January-February 2026 Q&A
Q: We recently did some contract work in a manhole with live primary cables running through it. During an audit, the client’s safety team cited us for failure to have our manhole workers tied off to rescue lines. We had a tripod up and a winch ready for the three workers. What did we miss?
A: We have received similar questions over the years, usually due to a misunderstanding of OSHA’s enclosed spaces standard. Found at 29 CFR 1910.269(e) and printed below, the latest revision of the rules includes modified language. Look for the terms “safe work practices,” “enclosed space(s)” and “safe rescue” as you read them.
1910.269(e)(1): Safe work practices. The employer shall ensure the use of safe work practices for entry into, and work in, enclosed spaces and for rescue of employees from such spaces.
1910.269(e)(2): Training. Each employee who enters an enclosed space or who serves as an attendant shall be trained in the hazards of enclosed-space entry, in enclosed-space entry procedures, and in enclosed-space rescue procedures.
1910.269(e)(3): Rescue equipment. Employers shall provide equipment to ensure the prompt and safe rescue of employees from the enclosed space.
Again, these rules address enclosed spaces, not the spaces referenced in 1910.269(t), “Underground electrical installations.” Enclosed spaces are not – as many think – spaces with energized cables inside. OSHA’s definition of an enclosed space never mentions energized cables. What it does state is that an enclosed space, “under normal conditions, does not contain a hazardous atmosphere, but may contain such an atmosphere under abnormal conditions.”
Where energized cables are present in a manhole, burning insulation created by a cable failure is the most likely source of a hazardous atmosphere. The highly toxic smoke produced instantly incapacitates those exposed to it, making self-rescue unlikely.
An enclosed space classification only applies where no hazardous atmosphere exists. Permits are required for spaces in which such atmospheres develop. All activities in those spaces must comply with the permit-required rules found at 1910.146(d) through (k), which include rescue requirements for hazardous environments, i.e., either (1) being trained on and equipped with breathing and protective apparatus or (2) using non-entry rescue, which requires rescue lines attached to workers entering the space. This is the most likely reason the auditors cited you, and their interpretation of the OSHA standard was correct.
Q: We received new disconnects with through-the-cover voltmeters indicating the phase-voltage conditions behind the cover. Each meter is connected to the load side of the switch. Are these appropriate for lockout/tagout or as a way for electricians to check for voltage after turning off the disconnect prior to starting work?
A: If NFPA 70E compliance is the goal, the meters are inappropriate for electricians. The 70E standard requires verification of testing devices before and after testing for the absence of voltage, and you can’t do that with a permanently mounted meter. In addition, it is insufficient to check voltage at a disconnect if the work location is remote to that disconnect; voltage must be tested at the point of exposure. You can use a non-contact voltage detector if you have been properly trained in its use and make the before/after verifications. Unfortunately, close access to the energized part is still required to perform the check.
Lockout/tagout may be appropriate for non-electrical workers authorized to operate disconnects. Mechanics and maintenance personnel who do not perform electrical work have no obligation to perform an electrical check. Instead, they must perform a disconnect, lock out the disconnect and then try to start the motor from the controls. The meter may be one method of determining if the disconnect is open, but its use would not relieve the operator of trying the locked-out apparatus to ensure removal of the energy source. The downside is that three-phase and other multipole disconnects may not always open all poles. Depending on the panel meter’s connection, this could result in a false reading or a reading with no confidence, which is the whole purpose of NFPA 70E’s verify/test/reverify.
Q: We have a question after reading Jim Vaughn’s “Train the Trainer 101: Grounding Trucks and Mobile Equipment” (http://incident-prevention.com/ip-articles/train-the-trainer-101-grounding-trucks-and-mobile-equipment). Let’s say that a line truck with insulating upper and lower sections is positioned so that a dropped line won’t directly contact it. All lines involved have been adequately covered with blankets and hoses, and the truck has been grounded using the best available equipment. Is this enough to comply with 1910.269(p)(4)(iii)(C) so that equipotential grounding mats and barricading aren’t necessary?
A: Paragraph 1910.269(p)(4)(iii)(C) states that employees “shall be protected from hazards that could arise from mechanical equipment contact with energized lines or equipment. The measures used shall ensure that employees will not be exposed to hazardous differences in electric potential. Unless the employer can demonstrate that the methods in use protect each employee from the hazards that could arise if the mechanical equipment contacts the energized line or equipment, the measures used shall include all of the following techniques …”
Ensuring employees are not exposed to potential differences can be accomplished through training and procedures that keep employees clear of the truck and step-potential hazards. The employer must be able to defend the training and procedures in place. If they can ensure alternative procedures protect workers on the ground, they have met the conditions of OSHA’s rule, so equipotential mats would not be required. However, if someone violates those rules, their training and the isolation policy are rendered moot. Equipotential mats would then be required.
Q: Do any published standards exist regarding the amount of time a student must spend completing an arc flash training course focused on electrical safety practices and work standards? For instance, does OSHA or NFPA require a student to spend, say, 90 minutes learning this content?
A: Some mandatory time requirements and other obligations exist for training, but they are few and far between and limited to specific industries. One example is powered industrial trucks (PITs), or forklifts, but there is no time requirement for PIT training, just some content rules. Both time and content requirements have been developed for the electrical safety portion of the OSHA 10-hour training and for MSHA new miner training, which provide general safety awareness for non-electrical workers.
If they relate to an employee’s task assignments, training on the topics you asked about – arc flash and electrical safety practices – should be delivered separately from the OSHA 10 curriculum, with no time requirements. OSHA demands that employers ensure employees are qualified in their work-related tasks. Employers must determine the training required and how to provide it. They can engage a third party to deliver training, or a qualified person can provide it in-house.
The bottom line is that no standard has been established regarding the length of an employee’s workplace hazard training because all exposures are not the same. Training must sufficiently address recognition of relevant hazards, safety procedures, personal protective equipment and emergency protocols. To prove its effectiveness, OSHA also expects training to include written and practical demonstrations.
Do you have a question regarding best practices, work procedures or other utility safety-related topics? If so, please send your inquiries directly to kwade@utilitybusinessmedia.com. Questions submitted are reviewed and answered by the iP editorial advisory board and other subject matter experts.