Q: Can you help us with regard to fall protection practices while working on top of a roof or in areas near substation transformers? We are aware of the exceptions for qualified climbers in OSHA 29 CFR 1910.269. How does that affect us?
A: Most utilities will tell you that they don't require fall protection to work a weatherhead on a roof. Many have no fall protection requirements or programs for working on top of transformers. I am aware that some utilities use the definition of a working surface issued by OSHA – at least once every two weeks or for a total of four man-hours or more during any sequential four-week period – as proof that a roof or transformer top is not a work surface and therefore an exception. (See December 18, 1997, OSHA interpretation letter to Niagara Mohawk Power Corp. at https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22508.)