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April 17, 1995

Mr. Charles R. Slagle
Director, Risk Management
Sprint 2330 Shawnee Mission Parkway
Shawnee Mission, Kansas 66205

Dear Mr. Slagle:

This is in response to your letter of November 18, 1994 concerning the initial and interval testing of personal protective equipment (rubber insulating gloves and blankets). Please accept our apology for the delay in this response.

The standards set forth in 1910.268(f)(5) are specifically designed for the telecommunications industry, as indicated by its heading. Those standards contained in 1910.137 cover all of general industry. Therefore, the applicable standards that would cover the initial and interval testing of rubber insulating gloves and blankets would come under 1910.268.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact Carla Marcellus on 202/219-8041 ext. 105.

Sincerely,



John B. Miles, Jr., Director
Directorate of Compliance Programs




November 18, 1994

John Miles, Director
Directorate of Compliance Programs
United States Department of Labor
Occupational Safety and Health Administration
200 Constitution Avenue, N.W.
Room N-3468
Washington, D.C. 20210

Dear Mr. Miles:

Sprint is a diversified international telecommunications company with local telephone services in 19 states. The local telephone outside plant workers, on occasion work near power hazards and wear rubber insulating gloves for protection. In addition, they also on occasion use rubber insulating blankets in various work procedures when working around power.

I am requesting an interpretation from OSHA as to the rubber glove and blanket insulation equipment testing intervals.

In Subpart I - Personal Protective Equipment, 1910.137(b)(2)(xii) and Table I-6 Rubber Insulating Equipment Testing Intervals, the standard requires that rubber insulating gloves and blankets must be tested before the first issue and every 6 months and 12 months respectively. The 1910.137 standard table conflicts with the table in 1910.268(f)(5). This table sets forth inspection intervals for rubber insulating gloves and blankets. The telecommunications standard for natural rubber gloves and blankets sets the testing interval for new equipment at 12 months and reissued equipment at 9 months.

As you can see, the two tables provide a conflict as to the initial testing and the testing interval for reissued equipment. Please provide an interpretation that will give sprint and other telephone companies in the industry a clear direction on this issue.

Your prompt response would be appreciated.

Sincerely,



Charles R. Slagle, ARM, CHCM
Director, Risk Management