September 16, 2003

Mr. Albert Yevchak
901 Alhambra Rd.
Cleveland, Ohio 44110

Dear Mr. Yevchak:

Thank you for your May 7 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding electric power work conducted from bucket trucks. Your inquiry and our response follow.

Question: What are the laws or rules regarding an electrician, lineman, etc. using a bucket truck? Should he have a groundman in case of an emergency?

Response: OSHA Standard 29 CFR 1910.269 covers the operation of and maintenance work on electric power generation, transmission, and distribution lines and equipment, including such work performed in aerial lifts. See, for example, paragraphs: (g) Personal protective equipment; (k) Material handling and storage; (l) Working on or near exposed energized parts; and (p) Mechanical equipment. The electrical safety work practices contained in Section 1910.269 apply only to qualified employees (and, to a limited extent, line-clearance tree trimmers).¹ We assume that your question concerns work covered by 1910.269.

Paragraph 1910.269(l)(1)(i) requires that at least two employees be present during:

(A) Installation, removal, or repair of lines energized at more than 600 volts;
(B) Installation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts;
(C) 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;
(D) Work using mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts; and
(E) Other work exposing an employee to electrical hazards greater than or equal to those posed by operations that are specifically listed above.

However, paragraph 1910.269(l)(1)(ii) provides three exemptions to the above:

(A) Routine circuit switching, if the employer can demonstrate that conditions at the site allow the work to be performed safely;
(B) Work performed with live-line tools if the employee is neither within reach of nor otherwise exposed to contact with energized parts; and
(C) Emergency repairs to the extent necessary to safeguard the general public.

If the work does not fall under the activities listed in paragraph 1910.269(l)(1)(i) or if the work falls under that paragraph but is one of the exempted activities listed in paragraph 1910.269(l)(1)(ii), then there is no OSHA requirement to have two employees present. For work practices that require at least two employees, the standard does not specify where the second employee must be located during the performance of the work. OSHA intends, however, for the second employee to be immediately available in the event of an accident and to point out poor work practices on the part of his/her fellow employee.

Additionally, if two or more employees are present at a field location, then 29 CFR 1910.269(b)(1)(i) requires that at least two persons trained in cardiopulmonary resuscitation (CPR) be available. The exception to this is that if all new employees are trained in first aid, including CPR, within three months of their hiring dates then only one trained person need be available.

Thank you for your interest in occupational safety and health. We have enclosed the appropriate portions of the OSHA standard for your reference. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. 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

¹ OSHA standards covering electrical utilization systems and safety-related work practices used by unqualified employees are located in 29 CFR Part 1910, Subpart S.  Construction work performed on electric power transmission and distribution lines and equipment is covered by 29 CFR Part 1926, Subpart V. [back to text]