OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 3, 1999

[Name Withheld]

Dear [Name Withheld]:

Thank you for your June 16, 1999 letter to the Occupational Safety and Health Administration (OSHA). You asked questions regarding the appropriate safety practices for the removal of electrical meters. Your scenario, corresponding questions, and our reply follow.

Scenario: Utility workers have historically replaced energized electrical meters by first removing the meters and installing anti-tamper shields where the meter mounting devices are located. The installations are then locked and sealed in place with numbered locking seals. However, a new practice has been implemented which allows utility workers to cut energized service wires (600 volts or less) at the service head (near the meter mounting). These service wires are then wrapped with electrical tape and left hanging in the air 10 to 20 feet off the ground. This procedure exposes workers to energized wiring and the general public to easy/unauthorized access by simply removing the tape. Once the tape is removed, the service wire is exposed, posing a very serious hazard of electrical shock.

Question #1: Is there a federal regulation that prohibits this practice of cutting these energized service lines?

Reply: No, provided this work is performed in accordance with the requirements governing minimum approach distances, as specified in the OSHA electrical power generation, transmission, and distribution standard 29 CFR 1910.269 subsection (l)(2). Basically, employees are required to maintain the minimum approach distances listed in the standard, unless they are insulated from the live part or the part is insulated from all other conductive objects. This insulation can take the form of rubber insulating gloves and rubber insulating sleeves as specified in 1910.269(l)(3). However, rubber insulating gloves and sleeves must meet the design and in-service care and use requirements for electrical protective equipment set forth under 1910.137.

Question #2: After cutting, do federal standards allow service cables to be wrapped in electrical tape and left 10 to 20 feet above the ground?

Reply: The 1910.269 standard does not contain installation requirements for your described situation, however the employer does have a responsibility, under the general duty provisions of the Act, to furnish to each of his or her employees a place of employment which is free from recognized hazards that are likely to cause death or serious physical harm. The eighth edition of the National Electrical Code (NFPA 70-1999) contains good recognized practices for the guarding of live parts.

In terms of your specific situation, Article 110-27 of the Code permits live parts to be guarded against accidental contact by elevation of 8 feet or more above the floor or other working surface. The key safety point is that electrical tape is considered a covering and not an insulation, and as such, guarding by location is essential. If the prescribed minimum height requirements are maintained, and adequate protection from electrical shock is provided for the employee, then the practices are in compliance with OSHA requirements. While the concerns you raise regarding the safety of the general public are extremely important when dealing with electricity, they do not fall within OSHA¿s purview.

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

Sincerely,



Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 12/01/2005]