Edison Electric Institute v. Occupational Safety and Health Administration

849 F.2d 611, 270 U.S. App. D.C. 280, 1988 CCH OSHD 28,234, 13 OSHC (BNA) 1744, 1988 U.S. App. LEXIS 7808, 1988 WL 56901
CourtCourt of Appeals for the D.C. Circuit
DecidedJune 7, 1988
Docket86-1486
StatusPublished
Cited by36 cases

This text of 849 F.2d 611 (Edison Electric Institute v. Occupational Safety and Health Administration) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Edison Electric Institute v. Occupational Safety and Health Administration, 849 F.2d 611, 270 U.S. App. D.C. 280, 1988 CCH OSHD 28,234, 13 OSHC (BNA) 1744, 1988 U.S. App. LEXIS 7808, 1988 WL 56901 (D.C. Cir. 1988).

Opinion

Opinion for the Court by Circuit Judge D.H. GINSBURG.

D.H. GINSBURG, Circuit Judge:

The Edison Electric Institute (“EEI”) petitions for review of certain provisions of the revised Electrical Standards for Construction, 29 C.F.R. Part 1926, Subpart K (1987) (“revised Subpart K”), issued by the Occupational Safety and Health Administration (“OSHA” or “the agency”) pursuant to the Occupational Safety and Health Act of 1970, 29 U.S.C. § 651 et seq. (1982 & Supp. IV 1986) (“the OSH Act” or “the Act”). Subpart K sets forth electrical safe *614 ty requirements designed to protect employees involved in construction work. Following' an informal rulemaking, OSHA promulgated revised standards that became effective on October 9, 1986, and are now codified at 29 C.F.R. § 1926.400 et seq. (1987). EEI, an association of investor-owned electric utilities, challenges three separate provisions of revised Subpart K as applied to the electric utility industry, namely, 29 C.F.R. § 1926.402(b) (1987), limiting the scope of Subpart K; 29 C.F.R. § 1926.432(a) (1987), requiring laboratory testing of certain equipment, and 29 C.F.R. § 1926.417(b) (1987), governing the locking and tagging of deenergized circuits. 1 For the reasons discussed below, we deny the petition for review.

I.

The OSH Act was adopted “to assure so far as possible every working man and woman in the Nation safe and healthful working conditions.” 29 U.S.C. § 651(b). In order to effectuate these policies, the Act authorizes the Secretary of Labor to . promulgate “occupational safety and health standards” governing worker exposure to health and safety hazards in the workplace. 2 The Act provides three means for promulgating these standards. First, for the two year period following the effective date of the Act, § 6(a) allowed the Secretary to adopt as an occupational safety and health standard any then-existing “national consensus standard” or “established Federal standard” without following the procedures set forth in the Administrative Procedure Act. 29 U.S.C. § 655(a). Second, § 6(b) of the Act allows the Secretary to promulgate, modify or revoke safety standards after notice and comment rulemaking proceedings. 29 U.S.C. § 655(b). Finally, § 6(c) allows the Secretary to promulgate emergency temporary standards when necessary to protect employees from a “grave danger.” 29 U.S.C. § 655(c). This rulemaking authority has been delegated by the Secretary to the Assistant Secretary for Occupational Safety and Health, who heads OSHA.

OSHA has enacted three existing standards governing electrical safety in the workplace. Two of these standards, Sub-parts K and V of 29 C.F.R. Part 1926, address electrical safety in construction work. The former governs general electrical safety requirements for construction, while the latter addresses the more specialized area of safety in the construction of electric transmission and distribution lines. The third standard, Subpart S of 29 C.F.R. Part 1910, governs electrical safety in general industry workplaces.

This case involves Subpart K, which was adopted in 1971 pursuant to § 6(a) of the OSH Act. Its provisions were drawn from the electrical safety regulations originally issued under § 107 of the Construction Safety Act, 40 U.S.C. § 333 (1982). See Safety and Health Regulations for Construction, 36 Fed.Reg. 7340 (1971); Redes-ignation of Safety and Health Regulations for Construction, 36 Fed.Reg. 25232 (1971). In addition to adopting these pre-existing federal regulations, former Subpart K also incorporated by reference the 1971 National Electrical Code (“the NEC”), a model code promulgated by the National Fire Protection Association (“NFPA”). 3 See 36 *615 Fed.Reg. 7370 (1971); Notice Concerning Applicability of Certain Electrical Standards, 37 Fed.Reg. 3431 (1972). The 1971 NEC was also incorporated by reference and by the direct adoption of certain provisions, into former Subpart S. See 36 Fed. Reg. 10466 (1971), 37 Fed.Reg. 3431 (1972).

In 1979, OSHA decided to revise the electrical safety standards for general industry contained in Subpart S. See Notice of Proposed Rulemaking, 44 Fed.Reg. 55274 (1979). As part of this revision, OSHA proposed that all the relevant provisions of the NEC be included in the text of the regulations, thereby eliminating the need to incorporate the code by reference. See id. at 55276. Following notice and comment, this change was adopted in the final revision, which was published on January 16, 1981, and became effective on April 16, 1981. See Final Electrical Standards, 46 Fed.Reg. 4034 (1981).

After the revision of Subpart S, OSHA turned to the revision of Subpart K, the standard at issue in this litigation. On January 2, 1982, a draft of the proposed revision was prepared by OSHA and submitted to the Advisory Committee on Construction Safety and Health (“the Advisory Committee”). After the Advisory Committee discussed this draft at their meeting of March 3, 1982, OSHA reviewed the suggested changes and published a revised proposal and notice of proposed rulemak-ing. See 48 Fed.Reg. 45872 (1983). According to the notice, the proposal was designed to place the relevant NEC requirements directly in the text of the standard, integrate the existing requirements of Subpart K into a new format, and draft the requirements in “performance language” so that “changes in technology could be accommodated, without compromising safety.” Id. Thirty-six written comments were filed in response to the notice. On April 10, 1984, a hearing was held before an administrative law judge. The final revised Subpart K was published on July 11, 1986, with an effective date of October 9, 1986. 51 Fed.Reg. 25294. This petition followed. 4

II.

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849 F.2d 611, 270 U.S. App. D.C. 280, 1988 CCH OSHD 28,234, 13 OSHC (BNA) 1744, 1988 U.S. App. LEXIS 7808, 1988 WL 56901, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edison-electric-institute-v-occupational-safety-and-health-administration-cadc-1988.