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 http://www.osha.gov.

October 26, 1999

Mr. Dimitrios S. Mihou, CSP
OSHA Regulatory Compliance/
Accident Prevention Specialist
Niagara Mohawk
300 Erie Boulevard West
Syracuse, NY 13202-4250

Dear Mr. Mihou:

Thank you for your March 2, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You have a question regarding minimum approach distances requirements of the Electrical Power Generation, Transmission, and Distribution Standard, 29 CFR 1910.269. Please accept our apology for the delay in responding. Your question and our response follow:

Question: When using rubber gloves and sleeves, can other body parts come within the minimum approach distances specified in 1910.269(l)(2)?

Answer: This issue is covered by 29 CFR 1910.269(l)(2)(i). The preamble summary and explanation section to 29 CFR 1910.269(l)(2)(i) contains the following explanation:

Final 1910.269(l)(2)(i) contains the first exception - insulating the employee from the energized part. This insulation can take the form of rubber insulating gloves and rubber insulating sleeves. This equipment protects the employee from electric shock as he or she works on the line or equipment. Even though uninsulated parts of the employee's body may come closer to the live part than would otherwise be permitted by Table R-6 through Table R-10, the employee's hand and arm would be insulated from the live part, and the working distances involved would be sufficient protection against arc-over. As noted earlier the tables include a component for inadvertent movement, which is unnecessary for employees using rubber insulating equipment. In the worst case situation, an employee would be working on a line requiring a 3-foot minimum approach distance. (Footnote omitted.) The electrical component of this minimum approach distance is 1 foot. Because the distance from the hand to the elbow is about 1 foot and because it would be uncomfortable to work closer than this distance to a line being held in the hand, the worst case minimum approach distance would exceed the electrical component of the minimum approach distance, and the employee would be protected from sparkover. In any event, the accident data in the record show that the overriding hazard to employees is posed by other energized conductors in the work area, to which the minimum approach distances still apply. The rubber gloves, of course, provide protection only for the line on which work is being performed. Of course, the insulation used would have to be designed for the voltage. (The revision of 1910.137 gives use voltages for electrical protective equipment.) 59 FR 4320, 4386 (January 31, 1994) (Emphasis added).

This discussion makes it clear that portions of the employee's body may come closer to an energized part than the minimum approach distance. However, this exception is limited to electrical parts on which the employee is actually working (see 29 CFR 1910.269(l)(2)(i); 59 FR 4320, 4386 (January 31, 1994) ("as a clarification, paragraph (l)(2)(i) notes that the insulation is considered as protection only against parts upon which work is being performed; the required minimum approach distance would have to be maintained from other exposed energized parts.). The employee's body must still maintain the minimum approach distance from energized parts on which the employee is not working. This includes energized parts at a different potential, such as another phase conductor. It also includes energized parts at the same potential if the employee is not actually working on them.

For example, consider a power line worker working on the primary tap of a single phase 7620/120-volt transformer fed by a 13,200-volt, three-phase overhead distribution circuit. If the employee is wearing rubber gloves and sleeves, the employee's chest can come closer than 2-feet, 1-inch from the transformer tap. However, the power line worker will need to maintain a 2-foot, 1-inch minimum approach distance from the 7620-volt phase conductor feeding the transformer and from the other two 7620-volt phase conductors with respect to any uninsulated portion of his or her body. Additionally, the employee would need to take measures to ensure that he or she does not contact the 120-volt secondary terminals or conductors.

To accomplish this employee protection, the other energized conductors in the work area can be covered with rubber insulating blankets or line hose suitable for the voltage involved. Please take note that insulating blankets, matting, covers, line hose, gloves, and sleeves made of rubber are electrical protective equipment and subject to the requirements of the Electrical protective equipment standard, 1910.137.

The employee must have positive control over the energized parts in order to be considered insulated from the energized parts. For example, if an employee is cutting an energized conductor while wearing rubber insulating gloves and sleeves, either the conductor would need to be maintained under positive control, or the employee would need to maintain the minimum approach distance from uninsulated parts of his or her body. Otherwise, the free ends of the cut conductor could swing into the employee.

Thank you for your interest in occupational safety and health. We hope that you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may wish to consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs