Standard Interpretations - Table of Contents
• Standard Number: 1910.269(p)(4)

December 21, 1998

Mr. Dimitrios S. Mihou, CSP
OSHA Regulatory Compliance /
Accident Prevention Specialist
Niagara Mohawk
300 Erie Boulevard West
Syracuse, NY 13202-4250

Dear Mr. Mihou:

This is a follow-up response to our interim letter of October 29, regarding your request for a clarification of the Occupational Safety and Health Administration's (OSHA's) standard, 29 CFR 1910.269, as it applies to aerial lift devices (e.g., bucket trucks).

In your letter, you indicated that the typical insulated aerial bucket trucks used by the industry are designed according to ANSI/SIA A92.2, which requires an insulated upper boom and a lower boom insert to isolate the chassis from the elevating boom section. Please find below, your specific questions and our responses.

Q1:

Does this section of the standard (§1910.269(p)(4)) apply to typical insulated aerial bucket trucks used by the industry when used in an energized area.

R1:

This section applies to insulated as well as uninsulated aerial lifts, as §1910.269(p)(4) indicates that the insulated portion of an aerial lift operated by a qualified employee in the lift is exempt from the referenced Tables' (R6-R10) requirements specifying the minimum approach distances. The bucket trucks that are not insulated must comply with the requirements of the minimum approach distance Tables that are referenced in this section. Those lifts that have insulated portions (i.e., insulated upper boom), but could become energized, must comply with 1910.269(p)(4)(ii) and the pertinent sections that are referenced under this provision.

Q2:

The chassis of insulated aerial bucket trucks may become accidentally energized when a conductor or other equipment have fallen or comes into contact with the lower section of the vehicle. Do the requirements of (p)(4)(iii)(A) through (p)(4)(iii)(C) apply to the lower section of the chassis for the occas