A law firm asked OSHA about the requirement that employers ensure disconnecting means for transmission lines are opened and rendered inoperable or tagged to show employees are working on the lines. The specific question: may tags be placed at ground-level locations on structures, where operators can actually see them, rather than at elevated disconnecting means?
OSHA acknowledged the standard technically requires tags "at the switch or other disconnecting means." However, it will treat non-compliant tag placement as a de minimis violation when all of these conditions are met: the disconnecting means are at elevated locations; tags are placed at a conspicuous location where they will be visible and obvious; the employer's procedures explicitly describe the alternative location (1.5 to 2.4 meters above grade); procedures require a visual inspection for tags before reenergizing circuits; tags clearly indicate which disconnecting means they apply to; and all other requirements of the standard are met.
The second question asked whether wearing insulating rubber gloves would independently permit alternate tag locations. OSHA pointed back to the Question 1 conditions and noted that while appropriate personal protective equipment enhances safety, it does not create exceptions to the tag placement rules on its own.