Flow charts for standard application

Yes — if an electrical installation meets the specific design requirements in Subpart S, it is considered to comply with the electrical-installation design provisions of 1910.269. Employers should confirm the installation meets 1910.302 through 1910.308 and then follow the electrical safety-related work practices of Subpart S as applicable.

• See the flow chart and statement in Appendix A-1 to 1910.269 showing that Subpart S design compliance covers the design aspects of 1910.269.
• For the full 1910.269 requirements, see 1910.269.

Complying with Subpart S electrical safety-related work-practice and training requirements can satisfy many, but not all, paragraphs of 1910.269; Appendix A-2 lists which paragraphs are covered and which still apply regardless.

• See Table 1 in Appendix A-2 to 1910.269 for the mapping of Subpart S compliance to specific paragraphs of 1910.269.
• For example, Subpart S coverage will satisfy the electric-shock-hazards portion of paragraph (d) and paragraphs (i)(2) and (i)(3), while paragraphs such as (a)(2)–(a)(4), (b), and (c) apply regardless of Subpart S compliance. See 1910.269 for the underlying requirements.

No — compliance with Subpart S does not remove all 1910.269(l) obligations; Appendix A-2 specifies which subsections of (l) are satisfied by Subpart S and which still apply.

• Appendix A-2 Table 1 shows that Subpart S compliance covers (l)(1) through (l)(5), (l)(7), and (l)(10) through (l)(12), but paragraphs (l)(6), (l)(8), and (l)(9) remain separately applicable under 1910.269.
• Employers must therefore review both 1910.269 and Subpart S requirements to ensure full compliance.

You must follow 1910.269 provisions for non–electric-shock hazards even if Subpart S covers electrical work practices; Appendix A-2 clarifies that certain 1910.269 paragraphs apply regardless of Subpart S compliance.

• Appendix A-2 notes that paragraph (d) for hazards other than electric shock still applies even when Subpart S is followed (see Appendix A-2 Table 1).
• Employers should consult 1910.269 to identify and meet non–electric-shock hazard requirements such as mechanical, thermal, or fall hazards.

You may follow the lockout and tagging procedures in 1910.333(b) for electric-shock hazards when the generation, transmission, or distribution installation already meets the electrical installation requirements of Subpart S (1910.302–1910.308).

• Appendix A-4 explains that if the installation conforms to 1910.302 through 1910.308 then the 1910.333(b) procedures may be used for electric-shock hazards (see Appendix A-4 to 1910.269).
• Remember that paragraphs (b)(2)(iii)(D) and (b)(2)(iv)(B) of 1910.333 still apply, and 1910.333(b) must be used for electrical hazards from work on, near, or with conductors and equipment; see 1910.333.

When hazards are commingled, the standard that applies is the one for the hazard that poses the greater risk; Appendix A-4 explains that the standard covering the greater hazard governs.

• Appendix A-4 states that where installations are commingled "to the extent that the electric power generation, transmission, or distribution installation poses the greater hazard," 1910.269's provisions prevail (see Appendix A-4 to 1910.269).
• Employers must evaluate hazards and follow the applicable provisions of 1910.269 or Subpart S depending on which hazard presents the greater risk.

1910.146 permit-required confined space requirements apply when the space meets the definition of a confined space or permit-required confined space, and Appendix A-5 shows how 1910.146 and 1910.269 interact for manholes and vaults.

• Appendix A-5 directs employers to use 1910.146(c) for general nonentry requirements that apply to all confined spaces and notes that paragraph (t) of 1910.269 contains additional requirements for work in manholes and underground vaults (see Appendix A-5 to 1910.269).
• Employers must comply with both 1910.146 and the specific manhole/vault provisions in 1910.269(t) when applicable.

Tree-trimming near energized lines may involve both 1910.269 (utility industry) and Subpart S electrical requirements; Appendix A-3 shows when Subpart S applies to tree-trimming operations.

• Appendix A-3's flow chart and notes explain application of 1910.269 and Subpart S to tree trimming and include approach-distance guidance such as the base 3.05 meters (10 feet) plus increments for higher voltages (see Appendix A-3 to 1910.269).
• Employers conducting tree-trimming near power lines should evaluate whether the work is part of electric power operations covered by 1910.269 or whether Subpart S rules for electrical safety-related work practices apply, and then follow the stricter applicable requirements.

Certain general paragraphs of 1910.269 always apply, even if you comply with Subpart S; Appendix A-2 identifies these paragraphs in its right-hand column.

• Appendix A-2 Table 1 shows that paragraphs such as (a)(2), (a)(3), (a)(4), (b), and (c) apply regardless of compliance with Subpart S (see Appendix A-2 to 1910.269).
• Employers must consult 1910.269 to ensure they meet these always-applicable provisions.

Yes — where Subpart S training and work-practice requirements apply, they satisfy many of the training and qualification provisions of 1910.269, but some 1910.269 training requirements remain separately applicable.

• Appendix A-2 maps specific training-related paragraphs: for example, Subpart S compliance covers paragraphs (i)(2) and (i)(3) of 1910.269 as indicated in Appendix A-2 Table 1.
• Employers should compare the training text in Subpart S (1910.332–1910.335) with 1910.269 to ensure all applicable employee training and qualification requirements are met.

No — following Subpart S for electrical safety does not allow an employer to ignore 1910.269 protective equipment requirements for non-electrical hazards; Appendix A-2 specifies which protective-equipment subsections remain applicable.

• Appendix A-2 shows that while many subsections of (l) are covered by Subpart S, others such as (l)(6), (l)(8), and (l)(9) remain the employer's responsibility under 1910.269 (see Appendix A-2 Table 1).
• Employers must evaluate both electrical and non-electrical hazards and provide personal protective equipment in accordance with 1910.269 and other applicable standards.

No — supplementary generating equipment used only to supply a workplace for emergency, standby, or similar purposes is not considered an electric power generation installation under 1910.269.

• Appendix A-2 explicitly states that supplementary electric generating equipment used solely for emergency or standby purposes is not considered an electric power generation installation (see Appendix A-2 to 1910.269).
• Employers should still review other relevant standards such as 1910.269 and Subpart S (1910.302–1910.308) to determine which requirements apply to their equipment.

Yes — 1910.333(b) and the general lockout/tagout requirements apply to electrical hazards, but other hazardous energies (mechanical, hydraulic, etc.) must be controlled per 1910.147 or 1910.333 as appropriate.

• Appendix A-4 indicates that while 1910.333(b) may be used for electric-shock hazards under certain circumstances, paragraph (b) of 1910.333 applies to any electrical hazards from work on, near, or with electric conductors and equipment, and other hazardous energies must be addressed as required in 1910.147 or 1910.333 (see Appendix A-4).
• Employers should reference the lockout/tagout standard 1910.147 for controlling non-electrical hazardous energy.

Employers should confirm their installations meet the Subpart S design requirements in [1910.302 through 1910.308] to be considered in compliance for electrical design aspects of 1910.269.

• Appendix A-2 states that if the electrical installation meets the requirements of 1910.302 through 1910.308 then the installation and associated safety-related work practices conforming to 1910.332 through 1910.335 are considered to comply with the applicable provisions of 1910.269 (see Appendix A-2).
• Employers must document compliance with those Subpart S sections and still verify any 1910.269 requirements that apply regardless of Subpart S coverage.

Yes — the general non-entry confined-space requirements in 1910.146(c) apply to all confined spaces, and 1910.269(t) adds additional requirements for manholes and underground vaults.

• Appendix A-5 explicitly tells employers to use 1910.146(c) for general nonentry confined-space requirements and to also follow paragraph (t) of 1910.269 for manholes and vaults (see Appendix A-5 to 1910.269).
• Employers must comply with both sets of requirements as applicable to ensure worker safety in confined spaces.

"Commingled" means hazards or installations are combined to the extent that one operation (for example, electric power generation, transmission, or distribution) poses the greater hazard, and the standard for the greater hazard will control.

• Appendix A-2 notes that "commingled" applies where the electric power generation, transmission, or distribution installation poses the greater hazard; in those cases 1910.269 controls (see Appendix A-2 to 1910.269).
• Employers must assess which operation presents the greater hazard and apply the corresponding OSHA standard (1910.269 or Subpart S sections).

Not automatically — Subpart S training and qualification sections will satisfy many of 1910.269’s electrical training and qualification requirements, but employers must verify that any additional qualification elements unique to 1910.269 are also met.

• Appendix A-2 cross-references Subpart S sections such as 1910.332–1910.335 and maps how they correspond to specific paragraphs in 1910.269 (see Appendix A-2).
• Employers should compare training topics, frequency, and qualification criteria in both Subpart S and 1910.269 and document that workers meet all applicable requirements.

When testing or positioning requires temporary re-energization during servicing, employers must follow the sequence of protective steps in 1910.147(f)(1) and provide effective employee protection during the energized period; Appendix A-4 and the lockout/tagout interpretation provide this guidance.

• Appendix A-4 explains the interplay of 1910.269, 1910.147, and 1910.333 for hazardous-energy procedures (see Appendix A-4 to 1910.269).
• OSHA’s letter clarifying the minor servicing exception describes the required sequence under 1910.147(f)(1) for temporary removal of LOTO devices and re-energization, including clearing tools, removing employees from danger areas, and providing employee protection during testing; see the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.
• Employers must document procedures and protections whenever temporary energization is necessary.

Not necessarily — Subpart S covers many electrical work-practice requirements including approach distances and arc-flash protections, but employers must confirm that the specific arc-flash and approach-distance provisions in 1910.269 are satisfied as mapped in Appendix A-2.

• Appendix A-2 links specific electrical safety-related work-practice paragraphs of 1910.269 to Subpart S provisions; for example, electric-shock-hazard provisions in paragraph (d) may be met by Subpart S (see Appendix A-2 Table 1).
• Employers should compare the exact language and technical criteria for approach distances, arc-flash PPE, and related practices in Subpart S (1910.332–1910.335) and 1910.269 to ensure full compliance.

Employers should keep clear documentation that the electrical installation was designed and maintained to meet the Subpart S design requirements in [1910.302–1910.308], and retain records showing use of the Subpart S work practices and training that correspond to 1910.269.

• Appendix A-4 and Appendix A-2 indicate that conformity with 1910.302–1910.308 allows reliance on 1910.333(b) procedures for electrical lockout/tagout in many situations (see Appendix A-4 to 1910.269).
• Maintain design, inspection, and maintenance records, training documentation for employees under Subpart S (1910.332–1910.335), and written procedures showing why 1910.333(b) is appropriate for the electrical hazards present.