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.

April 28, 1992




This is in response to your memorandum of March 11, requesting answers to questions related to various portions of 29 CFR 1910.331-335 Electrical Safety-Related Work Practices Standards. Your questions will be answered in the order of their presentation.

Question 1:   As used in 29 CFR 1910.333, what type of elevated power line constitutes an overhead line?

Reply:   Except as otherwise excluded by 1910.331, the Safety-Related Work Practices standards at 1910.333 apply to workplace overhead electrical conductors, within or outside of buildings, which pose an electrical hazard to employees. Overhead lines which are uninsulated and guarded by location only are considered hazardous. Also, overhead lines on which insulation is subject to penetration resulting in conductor exposure as a result of workplace operations are considered hazardous. Insulated conductors should not be confused with covered conductors. For clarification refer to the definition of "conductor" in 1910.399.

Question 2:   Does OSHA Standard 29 CFR 1910.335(a)(1) require that qualified persons wear protective gloves while working on energized equipment?

Reply:   No, 29 CFR 1910.335(a)(1) does not specifically, require qualified persons to wear protective gloves when working on energized equipment. By 1910.333(c)(2), qualified persons must be capable of working safely on energized circuits and must be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials and insulated tools. Qualified persons are required to use personal protective equipment. The type of personal protective equipment, which may be determined by qualified persons, must be appropriate for the particular work to safeguard employees from electrical hazards.

Question 3:   Can the guidelines for illumination of industrial lighting, found in ANSI/IES RP-7-1990, be used as a guide when enforcing 29 CFR 1910.333(c)(4), as it relates to minimally acceptable levels of illumination needed for employees working in spaces containing exposed energized parts?

Reply:   The consensus standards, such as ANSI/IES RP-7-1990, can be used as guidelines in the enforcement of 1910.333(c)(4).

Question 4:   Do the requirements of 29 CFR 1910.335(a)(2)(ii) apply to the enclosure of resistor banks on overhead cranes, as found at 29 CFR 1910.179.

Reply:   Yes, the requirements of 1910.335(a)(2)(ii) apply to work on or near resistor banks of overhead and gantry cranes covered by 1910.179 standards. The standard at 1910.335(a)(2)(ii) can not be used to require resistor bank enclosures. Enclosures for these resistor banks must meet the permanent installation standards at 1910.303(g)(2) and (h)(2). Employers must comply with the Safety-Related Work Practices Standards at 1910.331 through 1910.335 in addition to the electrical installation standards contained elsewhere, and predominantly at 1910.303 through 1910.308, in the General Industry Standards. Note that by 1910.332(a), employees who face a risk of electrical hazards that are not reduced to a safe level by the electrical installation requirements referenced above, must be trained in electrical safety-related work procedures are required by sections 1910.331 through 1910.335.

If you have additional questions, please feel free to contact James C. Dillard, of my staff, at FTS 523-8041.