- Standard Number:1910.268(f)(5)
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 http://www.osha.gov.
October 4, 1984
Mr. Kenneth S. Booth
406 West Main Street
Bowling Green, Missouri 63334
Dear Mr. Booth:
This is in response to your letter of August 7, to Vice President George Bush, concerning the Occupational Safety and Health Administration's (OSHA) telecommunications standard.
As you noted in your letter, Section [1910.268(f)(2)] requires rubber insulating equipment to be periodically tested at intervals ranging from nine months to 18 months. This requirement protects employees from the hazards resulting from the deterioration of the insulating equipment due to aging or use. Employees can not rely on insulating equipment which has not been tested within the amount of time given in the standard, even if the equipment has been properly stored[.]
in accordance with paragraph (f)(7) of Section 1910.268. Considering the fact that a breakdown in the insulating properties of this equipment can lead directly to a fatal accident, OSHA feels that allowing, as you suggest, up to five years between tests can unreasonably jeopardize employee safety.
This document was edited on 6/15/2002 to strike information that no longer relects current OSHA policy. For current information see the 3/13/2002 letter to P. Gelinas.
The national consensus standards on this subject, American Society for Testing and Materials "Standard Specification for the In-Service Care of Insulating Gloves and Sleeves" (ASTM F496-80) and "Standard Specification for In-Service Care of Insulating Blankets" (ASTM F479-81), require a 12 month testing interval for insulating equipment used in the telecommunications industry. Therefore, the OSHA standard is consistent with current industry practice.
However, to minimize unnecessary burden on employers, the existing OSHA standards are not interpreted as requiring the testing of equipment that is not in use for prolonged periods of time. Equipment in storage need not be tested until it is made available for use by employees. For example, a pair of rubber insulating gloves in storage and not available for use by employees for three years would not be required to be tested during the three-year period, but the gloves would have to be tested before being made available for use. Therefore, under the existing standard, the cost of testing is minimized to that necessary for the safety of employees.
I appreciate your concern in this matter. We welcome any additional comments you may have and will consider them in the revision of our standards.
Barry J. White, Director
[Directorate of Enforcement Programs]