October 19, 2006

Mr. Michael Ziobro
Sr. Safety & Industrial Hygiene Specialist
PPL Services-Safety Operations
600 Larch Street
Scranton, PA 18509

Dear Mr. Ziobro:

Thank your for your December 22, 2005 letter to the Occupational Safety and Health Administration's (OSHA's) Philadelphia Regional Office, regarding clarification of requirements under 29 CFR 1910.269(l)(1)(i) and 1910.269(l)(1)(ii). Your letter was forwarded to OSHA's Directorate of Enforcement Programs of the National Office for a response. 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 background information, paraphrased scenarios, paraphrased question, and our response are provided below.

Background Information: PPL Electric Utilities employees perform various tasks on single-phase dead front pad-mounted transformers for underground electrical distribution systems, using one qualified electrical employee. Questions have been raised whether the use of only one employee complies with the OSHA standards at 29 CFR 1910.269(l)(1)(i) and 1910.269(l)(1)(ii). The following scenarios are provided as examples of tasks being performed.

Scenario one: A single qualified employee is to install faulted circuit indicators on conductors inside a single-phase dead front pad-mounted transformer to investigate a fault. The employee is wearing personal protective equipment (PPE)¹ (including but not limited to flame-resistant clothing and eye protection equipment) appropriate for the hazard, while working in the proximity of conductors. The faulted circuit indicator is slipped around the conductor using a live-line tool (shotgun stick) that places the employee a safe distance from the conductors being worked on, inside the pad-mounted transformer enclosure² .

Scenario two: A single qualified employee is to move conductors inside a single-phase dead front pad-mounted transformer after locating a fault. The move is performed using a live-line tool (shotgun stick) that places the employee a safe distance from the conductors being manipulated inside the pad-mounted transformer enclosure. The employee is wearing personal protective equipment as in scenario one.

Note: In these two scenarios the primary supply tap fuse for the transformer is open.³ The primary conductor for the tap would normally supply 7.2 kilovolts to the transformer. Secondary conductors found inside the transformer normally carry 600 volts or less.

Scenario three: A single qualified electrical employee is to attach a clip device to the primary neutral bus or ground inside a single-phase dead front pad-mounted transformer. This is done to support the locating of underground electrical conductors. The clip is attached using a live-line tool (shotgun stick) that places the employee a safe distance from the conductors being worked on inside of the pad-mounted transformer enclosure. The employee is wearing personal protective equipment as noted in the previous scenarios.

Note: For this scenario, the primary supply tap fuse for the transformer is closed; thus the transformer is energized.

Question: May the tasks described in the above scenarios be performed by one qualified employee?

Response: The OSHA standard at 29 CFR 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 involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts, and
(E) Other work that exposes an employee to electrical hazards greater than or equal to those posed by operations that are specifically listed in paragraphs (l)(1)(i)(A) through (l)(1)(i)(D) of this section.

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

(A) Routine switching of circuits, if the employer can demonstrate that conditions at the site allow this work to be performed safely,
(B) Work performed 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, and
(C) Emergency repairs to the extent necessary to safeguard the general public.

You stated in your letter that in all the three scenarios that the procedures require using a live-line tool (e.g., a shotgun stick) that places the employee a safe distance from conductors inside the pad-mounted transformer enclosure. Additionally, our response assumes that the live-line tool is fully rated for the application and meets 1910.269(j). In such scenarios, where work is performed with live-line tools (e.g., a shotgun stick), and the employee is neither within reach of nor otherwise exposed to contact with energized parts, then there is no OSHA requirement to have two employees present. However, in the above scenarios, if an employee is wearing appropriate PPE as required by 1910.269(l)(2) and 1910.269(l)(3), but does not use a live-line tool (e.g., a shotgun stick), then it is likely that the employee is exposed to contact with parts within the transformer energized at more than 600 volts, and therefore, in accordance with 1910.269(l)(1)(i), at least two employees must be present while such work is being performed.

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 interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employee 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 Please note that OSHA has electrical PPE requirements in §1910.137. [ back to text ]

² It is important to note that OSHA does not confirm, approve, or endorse equipment design, procedures or safety practices; rather the Agency provides guidance to employers on how they may comply with the applicable OSHA standards. [ back to text ]

³ Although your letter states that the primary supply tap fuse is open, you have given no indication that the primary was deenergized following the provisions of §1910.269(m) and grounded as required by §1910.269(n). Therefore, under §1910.269(m)(1), the primary conductor must be treated as energized. [ back to text ]