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.

December 27, 1991

Mr. Daryl D. Magers
Senior Principal
Safety Engineer
EG & G Rocky Flats Plant
P.O. Box 1064
Golden, Colorado 80407-0464

Dear Mr. Magers:

Thank you for your letter of September 20 requesting interpretations and clarifications of 29 CFR 1910.335(a)(2)(i) on the use of general protective equipment and tools by employees when working near exposed energized conductors or circuit parts in the workplace. Please accept our apology for the delay in answering. Responses to your questions follow.

Question 1. Is this section (29 CFR 1910.335(a)(2)(i)) to

be interpreted to require all tools, including screwdrivers, pliers, etc., to be insulated when used near energized conductors or does it just address fuse handling devices, non-conductive rope, and protective shields and barriers as identified in the preamble to the final rule?

Reply: The standard at 29 CFR 1910.335(a)(2) addresses general protective equipment and tools as safeguards for personal protection of employees working near exposed energized conductors or circuit parts. This standard applies both to tools and to handling equipment. The intent of this standard is to require handling equipment, including ropes, handlines and fuse handling equipment, and tools, including screw drivers, pliers, etc., to be insulated if the tools or handling equipment might make contact with such energized conductors or parts.

Questions What are the definitions of insulated tools and 2 & 3 insulated handling equipment?

Reply: The following definitions apply to terminology used in the Electrical Safety-Related Work Practices standards at 29 CFR 1910.335. Tools are hand-held, manually-operated or motor-operated, implements for performing or facilitating mechanical operations. Handling equipment is equipment which is held or operated with the hand. Insulated means separated from other conducting surfaces by a dielectric substance or air space permanently offering a high resistance to the passage of current and to disruptive discharge through the substance or space.

Note: Tools are a specific category of handling equipment. When any tool or handling equipment is said to be insulated, it is understood to be insulated in a manner suitable for the conditions to which it is subjected [Reference-ANSI/IEEE Std 100-1984-IEEE, Standard Dictionary of Electrical and Electronics Terms). Otherwise, within the purpose of this referenced definition, tools and handling equipment are considered uninsulated.

Question 4. Are approved insulated gloves considered

handling equipment and can they or other approved personal protective equipment (PPE), be used in lieu of insulated tools?

Reply: Electrical personal protective equipment, such as, insulated gloves in compliance with 29 CFR 1910.137, are not required to be "approved", which is defined in 29 CFR 1910.399. Electrical personal protective equipment is certified by the manufacturer to comply with appropriate national consensus standards in compliance with 29 CFR 1910.137. Rubber insulating gloves which conform to American National Standards Institutes (ANSI) standards, J6.6-1967, in compliance with 29 CFR Subpart I -- Personal Protective Equipment -- are not considered handling equipment. Generally, personal protective equipment, such as rubber insulating gloves, should not be relied upon solely to provide protection against (electrical) hazards, but should be used in conjunction with engineering control safeguards and associated work practices.

Please note that the aforementioned standard at 29 CFR 1910.137 is under consideration for revision by proposed rulemaking, published in Federal Register, Volume 54, Number 19 on Tuesday, January 31, 1989. Adoption of American Society for Testing and Materials (ASTM) to replace references to ANSI standards is a proposed change. The rationale for this change is explained in the preamble on page 4977. A copy of the proposed rulemaking is enclosed for your use.

Question 5. If insulated tools must be approved for the

voltage on which they are being used, to what American National Standards Institute (ANSI), American Society for Testing Materials (ASTM), or other appropriate standards are they tested?

Reply: Insulated tools are not required to be "approved" as defined in 29 CFR 1910.399. Rather insulated tools are certified by the manufacturer to be suitable, given proper usage, for the specified conditions to which subjected. Apparently, ASTM (testing group F-18.20.08) is in the early stages of developing a standard which addresses insulated hand-held tools.

Question 6. Are there requirements for periodic re-testing

of insulating materials?

Reply: In compliance with 29 CFR 1910.335(a)(1)(ii), protective equipment shall be maintained in a safe, reliable condition and shall be periodically inspected or tested, as required by the applicable national consensus standard specified, to be in compliance with 29 CFR 1910.137. As noted previously, the Electrical Protective Equipment standards at 29 CFR 1910.137 are under consideration for revision by proposed rulemaking, published in the Federal Register, Volume 54, Number 19 on Tuesday, January 31, 1989.

Question 7. How, from an enforcement point of view, will

it be determined that the insulation is subject to damage and additional protection is required?

Reply: Generally, employer compliance with protective equipment inspection and testing requirements is discerned during Occupational Safety and Health Administration (OSHA) visits to employer facilities. Normally, compliance is determined by visual inspections of protective equipment, observation of associated workplace practices and examinations of employer records by compliance officer in consideration of OSHA standards and referenced national consensus standards and otherwise with respect to recognized safe and healthful industry practices.

Question 8. If you are aware of tool manufacturers that

produce insulated tools, particularly tools not designed for high line work, I would appreciate their names.

Reply: Identifying specific insulated tool manufacturers to the exclusion of others is considered inappropriate for the Occupational Safety and Health Administration in consideration of fair business practices. Information on manufacturing sources can be obtained from safety consultants and marketing enterprises.

Should you care to pursue the subject of insulated tools and handling equipment further, several International Electrotechnical Commission (IEC) publications prepared by Technical Committee No. 78 - Tools for Line Working, may be recommended as follows:

Publication 743 (1983): Terminology for Tools and Equipment to be Used in Line Working.

Publication 855 (1985): Insulating Foam -- filled Tubes and Solid Rods for Line Working.

Publication 900 (1987): Hand Tools for line Working up to 1000 V a.c. and 1500 V d.c.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


Patricia K. Clark, Director
Directorate of Compliance Programs