Which OSHA standard covers the work.
Two different OSHA standards can cover the same crew in the same hole. Which one applies changes what the job costs you in people — so it belongs in the bid, not in the argument afterwards.
Working on existing lines inside an existing vault
Splicing, testing, locating, inspecting, installing or removing telecom lines in an existing manhole or vault. OSHA said in 2016 it won't cite that work under the confined-space construction rules, so long as it's done under the telecommunications standard and that standard covers the hazards actually present.
work on or directly related to telecommunications lines and equipment by telecommunications employees in an existing telecommunications manhole or vault will not be subject to citation by OSHA under the Confined Spaces in Construction standards, 29 C.F.R. 1926.1200-.1213, if such work is performed in accordance with the Telecommunications standard, 29 C.F.R. 1910.268, and the hazards associated with such work are addressed by the Telecommunications standard.
That is an enforcement and citation policy, not a regulation. It can be withdrawn without rulemaking.
Building the vault, or boring new duct, is construction
Even between two existing manholes. OSHA said that in the same memo, in as many words: constructing manholes or vaults, installing new ducts, or horizontal boring for new ducts between existing structures does not fall under the citation policy.
Existing plant around you does not make it existing-plant work. That catches a lot of people, because HDD between two live manholes looks like the most existing-plant job there is.
And it can flip on the day
If the hole has an atmosphere you can't make safe before entry, the confined-space rules are back — whatever the job was called on paper. Coverage turns on a gas reading taken at the hole, which is why no field on a job posting can settle it for you, and why this site doesn't pretend to.
What that means for bodies on a hole
Under the confined-space construction rules an attendant stays outside the space and does nothing else while anyone is inside — 29 CFR 1926.1209(d) and (j).
Under 1910.268 a qualified tech may enter alone for brief periods for inspection, housekeeping or readings, and the first-aid-trained person who has to be immediately available is allowed to enter as well — 29 CFR 1910.268(o)(3).
That is a real difference in headcount. Worth pricing before you bid.
Two things we see written wrong constantly
1910.268 has no standby attendant requirement. It requires a first-aid-trained person immediately available where there is cause to believe a hazard exists — and that person is permitted to enter the hole. If something tells you 1910.268 mandates an attendant, it is repeating an error.
Table R-2 is not the lowest-power-conductor rule. Table R-2 is the approach-distance table for energised overhead power lines, at 1910.268(b)(7). The lowest-power-conductor rule is a separate climbing-position provision at 1910.268(n)(12). They get merged constantly and they are different rules. Table R-2's bottom row — 300 volts and under — reads avoid contact. It gives no distance, so don't work to one.
Your state may be stricter
About half the states run their own OSHA plans. Those have to be at least as effective as federal OSHA, and some are tighter. Check yours.
Read the standards yourself
- 29 CFR 1910.268 — Telecommunications
- 29 CFR 1926.1209 — Confined spaces in construction, attendant duties
- OSHA memorandum, 13 April 2016 — the citation policy quoted above
We are not your safety department and this is not legal advice. We quote OSHA and link to it; the standard is the thing that governs, not this page. If a figure here matters to a bid, read the source.