or policies does Oregon OSHA have regarding the use of the Oregon
Department of Transportation (ODOT) manual for Traffic Control on State
Highways for Short Term Work Zones? If none exists, could you provide
guidance regarding the application of the ODOT manual.
1 A.
ODOTs Short Term Traffic Control Handbook was cooperatively developed by
ODOT, OR-OSHA, Portland General Electric and other utility companies, and
city and county engineers. A letter from Technical Section, dated February 12,
1991 (still in effect), was issued to OR-OSHA field staff directing them to use the
Traffic Control for Short Term Work Zones handbook. A new edition of the
MUTCD was recently adopted at the federal level. As soon as it is determined
that all revisions have been made, OR-OSHA will adopt the new edition. Also,
committee work (at ODOT) will continue on the development of a new edition of
the Short Term Traffic Control Handbook. Mike Mitchell is on that committee.
One goal of the committee is to develop a handbook for use by all entities,
including ODOT, OR-OSHA, utilities, and municipalities. It probably is a good
idea that written guidance in the application of the handbook be issued to the
field staff in the future.
2 Q. Are orchard ladders allowed to be used on construction projects? Are there any Robert Salinas, SFO Consultation Mgr.
July 17, 2002
Page 2
requirements or circumstances that need to be considered if these ladders are
used on construction projects? If orchard ladders are allowed to be used on
construction projects, are they required to have a metal spreader or locking
device?
2 A. There is nothing in the rules that prohibits the use of orchard ladders on
construction sites. In fact, in some instances, such as on rough or sloped
ground, the tripod design of orchard ladders is really the safest to use. The
intent of 1926.1053(b)(4) is to prohibit ladders from being used for purposes
other than for what they are designed, such as scaffold platforms, bridging,
support, or in unsafe locations or on unsuitable surfaces. An orchard ladder, for
instance, is designed to be used on soil or turf, with each leg slightly penetrating
the ground. Orchard ladders should never be used on concrete or hard
surfaces. While it is not required that a tripod ladder be equipped with a
spreader brace, it is recommended that such ladders have spreader braces,
especially when theres potential for a leg becoming unanchored. Tripod ladders
with spreader braces, commonly called electricians tripod step ladders, are
common on construction sites.
3 Q. Under what circumstances can a body belt be worn in aerial lifts as part of a fall
protection system? Under what circumstances must a full body harness be worn
in aerial lifts as part of a fall protection system. Are there different requirements
for the use of body belts vs. a full body harness in Division 2 than there are in
Division 3?
3 A.
Division 3 requires that a full body harness be incorporated into a fall arrest
system when working from an aerial lift. The minimum that Division 2 requires is
that a body belt be incorporated into a fall arrest system when working from an
aerial lift, though nothing prohibits the use of a full body harness. The reference
to the use of a belt as the minimum should be a hint that theres a safer way to
work, namely by using a full body harness. The September 1, 2000 memo from
Barry Jones and Steve Beech allows the use of a body belt (as part of a fall
restraint system) while working from an aerial lift on a construction site so long as
it is physically impossible for the worker to move, be bounced, or thrown out of
the bucket.
4 Q. When working over water in an aerial lift on a construction project is fall
protection equipment required to be worn? Please explain your answer.
4 A.
Fall protection is required to be worn when working from an aerial lift over water.
While the wall of the bucket provides the primary fall protection, the lanyard Robert Salinas, SFO Consultation Mgr.
July 17, 2002
Page 3
attached to either a body belt or full body harness provides additional protection
from being thrown out of the bucket. Theres no exemption in the rule that allows
someone to work in a bucket without being attached by a lanyard while over
water, and there is a potential for injury from the impact, or from drowning.
5 Q. What is the definition of High Voltage? What is the definition of High Voltage
Lines? Is the Neutral line considered to be part of the High Voltage Line
system? Is the ground wire that runs down the pole considered to be part of the
High Voltage Line system. What are the clearance requirements for High
Voltage Lines? Do the clearance requirements apply to the Neutral line? Do
the clearance requirements apply to the above mentioned ground wire?
5 A.
High Voltage is defined in 1926, Subpart V (which applies only to the
construction of electrical transmission and distribution lines and equipment) as
750 to 230,000 volts, phase to phase. All other construction electrical
activities, are covered by 1926, Subpart K. Tables K-1, K-2 and K-3, and the
subheading for 1926.403(j), imply that high voltage is over 600 volts, nominal.

The term high voltage lines is not defined in either 1926, Subpart K or V.
Subpart V defines high voltage, and Subpart V defines electrical supply lines
as those conductors used to transmit electric energy and their necessary
supporting or containing structures. Oregons Overhead Line Safety Act defines
overhead line as any bare or insulated electric conductor installed above the
ground. Thus, high voltage lines are overhead supply lines used to conduct
electric energy at voltages over 600 volts up to 230,000 volts. Voltage over
230,000 volts is referred to as extra high voltage.
A neutral line is part of a high voltage overhead distribution line system. The
neutral provides the pathway for the current to return to its source. When a
neutral is broken, or if a phase drops across it, the neutral will become
energized. Normally theres no visible evidence of the neutral being energized.
Otherwise, if a system is not damaged and is working as designed, the neutral is
not energized. Transmission line systems do not have neutrals.
A ground, running down a pole, is also part of a high voltage overhead supply
system. When a ground is properly designed and installed, and not damaged,
its connection to the earth is of sufficient low impedance and ampacity that
ground fault current which may occur (if the system is faulted or overloaded)
cannot build to voltages dangerous to people. Robert Salinas, SFO Consultation Mgr.
July 17, 2002
Page 4
The overhead high voltage line clearance requirements are listed in 1926,
Subpart K, 1926.416(a) and OAR437-003-0047. While the requirements for
equipment, tools and material are specific (minimum of 10 feet or more,
depending on the voltage, must be kept at all times) the requirements for worker
exposure is less specific and is performance based. OAR437-003-0047(1) says
that no one is allowed to be within such proximity to high voltage lines that
contact can be made unless accidental contact with the lines has been
effectively guarded against. Non-qualified workers (those not familiar with the
construction and operation of the equipment and the hazards involved) are
normally not allowed within 10 feet of overhead high voltage lines.
While it certainly is a good idea to stay a safe distance from a neutral line (which
may become energized if the supply system is damaged), the 10 foot rule does
not apply to neutrals. A neutral is part of an electric power circuit as referred to
in 1926.416(a), but it is not a high voltage line as referred to in OAR437-003-
0047(1) and (2). The neutral is normally located on a cross arm with a phase, or
approximately 6 feet or less below the phases (within the electric supply space
on the pole, and at least 40 inches above the communication space). This
means that if a 10 foot clearance from the energized phases is maintained (by
non-qualified workers), a safe distance from the neutral will also be maintained,
as required by 1926.416(a)(1).
The clearance requirements do not apply to grounds on poles. Most supply
systems are designed with more than an ample number grounds, and unless the
system is damaged or highly overloaded (such as from a direct lightning strike to
a pole that someone is working next to), there should not be any hazard to
someone working in close proximity to a ground.