Pole-top rescue training and protective apparel

December 7, 1995

Mr. David L. White
Business Representative
IBEW-Local Union No. Two
[Recipient address omitted]
Dear Mr. White:

This is in response to your December 9, 1994 letter and your April 12 follow-up letter requesting interpretation of the electric power generation, transmission, and distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding. Your questions and our replies follow.

Question 1: On a two-man utility crew, do both employees have to be trained and be able to perform pole top rescue from a pole? If so, would each have to be able to perform pole top rescue by climbing the pole with the appropriate climbing gear?

Reply: Both employees must be trained and must demonstrate proficiency in pole top rescue procedures such that one employee may rescue the other. This is required under paragraph 1910.269(a)(2). When one or the employees does not climb poles in the routine performance of his or her job, he or she must be trained and must demonstrate proficiency in pole top rescue procedures such that he or she can effect the rescue of the other employee working on the pole when the need arises. Of particular concern is when company procedures call for administering CPR using defibrillation equipment on the victim while still on the pole. This clarification is consistent with paragraph 1910.269(a)(2) in that employees must be trained and familiar with safety-related work practices and safety procedures pertaining to their respective job assignments.

What pole top rescue procedures must be used is not specified under the performance-oriented requirements of 1910.269. Whether each employee would have to be able to perform pole top rescue by climbing the pole with appropriate equipment depends upon whether climbing the pole is the only way to effect rescue, in which case proficiency climbing with the appropriate equipment would be required. The rescuing employee may use a body belt, safety strap and climbers to climb the pole or may use other means, for example, an aerial lift, which is effective to reach the employee in need of rescue.

Question 2: Is "pole top rescue qualified" a requirement only when working from a pole on or nearby exposed energized parts, or is it required while performing any work from a pole such as de-energized maintenance, construction, routine operation, etc.? (My concerns are in reference to a man performing physical non-energized work form a pole or bucket and being injured by some mechanical force or possibly being incapacitated by a physical condition such as a heart attack, etc.)

Reply: For a two-person crew, goth employees must be trained and must demonstrate proficiency in pole top rescue, including getting to the injured employee, not only when a qualified employee (as defined in paragraph 1910.269(x)) is required to climb a pole to perform work on or nearby exposed energized electrical parts as required by paragraph 1910.269(l), but also when a pole is climbed to perform non-energized work which may require rescue.

Question 3: Are short sleeve shirts in violation of the paragraph 1910.269(l)(6)(iii) Apparel requirements?

Reply: The answer to your question is "no." However, when the hazard assessment under paragraph 1910.132(d)(1) indicates that the use of long sleeves or full length trousers is required to provide personal protection, wearing short sleeves or less than full length trousers would be in violation of paragraph 1910.132(d)(1)(i).
Occupational Safety and Health Administration's policy is clarified in the enclosed August 10, 1995 memorandum to OSHA Regional Administrators.
This memorandum provides guidelines for the enforcement of the aforementioned Apparel Standard.

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact the Office of General Industry Compliance Assistance, Mr. Ronald Davies, telephone (202) 219-8031, extension 110.

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

Enclosures

[Requester letter reproduced on OSHA page; omitted here.]