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.

October 29, 1998

Mr. Dimitrious S. Mihou, CSP
OSHA Regulatory Compliance/Accident Prevention Specialist
Niagra Mohawk Power Corporation
300 Erie Boulevard West
Syracuse, New York 13202-4250

Dear Mr. Mihou:

This is in response to your letter of August 13, addressed to John B. Miles, Jr., former Director, Directorate of Compliance Programs, requesting an interpretation of our standard 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution; Electrical Protective Equipment; Final Rule.

You stated in your letter, "Paragraphs (a)(2), (b), (c), (g), (k), (p) and (r) of this standard apply to line-clearance tree-trimming operations performed by line-clearance tree-trimmers who are not qualified." Your specific question was, what are the apparel requirements for line-clearance tree-trimmers considering that 1910.269 paragraph (l)(6)(iii) does not apply to line-clearance tree-trimmers who are not qualified employees and paragraph (r), Line-Clearance tree-trimming operations, does not have any apparel requirements.

Paragraph 1910.269(g)(1) states that personal protective equipment (PPE) shall meet the requirements of 1910 Subpart I. Personal protective equipment, which may include clothing, must be provided, used and maintained as required by 1910.132. Personal protective equipment must be selected and used such that employees are protected from the hazards identified in the hazard assessment required by paragraph 1910.132(d).

Thank you for your interest in occupational safety and health. If you have any questions or concerns please contact Russelle McCollough of my staff at (202)-219-8031.


Richard Fairfax, Acting Director
Directorate of Compliance Programs