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.

February 10, 1989

Mr. E.F. Kimball, Jr.
Manager, Safety & Employee Health
Louisiana Power and Light Company
Post Office Box 60340
New Orleans, Louisiana 70160

Dear Mr. Kimball:

In response to your request for an interpretation of 29 CFR 1926.951(a)(1)(i), rubber protective equipment shall be in accordance with the provisions of the American National Standards Institute (ANSI), ANSI J6 Series as follows:

    Rubber insulating gloves                J6.6-1971
    Rubber matting for use around           J6.7-1935 (R1971)
      electrical apparatus
    Rubber insulating blankets              J6.4-1971
    Rubber insulating hoods                 J6.2-1950 (R1971)
    Rubber insulating line hose             J6.1-1950 (R1971)
    Rubber insulating sleeves               J6.5-1971

These ANSI Standards are all manufacturing standards and do not cover care and use of this equipment. You are correct in your interpretation that compliance with 29 CFR 1926.951(a)(1)(ii) and 29 CFR 1926.951(a)(1)(iii) would meet the standards in regard to required inspection during use of this equipment.

As stated in the letter of September 2, 1988 from this office to you, there is now being considered a revision of 1910.137 which would require the dielectric testing of rubber insulating gloves as required in the American Society for Testing and Material (ASTM) standards for Electrical Protection Equipment for Workers, F496.7 and tables 1, 2, 3. (A copy of this ASTM Standard and tables was enclosed in that letter.)

If we can be of any further assistance, just let us know.

Sincerely,



Thomas J. Shepich, Director
Directorate of Compliance Programs