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.

July 12, 1996

Mr. Jack E. Luoma
GTE Government Systems Corporation
100 Ferguson Drive
P.O. Box 7188
Mountain View, CA 94039

Dear Mr. Luoma:

This is in response to your May 21 letter, requesting interpretation of the telecommunication standard, 29 CFR 1910.268 and the electrical protective equipment standard, 29 CFR 1910.137 as they apply to testing of rubber insulating matting. Specifically, you requested confirmation that retesting of rubber insulating matting is not required.

This is to confirm that retesting of rubber insulating matting is not required under paragraph 1910.137(b). However, employers must institute measures, such as visual inspections, to ensure that the matting is maintained in a safe and reliable condition as required under paragraph 1910.137(b)(1). It should be noted that rubber insulating matting is intended for supplementary use with other appropriate electrical protective equipment which is required to protect an employee from exposure from hazardous electrical energy sources. Rubber insulating matting which is not electrically and mechanically retested as "other rubber insulating equipment" is considered a "de minimis" violation of paragraph 1910.268(f)(5). [De minimis violations are violations of existing OSHA standards which have no direct or immediate relationship to safety or health. Such violations of the OSHA standards result in no citation, no penalty and no required abatement.]

We appreciate your interest in occupational safety and health. If we can be of further assistance, please contact the Office of Safety Compliance, Mr. Ronald Davies, telephone (202) 219-8031, extension 110.


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