapolation method with the other two
methods (the Gallet and CRIEPI
formulas), as shown in Figure 6.
516 and final IEEE Std 516 adopt this equation for
calculating the phase-to-phase maximum per-unit
transient overvoltage (Exs. 0524, 0525, and 0532),
and there is no evidence in the record to indicate
that it does not accurately represent the phase-tophase maximum per-unit transient overvoltage.
237 D = (C + a) × pu × V
max.
238 Central Research Institute of Electric Power
Industry.
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Southern Company included a second
figure (not shown here) consisting of the
area beyond 1,600 kilovolts, where test
data is unavailable to support either
Equation (1) or the determination of the
saturation factor, a. The commenter
concluded:
[These figures] show that three methods
agree rather closely for transient overvoltages
less than 1600 kV (the limitation of the
[Drafts 9 and 10] IEEE method). However, at
approximately 1800 kV, the results found
using the Gallet and CRIEPI formulas diverge
significantly from the [extrapolation] method.
The reason for this is primarily due to the
fact that the Gallet and CRIEPI formulae are
based on test data in this voltage range,
whereas, the [extrapolation] formula is not.
[Id.]
OSHA notes that there is a similar
divergence between these formulas at
voltages from 600 to 750 kilovolts. The
following table shows minimum airinsulation distances for two voltages 239
using the Equation (1) extrapolation
method and Southern Company’s
modified Gallet formula:
Voltage
Equation (1)
based on
extrapolation
method 1
Modified gallet
formula
592.8 kV .....................................................................................................................
2149.0 kV ...................................................................................................................
1.28 meters ........
9.23 meters ........
1.50 meters ........
10.68 meters ......
17
16
on IEEE Standard 516 Draft 9 (Ex. 0524).
This table shows a substantial
difference between the Southern
Company’s modified Gallet formula and
the extrapolation method at voltages
where test data exist. Southern
Company’s modified Gallet formula
produces minimum approach distances
that are much higher at voltage levels
where test data exist than they are
where test data do not exist. Because the
modified Gallet formula does not
accurately produce minimum approach
distances where test data exists, there is
no reason to believe that it will
accurately calculate minimum approach
distances where there is no test data.
Therefore, OSHA concludes that it
cannot rely on the Southern Company’s
analysis to show that the extrapolation
method does not provide adequate
employee protection.240 The results of
this comparison are not surprising. The
curves representing these formulas have
slightly different shapes. In comparison
to Equation (1), in which the saturation
factor increases nearly linearly before
and after extrapolation, the Gallet
formula results in a small increase in
the saturation factor at lower voltages,
but a large increase at higher voltages.
Thus, despite the similarity in
appearance between the two equations,
OSHA concludes that, compared to the
extrapolation method, the modified
Gallet formula does not equally
represent the strength of the air gap.
Further exploration of the modified
Gallet and CRIEPI formulas sheds
additional light on this issue. The Gallet
formula uses a gap factor as one
parameter. Southern Company used a
gap factor of 1.3 in its comparison.
Although the comment stated that
Southern Company based the gap factor
on rod-to-rod electrode configurations,
239 OSHA chose 592.8 and 2,149 kilovolts (which
correspond to systems of 161 kilovolts at 3.0 perunit maximum transient overvoltage and 800
kilovolts at 2.1 per-unit maximum transient
overvoltage) because these values generally
represent the low and high end of the voltage range
covered by Figure 6. In addition, there is rod-gap
test data supporting the current method at 592.8
kilovolts, but not at 2,149 kilovolts.
240 The Agency did not compare the modified
CRIEPI formula as there is no evidence in the record
to suggest that OSHA base the final rule on that
formula.
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1 Based
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Federal Register / Vol. 79, No. 70 / Friday, April 11, 2014 / Rules and Regulations
there is no record support for this value.
The lowest value for the gap factor
provided in the Gallet paper was 1.36
(Ex. 0553). Had Southern Company used
a gap factor of 1.33 instead,241 the
differences between the equations
would be generally smaller, and the
high-voltage ‘‘difference’’ noted by
Southern Company would not be
apparent until approximately 2,100
kilovolts. At system voltages higher than
242 kilovolts, IEEE Std 516–2009 uses a
gap factor equivalent to 1.377, which
results in smaller rather than larger
minimum air-insulation distances at
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241 With no record support for a gap factor of 1.3,
it appears that Southern Company chose the gap
factor arbitrarily. In this example, OSHA has chosen
an equally arbitrary gap factor simply to show how
the curves can be manipulated.
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voltages between approximately 800
and 2,200 kilovolts (Ex. 0532).
Therefore, the Agency is rejecting
Southern Company’s argument that the
modified Gallet and CREIPI formulas
show that the extrapolation method is
not sufficiently protective.
The concern about the lack of test
data appears to be unfounded, at least
for the range of overvoltages addressed
by the final rule. The largest overvoltage
addressed by the final rule is
approximately 2,500 kilovolts, which
corresponds to an 800-kilovolt system
with a phase-to-ground maximum perunit transient overvoltage of 2.5 pu. The
test data for rod-to-rod gaps extends to
1,600 kilovolts. Thus, the data cover
about two thirds of the voltage range
covered by the final rule, and the test
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20445
data provide substantial support for
maximum transient overvoltages of
1,600 kilovolts (which corresponds to
an 800-kilovolt system with a 1.5 perunit maximum transient overvoltage)
regardless of whether the exposure is
phase-to-phase or phase-to-ground. In
addition, the saturation factor varies
almost linearly with voltage, as can be
seen from the table and graphs of
voltage vs. saturation factor in the IEEE
reports on which Equation (1) is based
(Exs. 0556, 0558). Figure 7 reproduces
the relevant graphs in those papers.242
Thus, an extrapolation of the saturation
factor likely will produce reasonable
results.
BILLING CODE 4510–26–P
242 This graph is Figure 1 in Ex. 0556 and Figure
2 in Ex. 0558.
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BILLING CODE 4510–26–C
In addition, as noted earlier, the
Gallet and CRIEPI formulas, the other
two formulas described by Southern
Company for determining sparkover
voltages, have a similar shape. (See
Figure 6.) The extrapolation method
might not be as conservative at the
highest voltages as the Gallet and
CRIEPI formulas. However, because the
modified Gallet and CREIPI formulas
rely on a gap factor that is unsupported
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on the record, and because the gap
factor adopted in IEEE Std 516–2009
yields minimum approach distances
that are less conservative than the
extrapolation method, the Agency
believes that the extrapolation method
will provide adequate protection for
workers. For these reasons, OSHA
concludes that it is reasonable to
extrapolate the test data to determine
minimum approach distances.
Consequently, the final rule adopts the
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extrapolation method of determining
minimum approach distances by
providing equations for calculating the
saturation factor, a, as described in the
following paragraphs.
Drafts 9 and 10 of the 2009 revision
of IEEE Std 516, as well as the approved
edition of that standard, provided linear
equations for the saturation factor.
These equations varied depending on
the voltage range (Exs. 0524, 0525,
0532). IEEE Std 516–2009 limits the
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equation for the highest range to
transient overvoltages of 1,600 kilovolts
(Ex. 0532).243 Drafts 9 and 10 of the
2009 revision of that IEEE standard
extrapolated the saturation factor by
applying the equation for the highest
voltage range without limit (Exs. 0524,
0525). OSHA notes that Drafts 9 and 10
of IEEE Std 516 used slightly different
equations for the calculation of the
saturation factor than does IEEE Std
516–2009 (Exs. 0524, 0525, 0532). The
Agency compared the results of the two
sets of equations with the data from the
original IEEE reports on which Equation
(1) is based and determined that the
equations from IEEE Std 516–2009 fit
the data precisely. However, IEEE Std
516–2009 notes:
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[T]here is a different value of the ‘‘a’’
[saturation] factor for same voltage used to
calculate MAID and MTID. To avoid having
values of the ‘‘a’’ factors for MAID and MTID,
the working group decided to use only the
MTID ‘‘a’’ factor since it matches the values
of the ‘‘a’’ factor shown on the figure. [Ex.
0532]
Thus, the IEEE standard bases the
saturation factor on the withstand
voltages with tools in the gap. OSHA
believes that this approach is
appropriate for phase-to-ground
exposures. However, for phase-to-phase
exposures, which almost never involve
tools across the gap, the Agency believes
that this approach is unnecessarily
conservative. Draft 9 of the IEEE
standard uses equations for the
saturation factor based on test data for
air gaps without tools. Therefore, the
final rule bases the saturation factor on:
(1) The equations from IEEE Std 516–
2009 for phase-to-ground exposures and
(2) the equations in Draft 9 of that
standard for phase-to-phase exposures.
Therefore, Table V–2 applies the
equations for the saturation factor, a,
from IEEE Std 516–2009 to phase-toground exposures, while using the
equations for this factor from Draft 9 of
that standard for phase-to-phase
exposures. To extrapolate the saturation
factor to the highest voltage addressed
by the final rule, OSHA is extending the
application limit of Equation 59 from
IEEE Std 516–2009. The Agency based
these equations on the assumption that
no insulated tool or large conductive
object are in the gap. Note 3 to Table V–
2 indicates that, if an insulated tool
spans the gap or if a large conductive
object is in the gap, employers are to use
243 It should be noted that, despite the 1,600kilovolt limitation, IEEE Std 516–2009 apparently
applies this equation to 1,633 kilovolts (the
maximum transient overvoltage on an 800-kilovolt
system with a 2.5 per-unit maximum transient
overvoltage) in the minimum approach distance
tables in Appendix D of that standard.
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the equations for phase-to-ground
exposures (with VPeak for phase-to-phase
exposures).
Circuits operating at 362.1 to 420
kilovolts. In the 2009 reopening notice,
OSHA noted that IEEE Std 516–2009
included an additional voltage range,
362.1 to 420 kilovolts, in its minimum
approach distance tables; this range did
not appear in OSHA’s proposed rule (74
FR 46962). The Agency requested
comments on whether it should add this
voltage range to the minimum approach
tables in the final rule. Rulemaking
participants recommended adding this
voltage range to the OSHA standard,
though no electric utilities responding
to the issue operated any system in this
voltage range. (See, for example, Exs.
0545.1, 0548.1, 0551.1; Tr2. 93, 159.) Dr.
Randy Horton, testifying on behalf of
EEI, stated:
OSHA should include these voltage ranges
in the final [r]ule in order to provide
complete guidance to the industry. However,
there are not many lines that operate at these
voltages within the American electric utility
industry. [Tr2. 93]
Although it appears that there are few,
if any, electric power transmission
systems in the United States operating
at 362.1 to 420 kilovolts, OSHA is
including this voltage range in the final
standard. Otherwise, an employer with
a system operating in this voltage range
would have to set minimum approach
distances based on a maximum system
voltage of 550 kilovolts, the highest
voltage in the next higher voltage range
listed in Table V–6. Even if systems
operating in the 362.1- to 420-kilovolt
range are extremely rare, OSHA is not
requiring employers to adhere to
minimum approach distances that are
substantially higher than necessary to
protect employees doing work at those
voltages. Therefore, OSHA decided to
include the 362.1- to 420-kilovolt range
in Table V–6 in the final rule, which
specifies alternative minimum approach
distances for worksites at an elevation of
900 meters or less. Employers not using
that table can establish minimum
approach distances for any particular
voltage, including voltages in the 362.1to 420-kilovolt range, using the
equations in Table V–2 for the
maximum voltage on the particular
circuit involved.
The electrical component of MAD—
DC exposures. OSHA proposed
minimum approach distances for dc
circuits in Table V–5. OSHA received
no comments on these minimum
approach distances and, therefore, is
adopting them in Table V–7 of the final
rule as proposed.
OSHA’s requirements on minimum
approach distances better effectuate the
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purpose of the OSH Act than the
national consensus standard. Whenever
a final rule differs substantially from an
existing national consensus standard,
Section 6(b)(8) of the OSH Act requires
OSHA to publish a statement of reasons
in the Federal Register explaining why
the final rule will better effectuate the
purposes of the Act than the national
consensus standard. This final rule
contains requirements for minimum
approach distances that differ
substantially from those in the 2012
NESC, which the Agency determined is
the current, relevant national consensus
standard.
Paragraph (g) of § 1910.2 defines
‘‘national consensus standard’’. There
are currently two existing consensus
standards addressing minimum
approach distances for electric power
generation, transmission, and
distribution work: ANSI/IEEE C2–2012
and IEEE Std 516–2009. The 2012
NESC, which also is an IEEE standard,
was approved as an ANSI standard on
June 3, 2011.244 IEEE Std 516–2009 is
not currently an ANSI standard,
although the 2003 edition was an ANSI
standard.245 Many States adopt the
NESC (Tr2. 151).246 Mr. Charles Kelly of
EEI called the NESC ‘‘the preeminent
National Consensus Standard on
clearance distances for electric utility
work on high voltage lines and
equipment’’ (Tr2. 73). Mr. James
Tomaseski, testifying on behalf of the
NESC, called that document ‘‘the
authority on safety requirements for
power . . . systems’’ (Tr2. 35). In
contrast, rulemaking participants
characterized IEEE Std 516 as ‘‘an
engineering document’’ containing
engineering principles and guidelines
244 IEEE is the secretariat of the National
Electrical Safety Code, which IEEE adopted and
which ANSI approved subsequently as a standard.
The official designation of the current version of the
National Electrical Safety Code is ANSI/IEEE C2–
2012. Standards approved as ANSI standards are
American National Standards. In addition, the
ANSI approval process ensures that procedures
used to adopt standards conform to the procedures
described in the definition of ‘‘national consensus
standard’’ in 29 CFR 1910.2(g). See, for example,
OSHA’s adoption of national consensus standards
and established Federal standards under Section
6(a) of the OSH Act (36 FR 10466, May 29, 1971).
245 IEEE standards frequently undergo the ANSI
approval process. After becoming an approved
American National Standard, an IEEE standard
shares a joint ANSI/IEEE designation.
246 According to a survey conducted by IEEE, over
20 States adopted the 2007 edition of the NESC, and
several other States adopted other editions of the
NESC (https://standards.ieee.org/about/nesc/
pucsurvey2007.pdf). The States generally enforce
public safety provisions of the NESC through public
utility commissions. OSHA is not aware of any
States that adopted the updated consensus standard
since its most recent publication. OSHA anticipates
that States will adopt this edition of the NESC when
they update their regulations.
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(Tr2. 56; see also, for example, Tr2. 59,
74, 129–130, 174). However, the NESC
takes those engineering principles and
produces work rules, taking into
account the practical effects of the
requirements. (See, for example, Tr2. 57,
73, 175–176.) OSHA, therefore,
concludes that the 2012 NESC is the
existing national consensus standard for
the purposes of Section 6(b)(8).
The 2012 NESC sets its basic ac
minimum approach distances in Table
441–1. This table divides minimum
approach distances into two sets of
distances: one for voltages up to 72.5
kilovolts and the other for voltages of
72.6 to 800 kilovolts. The minimum
approach distances applying to voltages
of 72.5 kilovolts and less are the same
for work with and without tools
between the employee and the
energized part. The minimum approach
distances applying to voltages of 72.6 to
800 kilovolts vary depending on
whether a tool spans the distance
between the employee and the
energized part. The distances in Table
441–1 are identical to the minimum
approach distances in IEEE Std 516–
2009 for industry-accepted values of
maximum transient overvoltage, and the
NESC limits the application of Table
441–1 to situations in which IEEE Std
516–2009 declares that industryaccepted values of maximum transient
overvoltage are valid, as described
earlier in this section of the preamble.
Table 441–1 in the 2012 NESC does
not specify distances for phase-to-phase
exposures with tools or large conductive
objects between the employee and the
energized part. In addition, the table
applies only to worksites at an elevation
below 900 meters (3,000 feet). For
higher elevations, the 2012 NESC
requires the employer to calculate
minimum approach distances using a
formula equivalent to that in IEEE Std
516–2009.
The 2012 NESC requires the employer
to make an engineering analysis to
determine the minimum approach
distance in two situations: (1) If the
employer uses phase-to-phase live line
tools between the employee and the
energized part (Table 441–1, Note 8),
and (2) if the employer chooses to use
an engineering analysis in lieu of using
Table 441–1 (Rule 441A1). A note in the
2012 NESC reads: ‘‘IEEE Std 516–2009
contains information that may be used
to perform an engineering analysis to
determine minimum approach
distances.’’
The 2012 NESC bases its minimum
approach distances on IEEE Std 516–
2009; and, as explained previously, the
Agency concluded that the minimum
approach distances in IEEE Std 516–
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2009 expose employees to additional
risk of injury for various exposures. The
IEEE standard sets minimum approach
distances for exposures at voltages of
72.5 kilovolts and less that do not take
account of tools or conductive objects in
the air gap. Consequently, OSHA
determined that, for these voltages, the
IEEE method for calculating minimum
approach distances, on which the 2012
NESC bases its minimum approach
distances, does not protect employees as
well as the method for calculating
minimum approach distances specified
in the final rule. The final rule ensures
adequate employee protection, even
when tools or conductive objects are
present in the air gap. In addition, for
phase-to-phase exposures at voltages of
more than 72.5 kilovolts, the Agency
found that the method for calculating
minimum approach distances in IEEE
Std 516–2009, on which the 2012 NESC
bases its minimum approach distances,
does not use gap factors that adequately
represent the full range of employee
exposures. Furthermore, the 2012 NESC
permits employers to use the industryaccepted values for the maximum perunit transient overvoltage without
ensuring that the maximum transient
overvoltages at the worksite cannot
exceed those values. Although the 2012
NESC limits the use of the industryaccepted values in some situations, the
limitation does not appear to apply to
circuits such as the BPA circuit that
exhibited higher maximum per-unit
transient overvoltages. Thus, OSHA
concludes that the 2012 NESC is not as
effective as the final rule in protecting
employees against high maximum
transient overvoltages. Because the
minimum approach distances contained
in the final rule will better protect
employees than the distances specified
in the NESC, the Agency also concludes
that the final rule will better effectuate
the purposes of the OSH Act than the
NESC. Therefore, the Agency concludes
that the minimum approach distances
required by the final rule, which
account for actual workplace
conditions, will better protect
employees than the IEEE distances for
these exposures.
Impacts of changes in minimum approach
distances. The final rule at § 1926.950(d)(2),
as well as § 1926.960(c)(1)(ii) and Table V–
2, requires employers to determine the
maximum per-unit transient overvoltage for
the systems on which employees will be
working. Existing § 1910.269(a)(3) already
contains a comparable provision, requiring
employers to determine existing conditions
related to the safety of the work to be
performed, including maximum switching
transient voltages.
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The maximum per-unit transient
overvoltages addressed by the existing
standard are the industry-accepted
values of 3.0 for voltages up to 362
kilovolts, 2.4 for 552 kilovolts, and 2.0
for 800 kilovolts. OSHA believes that,
under the existing rule, most employers
simply assume these maximum per-unit
transient overvoltages and set minimum
approach distances accordingly. As
explained earlier, this final rule raises
the highest maximum transient
overvoltages to 3.5 for up to 420
kilovolts, 3.0 for 550 kilovolts, and 2.5
for 800 kilovolts. OSHA believes that
some systems will accommodate the
larger minimum approach distances that
will result from using these new, default
values. Not all systems will
accommodate such changes, however.
(See, for example, Exs. 0573.1, 0575.1,
0577.1.) For phase-to-ground exposures,
the minimum approach distance could
be as much as 2.35 meters (7.67 feet)
greater under the final rule than under
Table R–6 in existing § 1910.269. The
existing minimum approach distance is
4.53 meters (14.9 feet) for phase-toground exposures on an 800-kilovolt
system. The final rule sets 6.88 meters
(22.57 feet) as the largest minimum
approach distance for this voltage. (This
increase is due to the use of minimum
tool distances, as well as the higher
default maximum per-unit transient
overvoltage.) Consequently, OSHA
believes that employers with
installations that will not accommodate
these larger minimum approach
distances will either determine through
engineering analysis or establish
through the use of portable protective
gaps 247 precise maximum per-unit
transient overvoltages on these
installations so that the installations
will accommodate the required
minimum approach distances.
For the systems that exhibit transient
overvoltages that will not accommodate
the resultant minimum approach
distances, OSHA concludes that it is
feasible for employers to either control
the maximum transient overvoltages,
through the implementation of such
measures as portable protective gaps,
circuit alterations, or operational
controls (including blocking reclosing
and restricting circuit switching), or
deenergize the circuit to perform the
work. (See, for example, Exs. 0532,
0548.1; Tr2. 114–115.)
247 A portable protective gap is a device installed
on a phase conductor to provide a known withstand
voltage. The gap is designed to spark over at a low
enough transient overvoltage to prevent sparkover
at the (reduced) electrical component of the
minimum approach distance at the work location
(Ex. 0532).
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The final economic analysis, in
Section VI, Final Economic Analysis
and Regulatory Flexibility Analysis,
later in this preamble, assumes that
electric utilities with circuits operating
at 230 kilovolts or more (including all
circuits in the 169.1- to 242.0-kilovolt
voltage range 248) will be affected by
increases in minimum approach
distances at those voltages. Therefore,
the Agency estimates that 10 percent of
the circuits operating at 230 kilovolts or
more will require additional measures,
such as installing portable protective
gaps, that permit employers to adopt
minimum approach distances that their
circuits can accommodate.249 However,
OSHA is not including any costs for
retrofitting or redesigning circuits or
equipment for this purpose. The Agency
believes that such measures will be rare
and undertaken only when they are less
costly than the alternatives or when
necessitated for reasons unrelated to
requirements in the final rule. OSHA
did not include cost estimates for taking
outages because the Agency concludes
that only rarely will other, less costly,
measures be impractical.
Several rulemaking participants
maintained that adopting minimum
approach distances greater than the
distances in existing § 1910.269 would
have a substantial effect on how
employees perform energized line work
and possibly on whether they could
perform it at all. (See, for example, Exs.
0545.1, 0549.1, 0550.1, 0573.1, 0575.1;
Tr2. 53–55, 96–98.) Some of these
comments related to climbing
structures, with the commenters
claiming that employees would be
precluded from climbing some
structures if the final rule substantially
increased minimum approach distances.
(See, for example, Exs. 0549.1, 0573.1;
Tr2. 54–55, 166.) For instance,
Consolidated Edison reported that larger
minimum approach distances could
248 As seen from Table R–6 in existing § 1910.269
and Table V–1 in existing § 1926.950, existing
electric power circuits operate at 161 to 169
kilovolts and at 230 to 242 kilovolts. OSHA
broadened the ranges in the corresponding tables in
the final rule in the unlikely event that electric
utilities design and install circuits operating at
voltage between the listed voltage ranges.
249 The final economic analysis estimates that 10
percent of the ‘‘projects’’ (as that term is used in
Section VI, Final Economic Analysis and
Regulatory Flexibility Analysis, later in this
preamble) performed by employers with circuits
operating at 230 kilovolts or more will involve
installing portable protective gaps based on the
assumption that projects are distributed
proportionately across affected and unaffected
circuits. Consequently, if 10 percent of the circuits
operating at voltages of 230 kilovolts or more
require ‘‘additional measures, such as installing
portable protective gaps,’’ then 10 percent of the
projects on those circuits will require such
measures.
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prevent workers from climbing towers
on several of its lines and noted that
clearances vary from tower to tower (Ex.
0549.1). Consolidated Edison also
maintained that larger minimum
approach distances might prohibit it
from positioning an employee on the
tower with a live-line tool to perform
tasks such as installing cotter keys or
removing debris (id.). EEI argued that, if
minimum approach distances exceeded
the length of line insulators, employees
would not be permitted to use existing
live-line maintenance equipment
without changing their work methods
(Ex. 0545.1; Tr2. 114–115). EEI and
Consolidated Edison, among others,
maintained that larger minimum
approach distances could increase the
number of outages. (See, for example,
Exs. 0545.1, 0549.1.)
For each of the examples the
commenters provided of situations in
which higher minimum approach
distances might be problematic, the
worker would be at ground potential
while located on a tower or other
structure. Thus, these comments relate
solely to phase-to-ground exposures. For
these exposures, the final rule increases
minimum approach distances
substantially under two conditions: (1)
When the maximum per-unit transient
overvoltage exceeds the default
maximums under the existing
standards,250 or (2) when insulating
tools or conductive objects are present
in the air gap. In each case, the
employer can implement measures,
such as using a portable protective gap,
to reduce the maximum per-unit
transient overvoltage and, consequently,
the minimum approach distance. (See
Appendix B to final Subpart V for a
discussion of the use of a portable
protective gap to reduce the required
minimum approach distance. Appendix
B to existing § 1910.269 recognizes this
method of reducing the required
minimum approach distance.) In
addition, when the employer can
demonstrate that there will be only air
between the employee and the
energized part, which should normally
be the case during climbing or
inspection procedures, Table V–2
permits the employer to determine
minimum approach distances using the
equation based on minimum airinsulation distances, which will
produce smaller minimum approach
distances than the equation based on
minimum tool-insulation distance.
250 The maximum per-unit transient overvoltages
under existing § 1910.269 are 3.0 for voltages up to
362 kilovolts, 2.4 for 552 kilovolts, and 2.0 for 800
kilovolts.
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20449
Some rulemaking participants
maintained that revised minimum
approach distances would result in
costs related to the purchase of new
tools, revision of training programs, and
retraining of employees. (See, for
example, Exs. 0545.1, 0548.1, 0550.1,
0551.1; Tr2. 94–95.) For instance,
American Electric Power commented:
The potential [cost impact] could be
significant, especially when considering the
proposed changes and resulting implications
on the design standards. It is sufficient to
state that changes in minimum approach
distances, that exceed the length of standard
line insulation, could require the re-tooling
of live line maintenance equipment (placing
some live line maintenance currently done
on hold until new tooling is available); the
development of new work methods and the
training/re-education that could be required;
and could impact current design standards
(that are relatively common across the
industry). In some cases, on [extra-highvoltage] lines, it is not possible to state that
new tooling and procedures can be
established until maintenance experts have
had adequate time to fully evaluate the
situation. [Ex. 0550.1]
OSHA included the costs of training
employees in the requirements of the
standard, including the minimum
approach-distance requirements, in the
economic analysis conducted for the
proposed rule. (See 70 FR 34905–
34910.) The proposal included revised
minimum approach distances that were
in some cases greater than the distances
specified in existing § 1910.269. OSHA’s
estimates for the proposed rule already
accounted for the costs associated with
training employees in the revised
minimum approach distances, including
any necessary changes in procedures.
Therefore, the Agency concludes that it
is not necessary to increase those cost
estimates as a result of the changes
made to the minimum approachdistance provisions between the
proposed and final rules.251
Table 9 shows the differences
between the default minimum approach
distances in existing § 1910.269 and the
final rule for phase-to-ground and
phase-to-phase exposures on circuits
operating between 72.6 kilovolts and
169.0 kilovolts. This table compares the
minimum approach distances in Table
R–6 in existing § 1910.269 with the
largest minimum approach distances in
Table 7 through Table 9 in Appendix B
to final Subpart V. The distances in the
tables in the appendix assume that an
insulated tool spans the gap (or that a
251 OSHA addressed the cost of retrofitting or
redesigning circuits or equipment earlier in this
discussion. OSHA’s conclusion regarding these
costs apply equally to American Electric Power’s
comment regarding the need to purchase new liveline maintenance equipment.
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large conductive object is in the gap) for
phase-to-ground exposures.
TABLE 9—INCREASES IN MINIMUM APPROACH DISTANCES FOR PHASE-TO-GROUND EXPOSURES FROM EXISTING
§ 1910.269 TO FINAL SUBPART V
Phase-to-ground
increase
m (ft)
Voltage
kV
72.6 to 121.0 ............................................................................................................................................
121.1 to 145.0 ..........................................................................................................................................
145.1 to 169.0 ..........................................................................................................................................
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For these voltage ranges, the
maximum difference is no more than
0.24 meters (9 inches). As photographs
of live-line tool work in the record
show, at these voltages, employers can
comply with the minimum approach
distances specified in the final rule by
having employees make small
adjustments in their working positions
(269-Ex. 8–5). For example, employees
using live-line tools can take a position
slightly lower on the pole or structure
and maintain the revised minimum
approach distances. (As noted
previously, when employees work
where the employer can demonstrate
that no insulated tool spans the gap and
that no large conductive object is in the
gap, such as during climbing or
inspection activities, the final rule sets
minimum approach distances for phaseto-ground exposures that are
substantially smaller than the minimum
approach distances for working with
tools; and the maximum difference
between the existing and the new
minimum approach distance is no more
than 0.14 meters (5.5 inches).
Information in the record indicates that,
as long as OSHA does not apply
minimum approach distances to
climbing and similar activities based on
tools in the gap, employers should be
able to comply with the minimum
approach distances required by the final
rule for those activities without
adopting additional measures (Ex.
0575.1252).) Because employers
252 In this exhibit, EEI described how applying
‘‘MAD for tools’’ to climbing and inspection
activities would make some of this work infeasible.
According to EEI, up to 23 percent of line insulators
at transmission voltages are shorter than minimum
approach distances based on tools in the gap. As
explained previously in this section of the
preamble, when the employer can demonstrate that
there will be only air between the employee and the
energized part, which normally should be the case
during climbing or inspection procedures, Table V–
2 permits the employer to determine minimum
approach distances using the equation based on
minimum air-insulation distances, which will
produce smaller minimum approach distances than
the equation based on minimum tool-insulation
distance. Therefore, OSHA concludes, the
percentage of structures that workers could not
climb or inspect without violating the default
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generally should be able to demonstrate
that no insulated tool spans the gap and
that no large conductive object is in the
gap during climbing and inspection
activities and because the increases in
minimum approach distances for
voltages of 72.6 to 169.0 kilovolts are
small, OSHA believes that, with regard
to circuits operating at those voltages,
employers will not incur significant
costs beyond costs associated with
retraining employees, which OSHA
included in its economic analysis.
Explanation of the final minimum
approach-distance requirements. As
noted earlier in this section of the
preamble, final § 1926.960(c)(1)
specifies minimum approach distances.
The proposed rule would have required
the employer to ensure that no
employee approached or took any
conductive object closer to exposed
energized parts than the minimum
approach distances in proposed Tables
V–2 through V–6. The final rule splits
this requirement into two provisions.
First, as noted previously, paragraph
(c)(1)(i) requires employers to establish
minimum approach distances no less
than the distances computed by Table
V–2 for ac systems or Table V–7 for dc
systems; OSHA described and explained
earlier in this section of the preamble
the equations in Table V–2 of the final
rule. Second, paragraph (c)(1)(iii) of the
final rule requires the employer to
ensure that no employee approaches, or
takes any conductive object, closer to
exposed energized parts than the
employer’s established minimum
approach distances, unless the
employee works in accordance with
paragraphs (c)(1)(iii)(A), (c)(1)(iii)(B), or
(c)(1)(iii)(C). (See the discussion of these
alternative methods later in this section
of the preamble.)
Paragraph (c)(1)(iii) in the final rule is
equivalent to proposed paragraph (c)(1),
minimum approach distances in the final rule is
significantly smaller than 23 percent for voltages up
to 169.0 kilovolts and that, up to this voltage level,
any costs related to complying with the final rule’s
minimum approach distances applicable to
climbing or inspecting a structure (such as
performing an engineering analysis) are negligible.
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0.18 (0.59)
0.21 (0.69)
0.24 (0.79)
Phase-to-phase
increase
m (ft)
0.13 (0.43)
0.14 (0.46)
0.23 (0.75)
except that it is the employer that is
establishing the specific minimum
approach distances for the workplace,
based on equations in the standard,
rather than the standard setting those
distances explicitly.
The proposed rule would have
allowed employees to approach
energized parts closer than the
minimum approach distance under
certain conditions (see proposed
§ 1926.960(c)(1)(i) through (c)(1)(iii)).
Existing § 1926.950(c)(1)(i), which is
similar to proposed § 1926.960(c)(1)(i),
permits the employee to be insulated or
guarded from the live parts. OSHA
omitted from the proposal language in
the existing standard specifically
recognizing guarding. However, the
language proposed in paragraph (c)(1)
required employees to maintain
minimum approach distances from
‘‘exposed’’ energized parts. OSHA
defines ‘‘exposed’’ in final § 1926.968 as
‘‘[n]ot isolated or guarded’’; therefore,
the minimum approach-distance
requirement does not cover guarded live
parts, whether guarded by enclosures or
barriers or guarded by position
(isolated), because they are not
‘‘exposed.’’ OSHA removed similar
redundancies throughout proposed
paragraphs (c)(1)(i) through (c)(1)(iii).
Farmers Rural Electric Cooperative
Corporation (FRECC) urged OSHA to
retain the language that explicitly
recognizes that employees do not have
to maintain minimum approach
distances from guarded or isolated
energized parts (Ex. 0173).
Including language exempting
guarded or isolated live parts would be
redundant and could lead to
misinterpretation of the rule by
implying that ‘‘exposed energized parts’’
has a meaning other than not guarded or
isolated. Consequently, OSHA did not
change the relevant language in this
final rule in response to FRECC’s
comment, and the final rule removes the
redundancies as proposed.
OSHA proposed a note to paragraph
(c)(1) reading as follows:
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Paragraph (f)(1) of § 1926.966 contains
requirements for the guarding and isolation
of live parts. Parts of electric circuits that
meet these two provisions are not considered
as ‘‘exposed’’ unless a guard is removed or
an employee enters the space intended to
provide isolation from the live parts.
Final § 1926.966(f)(1) requires the
employer to provide guards around all
live parts operating at more than 150
volts to ground without an insulating
covering unless the location of the live
parts gives sufficient clearance
(horizontal, vertical, or both) to
minimize the possibility of accidental
employee contact. This provision,
which applies to substations, requires
guards or isolation for all live parts
operating at more than 150 volts to
ground unless the live parts have an
insulating covering. As explained
previously, ‘‘exposed’’ means ‘‘[n]ot
isolated or guarded,’’ and live parts that
are insulated, but not guarded or
isolated, are exposed. Thus, live parts
operating at more than 150 volts with an
insulating covering meet final
§ 1926.966(f)(1), but are still exposed.
Therefore, the proposed note to
§ 1926.960(c)(1) inaccurately portrays
insulated parts as not exposed, and
OSHA did not include the note in the
final rule.
Proposed paragraph (c)(1)(i) contained
the first exception to maintaining the
minimum approach distances—
insulating the employee from the
energized part. This insulation, for
example, can take the form of rubber
insulating gloves and rubber insulating
sleeves. This equipment protects
employees from electric shock while
they work on energized lines or
equipment. Even though uninsulated
parts of an employee’s body may come
closer to the live part being worked on