Q: OSHA’s digger derrick exception – found at 29 CFR 1926.1400(c)(4) – includes digger derricks when they are used for augering holes for poles carrying electric or telecommunication lines, for placing and removing the poles, and for handling associated materials for installation on, or removal from, the poles, or when used for any other work subject to 1926 Subpart V. Substations are included in Subpart V, so why do some people say setting steel or regulators is not covered by the exception?
A: You might try to justify substations as being in Subpart V – except for what the substation rules cover in Subpart V. OSHA 1926.966, “Substations,” is not about construction of substations. It is about working in substations. The rule covers minimum approach distances, guarding of live parts, switching and electrical safety. Steel erection, just like concrete work, falls under horizontal standards.
The logical thinking of very reasonable people regarding this issue often is challenged for sensibility, mostly because of their perspective. For instance, if I can hang a capacitor on a wood pole with a digger derrick, why can’t I hang a beam and capacitor in a substation with a digger derrick? It’s the same thing, it’s a capacitor. The right perspective is that all construction-related lifting of loads by cranes is regulated under 1926.1400, except lifting poles and pole-mounted equipment that are installed using a truck specifically designed for digging and setting poles.