In the May 2001 issue of Cabling Installation & Maintenance, an article on confined spaces quoted OSHA regulation 1910.146 (see "Confined spaces call for special safety procedures," May 2001, page 100). After much research, it has been determined that OSHA also has a regulation for telecommunications spaces. It is 1910.268 Tele communications.
As stated in the preamble to 1910.268, the section "sets forth safety and health standards that apply to the work conditions, practices, means, methods, operations, installations, and processes performed at telecommunications field installations, which are located indoors or in building spaces used for such field installations.
"Center work includes the installation, operation, maintenance, rearrangement, and removal of communications equipment and other associated equipment in telecommunications switching centers. Field work includes the installation, operation, maintenance, rearrangement, and removal of conductors and other equipment used for signal or communications services, and of their supporting and containment structures, overhead or underground, on public or private rights of way, including buildings and other structures."
In most cases, 1910.268 supersedes 1910.146. In March 1993, a member of the Communications Workers of America (CWA) wrote to OSHA on behalf of the CWA's 600,000 workers, including approximately 70,000 at that time who had jobs requiring entry and work within confined spaces. In that letter, the CWA requested clarification of the circumstances under which 1910.146, rather than 1910.268, would apply to telecommunications spaces.
OSHA replied to the CWA letter in May 1993. In the letter, OSHA characterized 1910.146 as a "generic standard" and 1910.268 as "an industry-specific standard." The letter further stated that "OSHA provides clear guidance regarding the application of generic standards in 29 CFR 1910.5, Applicability of Standards. In particular, 29 CFR 1910.5(c)(1) provides that a particular standard will supersede a generic standard when the 'particular standard specifically applies to a condition, practice, means, method, operation, or process.'
"Also, 29 CFR 1910.268(c)(2) states that a generic standard 'shall apply ... to any employment in any industry, even though particular standards are also prescribed for the industry ... to the extent that none of such particular standards applies.'
"The telecommunications standard explicitly provides for the application of a generic standard in 29 CFR 1910.268(a)(3), Application, which states 'operations or conditions not specifically covered by this section are subject to all the applicable standards contained in this part 1910.'"
The letter from OSHA to the CWA further stated that 1910.146 requires all employers, including telecommunications companies, to determine if their workplaces contain any confined spaces that meet the definition of a "permit-required confined space." It also recalled that OSHA previously stated that where permit space hazards are addressed by 1910.268, the telecommunications standard-not the permit space standard-applies.
Later, the letter stated that "the measures required by the telecommunications standard for the protection of employees working on underground lines divide into three categories:
- Protection from falling or from falling objects;
- Availability of first aid assistance where there is reason to believe that safety hazards are present;
- Testing the atmospheres of manholes and unvented vaults prior to employee entry and, where atmospheric hazards are detected, ventilating and taking any other measures necessary for safe entry."
OSHA summed up its response with the following: "1910.268, rather than 1910.146, applies only to the extent that compliance with the above-described provisions adequately addressed the permit space hazards to which telecommunications employees are exposed."
The OSHA Web site (www.osha.gov) is a great reference site. Under "Search," list 1910.268. You will find many clarifications and interpretations that cover everything from work gloves in the telecommunications industry to induced voltages encountered while performing telecommunications work.
Philip N. Milan, RCDD/LAN specialist, is president of the Massachusetts Telecommunications Contractors Association Inc.