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OSHA 1910.269

Electric power generation safety

Subpart R

50 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.269(a)(1)(i): What work installations does this standard cover (who and what is included)?

This standard covers the operation and maintenance of electric power generation, control, transformation, transmission, and distribution lines and equipment, including related communication or metering equipment accessible only to qualified employees. See 1910.269(a)(1)(i).

Under 1910.269(a)(1)(i)(A): Are industrial plant generation installations treated the same as utility generation installations?

Yes — power generation, transmission, and distribution installations of electric utilities and equivalent installations of industrial establishments are covered when they are accessible only to qualified employees. See 1910.269(a)(1)(i)(A).

Under 1910.269(a)(1)(i)(B): Does 1910.269 apply to non-electrical systems at a generating station, like coal conveyors or water penstocks?

Yes — 1910.269 explicitly applies to certain non-electrical installations at generating stations, including fuel and ash handling such as coal conveyors and water and steam installations like penstocks and pipelines. See 1910.269(a)(1)(i)(B) and its subparagraphs 1910.269(a)(1)(i)(B)(1) and 1910.269(a)(1)(i)(B)(2).

Under 1910.269(a)(1)(ii): When does 1910.269 not apply because of construction work or Subpart S overlap?

1910.269 does not apply to construction work as defined in 1910.12 (except certain line-clearance tree trimming and specified generation work) and does not apply to electrical installations or safety-related work practices already covered by Subpart S standards. See 1910.269(a)(1)(ii).

Under 1910.269(a)(1)(ii)(B) and the Note: Can work that follows 1910.332–1910.335 be treated as complying with parts of 1910.269?

Yes — OSHA considers work practices conforming to 1910.332–1910.335 as complying with the electrical safety-related work-practice requirements identified in 1910.269’s appendix table, provided the employer is working on a generation or distribution installation that meets 1910.303–1910.308 through 1910.308. See 1910.269(a)(1)(ii)(B).

Under 1910.269(a)(3)(i): What information must a host employer give to a contract employer before work begins?

The host employer must give contract employers information about the installation’s characteristics, known safety-related conditions, and any design or operational details the contractor needs to do required assessments and protect their employees. See 1910.269(a)(3)(i) and its subparagraphs 1910.269(a)(3)(i)(A) through 1910.269(a)(3)(i)(D).

Under 1910.269(a)(3)(i)(A)–(D): Can a host employer be required to perform new inspections to supply the information to a contractor?

No — the host employer need only provide information it can obtain from existing records through reasonable diligence; the paragraph does not require the host to make new inspections to obtain that information. See 1910.269(a)(3)(i).

Under 1910.269(a)(2)(i)(A): What basic training must all employees performing work under 1910.269 receive?

All employees must be trained and familiar with the safety-related work practices, safety procedures, and other safety requirements in 1910.269 that apply to their job assignments. See 1910.269(a)(2)(i)(A).

Under 1910.269(a)(2)(ii): What extra training must a qualified employee have compared to an unqualified worker?

A qualified employee must be trained and competent in distinguishing exposed live parts, determining nominal voltages, understanding and maintaining minimum approach distances, using special precautionary techniques, PPE, insulating materials, and recognizing electrical hazards and how to control them. See 1910.269(a)(2)(ii).

Under 1910.269(a)(2)(iii): What training is required for line-clearance tree trimmers who are not qualified employees?

Non-qualified line-clearance tree trimmers must be trained and competent to distinguish exposed live parts, determine nominal voltages, and know the minimum approach distances for the voltages they will be exposed to and how to maintain them. See 1910.269(a)(2)(iii).

Under 1910.269(a)(2)(iv)–(v): How often and when must employers retrain employees?

Employers must supervise regularly and inspect at least annually to ensure compliance, and provide retraining if inspections show noncompliance, if new technology or procedures change required safety practices, or if the employee must perform rarely used tasks (less often than once per year) before doing them. See 1910.269(a)(2)(iv) and 1910.269(a)(2)(v).

Under 1910.269(a)(2)(viii): How can an employer document that an employee has demonstrated proficiency in required work practices?

An employer must ensure each employee has demonstrated proficiency before considering training complete; employment records of successful training are one way to track this, and for previously trained workers the employer may confirm training, examine or interview them, and closely supervise until proficiency is demonstrated. See 1910.269(a)(2)(viii).

Under 1910.269(a)(1)(i)(E): When does the full 1910.269 apply to line-clearance tree trimming?

If line-clearance tree trimming is performed by qualified employees for an organization that operates or controls the operating procedures for the lines or equipment, the entire 1910.269 applies except for paragraph (r)(1). See 1910.269(a)(1)(i)(E)(1).

Under 1910.269(a)(1)(i)(E)(2): What parts of 1910.269 apply to line-clearance trimmers who are not qualified?

For non-qualified line-clearance tree trimmers, the employer must follow paragraphs (a)(2), (a)(3), (b), (c), (g), (k), (p), and (r) of 1910.269 to protect those employees. See 1910.269(a)(1)(i)(E)(2).

Under 1910.269(a)(2)(vi): What training formats are acceptable for 1910.269 training?

The training required by 1910.269(a)(2) may be delivered as classroom or on-the-job training. See 1910.269(a)(2)(vi).

Under 1910.269(a)(3)(i)(B): What duty does the host employer have to tell contractors about site conditions known to them?

The host employer must inform contractors of site conditions related to safety that are known to the host and listed in paragraphs (a)(4)(vi)–(a)(4)(viii), but only information the host can obtain from existing records through reasonable diligence is required. See 1910.269(a)(3)(i)(B).

Subject: Interaction of 1910.269 and Subpart S — How should an employer decide which standard to follow when both could apply?

Employers must comply with all other applicable standards in part 1910; where 1910.332–1910.335 apply and the work occurs on installations meeting 1910.303–1910.3081910.308, OSHA considers compliance with those Subpart S work-practice rules to satisfy identified 1910.269 requirements. See 1910.269(a)(1)(ii)(B).

Under 1910.269(a)(2)(ii)(C): What are minimum approach distances and who must know them?

Qualified employees who will be exposed to energized parts must know the minimum approach distances for the voltages involved and the skills and techniques necessary to maintain those distances. See 1910.269(a)(2)(ii)(C).

Practical application: If a generator room in a plant is used only for emergency standby, does 1910.269 always cover it?

Not necessarily — Subpart S covers supplementary electric generating equipment used only to supply a workplace for emergency, standby, or similar purposes, while 1910.269 covers power generation installations otherwise; consult 1910.269(a)(1)(i)(A) and Subpart S provisions at 1910.3031910.308 to determine which applies.

Under 1910.269(a)(3)(ii)(A): What must a contract employer do to instruct its employees about hazardous conditions the host employer communicated?

The contract employer must make sure each employee is instructed in the hazardous conditions relevant to the employee’s work that the contract employer learned from the host employer. Employers satisfy this by training employees on the specific hazards the host communicated for that work location and tasks.

Under 1910.269(a)(3)(ii)(B): What must a contract employer tell the host employer before starting work?

The contract employer must advise the host employer of any unique hazardous conditions that the contract employer’s work will create or present before work begins. This means sharing hazards that are specific to the contractor’s methods, equipment, or materials so the host can coordinate protections.

Under 1910.269(a)(3)(ii)(C): When must a contract employer inform the host employer about unanticipated hazardous conditions discovered during work?

The contract employer must notify the host employer of any unanticipated hazardous conditions discovered during the work within 2 working days after discovering the hazard. This gives the host time to update site protections and coordinate with the contractor.

Under 1910.269(a)(3)(iii): How must contract and host employers coordinate their work rules and procedures?

The contract employer and the host employer must coordinate their work rules and procedures so that every employee—whether employed by the host or the contractor—is protected as required by the standard. Coordination means aligning procedures, communications, and protections before and during work to avoid gaps or conflicting practices.

Under 1910.269(a)(4): What existing characteristics and conditions must be determined before working on or near electric lines or equipment?

You must determine the existing characteristics and safety-related conditions of the lines and equipment before starting work. Important items to identify include nominal voltages, maximum switching-transient voltages, hazardous induced voltages, presence and condition of protective grounds and equipment grounding conductors, locations of circuits (including communications and fire-protective circuits), pole condition, and environmental conditions that affect safety.

Under 1910.269(b)(1)(i): For field work on exposed lines or equipment energized at 50 volts or more, how many persons with first-aid training must be available?

For field work involving two or more employees at a work location on exposed lines or equipment energized at 50 volts or more, at least two persons with first-aid training must be available. (There is a limited exception for certain line-clearance tree trimming crews described in the standard.)

Under 1910.269(b)(1)(ii): How many trained first-aid responders are required at fixed work locations such as substations?

At fixed work locations, the employer must provide enough trained persons so that any employee exposed to electric shock can be reached by a trained person within 4 minutes; if there aren’t enough employees to meet that response time, every employee at that location must be trained.

Under 1910.269(b)(3): What are the employer’s responsibilities for first-aid kits in electric power work?

The employer must maintain each first-aid kit, make sure it is readily available, inspect it often enough to replace used items, and perform at least one formal inspection each year.

Under 1910.269(c)(1) and (c)(2): What must a job briefing before each job include and who conducts it?

The employee in charge must conduct a job briefing before each job and must be given all available information about existing characteristics and conditions that affect safety. The briefing must cover hazards associated with the job, the work procedures to be used, special precautions, energy-source controls, and required personal protective equipment.

Under 1910.269(c)(3)–(c)(4): When must additional job briefings be held and how extensive should they be?

At minimum, one job briefing must be held before the first repetitive or similar job of each day or shift; additional briefings are required whenever significant changes occur that might affect employee safety. A brief discussion is acceptable for routine work when trained employees can recognize hazards, but a more extensive discussion is required for complicated or especially hazardous work or when employees cannot be expected to recognize the hazards.

Under 1910.269(d)(1): Does 1910.269(d) apply to lockout/tagout in electric power generation, and how does 1910.147 relate?

Yes—1910.269(d) applies to the use of lockout/tagout procedures for controlling energy sources in electric power generation installations; installations that are not integral to power generation processes (i.e., similar to general-industry equipment) are covered by [1910.147].

Under 1910.147 and the OSHA letter on minor servicing (2024-10-21): If servicing requires temporary energization for testing or positioning, can lockout/tagout devices be removed and what steps must be followed?

Yes—temporary removal of lockout/tagout devices is allowed when re-energization is necessary to test or position equipment, but the employer must follow a strict sequence to protect employees: clear tools and materials, remove employees from hazardous areas, remove the lockout/tagout devices as specified, perform testing or positioning with effective protections in place, then de-energize and reapply energy-control devices if additional servicing is needed.

  • See the temporary re-energization steps in the OSHA letter of interpretation "Minor servicing exception clarification" (Oct. 21, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 and the general LOTO rule at 1910.147.

Under 1910.269(d)(2)(ii): When may a tagout system be used instead of lockout, and what must an employer demonstrate?

A tagout system may be used if the energy-isolating device is not capable of being locked out; if the device can be locked out, the employer must use lockout unless it can demonstrate that its tagout program provides full employee protection equivalent to lockout, including compliance with all tagout provisions and any additional measures needed to equal the safety of lockout.

Under 1910.269(d)(2)(v): Who must perform the periodic inspection of energy control procedures and how often must it be done?

The employer must have an authorized employee who is not using the energy control procedure perform a periodic inspection at least annually; the inspection must be designed to find and correct deviations or inadequacies.

Under 1910.269(d)(2)(ii)(C): For machines installed or majorly repaired after November 1, 1994, what is required for energy-isolating devices?

Any energy-isolating device on machines that are new or undergo replacement/major repair, renovation, or modification after November 1, 1994, must be designed to accept a lockout device.

Under 1910.269(b) and 1910.151(b): When must first-aid supplies be placed in weatherproof containers?

First-aid supplies that could be exposed to the weather must be placed in weatherproof containers. Employers must also meet the medical services and first-aid requirements in [1910.151] when performing work covered by 1910.269.

  • See the weatherproof container instruction in 1910.269(b) and the related medical/first-aid requirements in 1910.151(b).

Under 1910.269(d)(2)(v)(E), what must my periodic inspection certification include for energy control (LOTO) procedures?

Under 1910.269(d)(2)(v)(E) the employer must certify that the required periodic inspections have been done and include the machine or equipment inspected, the date, the employees included, and the inspector's name.

  • The certification must identify the specific machine or equipment on which the energy control procedure was used.
  • It must show the date of the inspection and list the employees who participated in the inspection.
  • It must name the person who performed the inspection.

Note: The standard allows using normal work schedules and operation records as the certification if those records already contain the required information (see the note in 1910.269(d)(2)(v)(E)).

Under 1910.269(d)(2)(v)(C) and (D), who must the inspector review responsibilities with during a periodic LOTO inspection?

Under 1910.269(d)(2)(v)(C) and 1910.269(d)(2)(v)(D), the inspector must review the inspected energy control procedure with the employees who have responsibilities under that procedure: authorized employees when lockout is used, and both authorized and affected employees when tagout is used.

  • For lockout systems: the periodic inspection must include a review between the inspector and each authorized employee of that employee's responsibilities under the procedure.
  • For tagout systems: the periodic inspection must include a review between the inspector and each authorized and affected employee of that employee's responsibilities and the tagout elements required in the standard.

Reference: 1910.269(d)(2)(v)(C) and (D).

Under 1910.269(d)(2)(vi) what training must employers provide for authorized, affected, and other employees about energy control?

Under 1910.269(d)(2)(vi) the employer must train employees so they understand the energy control program and have the skills to apply, use, and remove energy controls safely.

  • Authorized employees must be trained to recognize hazardous energy sources, the type and magnitude of energy present, and the methods for isolating and controlling that energy (1910.269(d)(2)(vi)(A)).
  • Affected employees must be instructed in the purpose and use of the energy control procedures (1910.269(d)(2)(vi)(B)).
  • All other employees who work in areas where energy control procedures may be used must be instructed about the procedures and the prohibition against restarting or reenergizing locked out or tagged equipment (1910.269(d)(2)(vi)(C)).

These training elements ensure each group knows what to expect and what actions are prohibited during energy control operations.

Under 1910.269(d)(2)(vii), what specific limitations about tags must be included in tagout training?

Under 1910.269(d)(2)(vii) tagout training must teach employees that tags are warning devices with specific limits and requirements.

  • Tags are only warning devices and do not provide the physical restraint that locks do (1910.269(d)(2)(vii)(A)).
  • A tag attached to an energy isolating means must not be removed except by the authorized person who applied it, and it must never be bypassed, ignored, or defeated (1910.269(d)(2)(vii)(B)).
  • Tags must be legible and understandable to authorized, affected, and other employees whose work operations may be in the area (1910.269(d)(2)(vii)(C)).
  • Tags and attachments must withstand workplace environmental conditions (1910.269(d)(2)(vii)(D)).
  • Training should make clear that tags may create a false sense of security and must be understood as part of the overall energy control program (1910.269(d)(2)(vii)(E)).
  • Tags must be securely attached so they cannot be accidentally detached (1910.269(d)(2)(vii)(F)).

Training must explain these limitations so employees treat tags appropriately and do not assume they provide the same protection as locks.

Under 1910.269(d)(3)(ii)(D) and related paragraphs, what are the construction and attachment requirements for tagout devices?

Under 1910.269(d)(3)(ii)(D) tagout devices and their means of attachment must be substantial enough to prevent inadvertent or accidental removal and must meet specific attachment design requirements.

  • Tag attachment means must be non-reusable, attachable by hand, self-locking, and nonreleasable with a minimum unlocking strength of at least 50 pounds and generally similar to a one-piece nylon cable tie (1910.269(d)(3)(ii)(D)).
  • Tagout devices must be constructed and printed so that weather or wet conditions do not make the tag illegible (1910.269(d)(3)(ii)(A)(1)).
  • Tagout devices must be standardized within the facility by at least color, shape, size, and for tags also print and format (1910.269(d)(3)(ii)(B)).
  • Each tagout device must identify the employee who applied it (1910.269(d)(3)(ii)(E)).
  • Tags must warn against hazardous conditions and include legends such as “Do Not Operate” as required by 1910.269(d)(3)(ii)(F) (see also 1910.145 for accident prevention tag specifics).

These requirements ensure tagout devices remain effective and understandable under workplace conditions.

Under 1910.269(d)(6)(iv)(B)(1) and (B)(2), where must a tag be attached when the energy isolating device can be locked out, and what if a tag cannot be affixed directly to the isolating device?

Under 1910.269(d)(6)(iv)(B)(1) and 1910.269(d)(6)(iv)(B)(2), when a tagout device is used with an energy isolating device designed to be locked out, the tag must be fastened at the same point where a lock would be attached; if a tag cannot be affixed directly, it must be placed as close as safely possible and in a position immediately obvious to an operator.

  • If the isolating device is lockable, the tag attachment point must be the same point a lock would use (1910.269(d)(6)(iv)(B)(1)).
  • If direct attachment is not possible, the tag must be located as close as safely possible to the isolating device in a clearly visible spot to anyone attempting to operate the device (1910.269(d)(6)(iv)(B)(2)).

These placement rules help ensure the tag warns the right person at the right location.

Under 1910.269(d)(6)(vii), how must an authorized employee verify isolation and when must tests be performed to ensure deenergization?

Under 1910.269(d)(6)(vii) the authorized employee must verify that isolation and deenergizing have been accomplished before starting work; when normally energized parts will be exposed, a test must be performed to ensure those parts are deenergized.

  • Verification of isolation and deenergizing is required before beginning work on locked out or tagged out machines or equipment.
  • If work will expose normally energized parts, the authorized employee must perform an electrical test (or equivalent) to confirm those parts are deenergized.
  • If there is a possibility of reaccumulation of stored energy, verification of isolation must be continued until servicing is complete or the hazard no longer exists (1910.269(d)(6)(vi)).

These steps are meant to prevent unexpected energization or residual energy contact during servicing.

Under 1910.269(d)(7)(iv), what procedures must an employer have if a lockout or tagout device must be removed when the authorized employee who applied it is not available?

Under 1910.269(d)(7)(iv) the employer may remove a lock or tag applied by an authorized employee only under a documented procedure that provides equivalent safety and includes specific steps.

The required procedure must include at least the following:

  • Verification that the authorized employee who applied the device is not at the facility (1910.269(d)(7)(iv)(A)).
  • Making all reasonable efforts to contact the authorized employee to inform them their device has been removed (1910.269(d)(7)(iv)(B)).
  • Ensuring the authorized employee knows their device was removed before they resume work at the facility (1910.269(d)(7)(iv)(C)).

The employer must document and train employees on this alternative removal procedure and be able to demonstrate it affords a degree of safety equivalent to removal by the authorized employee who applied the device.

Under 1910.269(d)(8)(i)(A)-(E) and OSHA's interpretation of temporary energization, what sequence must be followed if LOTO devices are temporarily removed to test or position equipment?

Under 1910.269(d)(8)(i)(A)-(E) the employer must follow a specific sequence when locks or tags are temporarily removed to test or position machines: clear tools and materials, remove employees from the area, remove devices per procedures, energize for testing with employee protection in place, then deenergize and reapply energy controls.

OSHA’s interpretation on the minor servicing exception clarifies that reenergization for testing/positioning is allowed only for the limited time needed and that the employer must provide employee protection (e.g., guards or removing employees from the hazard area) during those energized periods.

Under 1910.269(d)(2)(viii), when must retraining be provided and what must retraining accomplish?

Under 1910.269(d)(2)(viii) retraining must be provided whenever job assignments change, equipment or processes change creating new hazards, procedures change, or when inspections or other evidence show an employee’s knowledge or use of procedures is inadequate; the retraining must reestablish proficiency and introduce new or revised methods.

  • Retraining is required when employees change jobs, machines, equipment, or processes that introduce new hazards or when the energy control procedures change (1910.269(d)(2)(viii)(A)).
  • Retraining is also required when periodic inspections reveal, or the employer has reason to believe, an employee deviates from or is inadequate in using the procedures (1910.269(d)(2)(viii)(B)).
  • The retraining must restore employee proficiency and introduce any new or revised control methods and procedures as necessary (1910.269(d)(2)(viii)(C)).

Retraining should be documented and tailored to address the specific gaps or changes that triggered the retraining requirement.

Under 1910.269(d)(3)(ii)(C), how strong and durable must lockout devices be?

Under 1910.269(d)(3)(ii)(C) lockout devices must be substantial enough to prevent removal without excessive force or unusual techniques (for example, they should not be removable with bolt cutters or metal cutting tools).

  • Locks must be robust and designed so they cannot be defeated with common extreme tools or techniques.
  • Lockout devices should match the strength and durability needed for the environment and the energy being controlled; selection should consider the exposure and potential attack methods.

This requirement helps ensure locks provide real physical restraint, not just a symbolic barrier.

Under 1910.269(d)(2)(ix) and 1910.269(d)(3), what must employer training certifications include for energy control training?

Under 1910.269(d)(2)(ix) and 1910.269(d)(3), the employer must certify that employee training has been accomplished and kept up to date, and the certification must contain each employee’s name and the dates of training.

  • The employer must maintain a training certification showing that required training occurred and is current (1910.269(d)(2)(ix)).
  • The certification must list each employee’s name and the dates they received the training (1910.269(d)(3)).

Keeping precise training records supports compliance and helps schedule retraining when procedures, equipment, or employee assignments change.

Under 1910.269(d)(8)(ii), what must an employer do when using a group lockout or tagout device so each worker remains protected?

The employer must assign a specific authorized employee to be primarily responsible for the group lockout and require each authorized employee to attach and remove their own personal lock or tag when they begin and stop work.

  • Under 1910.269(d)(8)(ii)(A) the employer must vest primary responsibility in an authorized employee (for example, an operations lock) for the set of employees protected by the group device.
  • Under 1910.269(d)(8)(ii)(B) the authorized employee must be able to determine each individual group member’s exposure status with regard to the lockout/tagout.
  • If multiple crews or crafts are involved, the employer must assign an overall coordinator as required by 1910.269(d)(8)(ii)(C) to maintain continuity of protection.
  • Each authorized employee must affix a personal lock or tag to the group lockout device, lockbox, or comparable mechanism when starting work and remove it when stopping work as required by 1910.269(d)(8)(ii)(D).

Practical tips: document the group LOTO procedure, train authorized employees, and verify that the person requesting removal or transfer of the group device is the one responsible for it (see the related requirements for system-operator-controlled central devices at 1910.269(d)(8)(v)).

Under 1910.269(e), what are the required steps for atmospheric testing, instrument calibration, and ventilation before entering an enclosed space?

Before entry you must use a calibrated direct-reading instrument to test for oxygen first, then test for flammable gases/vapors only after confirming sufficient oxygen; instruments must be kept in calibration (±10%) and continuous forced-air ventilation must begin before entry and be maintained as specified.

  • Instrument calibration and accuracy: 1910.269(e)(8) requires test instruments to be kept in calibration and have a minimum accuracy of ±10 percent.
  • Order of testing: 1910.269(e)(9) requires testing for oxygen deficiency before entry with a direct-reading meter; 1910.269(e)(10) and 1910.269(e)(11) require that testing for flammable gases/vapors be done after oxygen testing/ventilation demonstrates enough oxygen for an accurate flammability test, and that forced-air ventilation be used if hazardous concentrations or oxygen deficiency are found.
  • Continuous forced-air ventilation: 1910.269(e)(12) requires ventilation to begin before entry and continue long enough to show a safe atmosphere exists; 1910.269(e)(13) requires the air supply be from a clean source.
  • Attendants and rescue equipment: 1910.269(e)(3) and 1910.269(e)(7) require rescue equipment and that an attendant with first-aid training be immediately available outside the space.

Note: OSHA’s Respiratory Protection interpretation explains that, where OSHA respiratory protection rules apply, an oxygen-deficient atmosphere is recognized below 19.5% oxygen (see https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16). Follow written procedures and training so testing, ventilation, and monitoring protect entrants at all times.

Under 1910.147(f)(1), what must an employer do when a machine must be temporarily re-energized for testing or positioning during service or maintenance?

Under 1910.147(f)(1), the employer may temporarily remove lockout/tagout devices to test or position equipment, but only after following a specific sequence of actions and providing effective employee protection during the energized period.

  • Required sequence: before re-energizing you must (1) clear the machine of tools and materials (1910.147(e)(1)), (2) remove employees from the hazardous area (1910.147(e)(2)), (3) remove lockout/tagout devices in accordance with the standard (1910.147(e)(3)), (4) energize and perform the testing/positioning while maintaining protections (such as guarding or other means that eliminate employee exposure), and (5) de-energize, isolate, and reapply lockout/tagout devices if additional servicing is required (1910.147(d)).
  • Employer obligations: provide written procedures for these transition steps, train authorized employees, and ensure protections remain effective while the equipment is energized; temporary re-energization is only permitted for the limited time necessary.

This approach and the required sequence are explained in OSHA’s interpretation on temporary energization for testing/positioning (Minor servicing exception clarification).