OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 10, 1979

James Thomas Demos, LTD
Attorneys at Law
33 North Dearborn Street
Suite 826
Chicago, Illinois 60602

Dear Mr. Demos:

This is in response to your recent letter concerning the accuracy of definitions.

Employees engaged in the Construction of electric transmissions and distribution lines are required to use hydraulic tools that contain an insulating oil and nonconducting hoses. The "insulating type" as used in my April 3, 1978, letter means a fluid that will not conduct electricity; "nonconducting" as used in 29 CFR 1926.951(f)(4)(i) means a hose meeting the requirements of the American National Standards Institute (ANSI) J6.1-1950 (R1971) for rubber insulating line hose.

The requirements for the use of insulating type fluids, and nonconducting hoses, is to protect an employee from electrocution by an accidental contact of the hose with an energized line.

If I may be of any further assistance, please feel free to contact me.


Grover C. Wrenn Director,
Federal Compliance
and State Programs