July-August 2026 Q&A
Q: How do consensus standards apply to the employer’s responsibility for safe work practices?
A: Consensus standards are part of a system that employers can use to develop their safety programs. The issue here is whether an employer can defend their programs. Compliance with a consensus standard does not necessarily ensure OSHA compliance; the agency has clearly defined consensus standards as useful for helping employers meet the more performance-based requirements of the OSHA rules, which typically tell employers what must be accomplished but not how it must be done.
OSHA states in Appendix G to 29 CFR 1910.269 that it “will not necessarily deem compliance with the national consensus standards to be compliance with the provisions of § 1910.269.” In the most recent revisions to 1910.269 and 1926 Subpart V, the agency dropped the use of “adopted” consensus standards – a process that treated “shall” portions of select consensus standards as enforceable – updating the terminology to “referenced” consensus standards. A referenced standard is not enforceable as a rule, but OSHA will often issue General Duty Clause citations using language drawn from referenced consensus standards.
Q: Can we use rubber gloves to install grounds?
A: OSHA 1910.269(n)(6)(i) allows use of rubber gloves to ground at 600 volts or below, so we can’t use them to install grounds above that threshold. There isn’t much need for voltages between 600 volts and 4 kV, aside from some specialty voltages.
The employer must verify that all conductors are de-energized where employees are grounding with rubber gloves. This means developing a procedure and relevant training to ensure that workers test for voltage before installing grounds, just as we conduct voltage testing when installing grounds with hot sticks.
There’s a specific, practical reason why we use hot sticks at 4 kV and above: to address potential circuit energization while making a ground connection. Despite OSHA allowing rubber glove installation of grounds below 600 volts, workers should be aware that grounding an energized circuit under that threshold can be as hazardous as using hot sticks to ground an energized circuit above 600 volts.
Q: In distribution URD, what’s the correct way to ground/isolate the conductor we’ll be working on? Where is the best place to ground, or how do we isolate, and which is best? Our primary concern is splicing and having the neutrals at different potentials. We are trying to get away from removing the jacket on the conductor and bonding across. This gives us another area to fix in the conductor, and sometimes space to do that is an issue. Can you offer any guidance?
A: As part of confirming that a cable is de-energized, ground it on a bushing or feed-through with a grounding cap at each end. Next, connect the ground lead to the cable’s twisted concentric. Achieve isolation by cutting the twisted concentric from the ring-bond ground in the pad or enclosure. In addition, you must isolate the bushing mount from the transformer bracket it is typically mounted to. This eliminates cable capacitance because the phase conductor is now in series with the concentric, not parallel to it.
Simply parking the cable is another method of verification. When parked at each end, the phase conductor is isolated. Although it isn’t grounded, no rule exists that requires us to ground the cable, and isolation is a legitimately safe work mode. A parked elbow means the phase conductor is isolated but the concentric is still continuous.
Since the concentric is bonded to the pad, the concentric and enclosure have equal potential. Keep in mind that a system fault could still create high potential between the concentric/pad-mount and the surrounding earth.
IEEE’s “Worker protection while working de-energized underground distribution systems” is a great compendium of preferred employee protection practices for de-energized URD work. You can access a copy at https://ieeexplore.ieee.org/document/1256391.
Q: Does OSHA require annual inspections and testing of full-body harnesses used in fall protection?
A: OSHA does not mandate annual fall protection inspections. The agency considers an employee’s required daily inspections and inspections by a competent person to be effective.
Note that inspection protocols must consider the fall protection manufacturer’s guidelines. Some body belts have limited lifetime use; be sure to read each belt’s labeling to determine whether any limits apply.
Q: If we have double circuits, one at 13.8 kV and one at 34.5 kV, can our workers use Class 2 and 3 gloves, or do we have to use the gloves rated for the highest voltage?
A: Some readers might believe that “cradle to cradle” means one pair of gloves unless you cradle and change, so let’s clear that up right away. Cradle to cradle is a legitimate working policy that has value, but it’s not an OSHA requirement. Along with ground to ground and lock to lock, use of this method increases the safety buffer during hot work. All three methods have been sporadically used across the industry, becoming more popular with employers when the OSHA Electrical Transmission & Distribution Partnership adopted and published them as best practices.
Gloves must be rated for the worker’s voltage exposure. Class 2 gloves tested for use at 18 kV clearly don’t meet the phase-to-ground 19.9 kV of a 34.5-kV circuit. Entering the minimum approach distance of an uncovered bus means that you are exposed and thus required to don appropriately rated gloves. With 13.8 kV and 34.5 kV on the same structure, there is no reason why two classes of gloves can’t be issued in the same bucket and changed as needed. It is legal to remove the Class 3 gloves when backing out of the 34.5-kV MAD, donning the Class 2 gloves before you enter the 13.8-kV MAD.
Although some readers may protest this line of thinking, we are merely stating OSHA rules and industry practices pertaining to insulation/isolation. The employer must be able to demonstrate that their method complies with OSHA’s minimum requirements. We suggest updating your training and policy documents to require use of a call-and-response technique: Workers in the air call out a glove change, then workers on the ground respond to acknowledge the change is occurring.
Q: Does OSHA require us to ground trucks used in energized power-line work?
A: No. The singular applicable rule is found at 1910.269(p)(4)(iii)(c), which states that unless the employer can demonstrate that the methods in use protect employees from the hazards that could arise if mechanical equipment contacts energized lines or equipment, protective measures must include the best available ground, bonding equipment together, using ground mats and employing insulating material.
So, how can we say that OSHA doesn’t require truck grounding when using the best available ground is the first protective measure they mention? Because the agency initially states this: “Unless the employer can demonstrate that the methods in use protect each employee …” Sometimes safety solutions are simple. For instance, if touching a truck can kill you, don’t touch the truck. If standing 2 feet from a truck exposes you to step potential, stand 10 feet away.
The purpose of grounding a truck is to open protectors and clear the circuit if the grounded boom contacts the bus. A worker in contact with the truck provides a parallel path to ground with the temporarily installed truck ground. Only the coincidence of parallel resistances decides whether that contact is lethal, which is why OSHA’s rule also demands grounding in an equipotential arrangement. If you promote truck grounding to protect workers but do not use equipotential mats, you are not complying with the standard.
For a detailed review of step and touch hazards related to grounded trucks, readers can review “A Close Look at Step and Touch Potentials” by Jim Vaughn, CUSP, available at https://incident-prevention.com/blog/a-close-look-at-step-and-touch-potentials/.
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.