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.

May 20, 1996

Mr. Fred M. Fielding
U. S. Composites Corp.
Charles Park, Bldg. 1
P.O. Box 536
Guilderland, NY 12084-0536

Dear Mr. Fielding:

This is in response to your February 23 letter requesting interpretation of Occupational Safety and Health Administration (OSHA) electrical standards under paragraphs 1910.269, 1910.333 and 1910.335(a)(2) as they apply to employees using insulated hand tools. Please accept our apology for the delay in responding. Your questions and our response follow.

Question 1: If insulated hand tools (specifically, screwdrivers in conformance to the IEC 900 and ASTM F 1505 standards) are used, are rubber gloves required?

Question 2: If rubber gloves are required, what are the voltage thresholds for requiring them?

Question 3: If rubber gloves are required, what is the reason for them, that is, are they required because of a potential flaw in the insulation coating of the hand tool?

Reply: OSHA standards do not specifically require that an employee wear rubber insulating gloves when using insulated hand tools when working near exposed energized electrical conductors or circuit parts. When used however, rubber insulating gloves and rubber insulating sleeves must meet the requirements under 1910.137.

Under paragraph 1910.333(c)(2), only qualified persons may work on electric circuit parts or equipment that has not been deenergized under the procedures of paragraph 1910.333(b). These qualified persons shall be capable, as determined by their electrical knowledge and skills, of working safely on energized circuits. This capability includes familiarity with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials and insulated tools.

Also, this capability includes familiarity with the construction and operation of the equipment and the electrical hazards involved, in accordance with the definition of qualified person in 1910.399.

Under paragraph 1910.335(a)(1), employees working in areas where there are potential electrical hazards must be provided with, and must use, electrical protective equipment. The electrical protective equipment used by the qualified person must be appropriate for the specific parts of the body to be protected and for the work being performed. Paragraph 1910.335(a)(2)(i) requires employees working near exposed conductors or circuit parts to use insulated tools or handling equipment might make contact with such exposed conductors or parts. Wearing rubber insulating gloves when using an insulated hand tool may be appropriate for a particular work application. For example, if an employee's hand is exposed to contact with energized parts other than the one being manipulated with the tool, rubber insulating gloves would be required. Other personal protective equipment which provides for the electrical safety of the qualified person may also be used.

Insulated hand tools (which conform to International Electrotechnical Commission (IEC) 900 and American Society for Testing and Materials (ASTM) F 1505 standards) rated for the voltage involved would be considered insulation of the person form the energized part on which work is being performed. Generally, these tools which have a maximum rated voltage of 1000 volts for alternating current (a. c.) applications and 1500 volts for direct current (d. c.) applications would be suitable for work covered under the provisions of 29 CFR 1910 Subpart S.

When a qualified person is working on or near electric power generation, transmission, and distribution lines or equipment covered under 1910.269, the person may not approach or take any conductive object closer to exposed energized parts than set forth in Tables R-6 through Table R-10 under paragraph 1910.269(l), unless:

1. The person is insulated from the energized part (rubber insulating gloves or rubber insulating gloves and sleeves worn in accordance with paragraph 1910.269(l)(3) are considered insulation of the person only with regard to the energized part upon which work is being performed), or

2. The energized part is insulated from the employee and from any other conductive object at a different potential, or

3. The person is insulated from any other exposed conductive object, as during live-line bare-hand work.

Please not that rubber insulated gloves and sleeves are electrical protective equipment intended to protect the hands and arms of a person from exposure to hazardous electric energy conducted through a conductive object or otherwise by electric arc or direct contact.

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact the [Office of General Industry Compliance Assistance at (202) 693-1850].


John B. Miles, Jr., Director
Directorate of Compliance Programs