October 5, 2004

Mr. Henry L. Dean
Method/Training Department
ComEd
1919 Swift Road
Oakbrook, IL 60523

Dear Mr. Dean:

Thank you for your May 12, 2003 letter to the Occupational Safety and Health Administration (OSHA) regarding grounding requirements for aerial lifts (bucket trucks) under 29 CFR 1910.269(n)(6) and (n)(7), and 29 CFR 1926.952(b)(2). 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. We apologize for the delay in our response.

Your scenario, paraphrased question, and our response are provided below:

Scenario: We are grounding an aerial lift (bucket truck) for protection of workers on the ground. The lift is considered a mechanical device; it is not a piece of energized equipment. We are grounding the aerial lift either to screw anchors driven into the ground or to a system neutral cable.

Question: What are the OSHA requirements for attaching the grounding devices in the scenario described above? Specifically, do you use hot sticks, rubber gloves, or a combination of live-line tools and gloves to attach the grounding devices?

Reply: Our response addresses the OSHA standards referenced in your letter -- 29 CFR 1910.269, as well as 29 CFR Part 1926, Subpart V. As you may know, OSHA's general industry standard at 29 CFR 1910.269 applies to the maintenance of electric power generation, transmission, and distributioninstallations, while OSHA's construction standards in Part 1926, Subpart V apply to the construction of electric transmission and distribution lines and equipment.

You described two methods for grounding an aerial lift: 1) grounding to a screw anchor driven into the ground, and 2) grounding to a neutral cable on your system. Neither OSHA's general industry standards nor OSHA's construction standards require the use of electrical protective equipment or a live-line tool when grounding mechanical equipment, unless an employee is going to approach or take a conductive object closer to an energized part than the minimum approach distance established in the standards, see 29 CFR 1910.269(l)(2) and 1926.950(c).

Thus, if you can accomplish either of the grounding methods without violating the relevant minimum approach distance, it isnot necessary to use electrical protective equipment or a live-line tool when grounding the aerial lift. On the other hand, if it is not possible to attach the grounding device without violating the relevant minimum approach distance, any of the protective measures outlined in 29 CFR 1910.269(l)(2) or 1926.950(c), as applicable, are permitted, including rubber insulating gloves or suitable live-line tools. Neither 29 CFR 1910.269(n)(6) and 1910.269(n)(7), nor the corresponding constructionprovision -- 29 CFR 1926.954(e)(1) and 1926.954(e)(2), apply to aerial lifts.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretationletters 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