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.

July 11, 1983

Mr. William A. James
Code/Consultant/Variance Specialist
Technical Section
Accident Prevention Division Workers' Compensation
Department Labor and Industries Building
Salem, Oregon 97310

Dear Mr. James:

This is in response to your letter of June 2, 1983, addressed to Mr. James Lake, requesting an interpretation of 29 CFR 1910.268(n)(11)(iv) as it applies to the use of insulating gloves.

29 CFR 1910.268(f)(1) specifies that rubber gloves used for telecommunications work must meet the requirements of ANSI J6.6-1971, "Standard Specification for Rubber Insulating Gloves." This standard places gloves in classes depending on their protective characteristics. However, the standard permits gloves (referred to as "modified Class I" gloves) acquired before July 1, 1975, to meet a few different test specifications. For example, the "modified Class I" glove must have a breakdown voltage of 17kV, compared to 20kV for the standard Class I glove.

The ANSI standards have been revised, and the most recent corresponding national consensus standard is ASTM D120-79a, "Standard Specification for Rubber Insulating Gloves and Sleeves," addresses the care and use of this equipment.

29 CFR 1910.268(n)(11)(iv) requires the use of the insulating gloves for employees handling utility poles if there is a possibility that the pole may contact a power conductor. If the lines are more than 15kV to ground, the gloves must be Class II or better. If the lines are 15kV or less to ground, the gloves must have a breakdown voltage of at least 17kV. According to S1910.268(f)(1), "modified Class I" gloves meet this requirement. Also, since ASTM D120-79a, Table 2, lists the minimum breakdown voltage of standard Class I gloves as 20kV, these gloves are also acceptable for handling poles near power lines of 15kV or less.

This document was edited on 6/15/2002 to strike information that no longer reflects current OSHA policy. For current information see the
3/13/2002 letter to P. Gelinas.

Use of insulating gloves as thus outlined will provide protection to employees handling wooden utility poles near electric power lines. It should be noted that the maximum use voltages given in ASTM D120-79a and ASTM D496-80 are not appropriate for this type of work. (See appendices A and B.) Section 3.2 of ASTM D120-79a and sections 3.2 and 3.2.1 of ASTM F496-80 indicate that the listed maximum use voltages are for protection against direct contact with energized lines, when the gloves are the only protection provided.

[Corrected 6/2/2005]