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.



February 10, 2000

Mr. Richard C. McCool, CIH, CSP
Manger, Safety and Health
Gulf Power, A Southern Company
One Energy Place
Pensacola, FL 32520

Dear Mr. McCool:

Thank you for the June 1, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs]. You have a question about minimum approach distance requirements of the Electrical Power Generation, Transmission, and Distribution Standard, 29 CFR §1910.269. Your scenario, question, and our response follow:

Scenario: An employee is working on the low side or secondary bushing (taking a reading or running a new service) of a pole transformer that is energized at 120 volts (see Figure 1). The worker is positioned in an aerial lift "bucket" and working within the minimum approach distance (two foot, two inches for AC live line work) of the high side bushing, energized at 7200 volts. The employee cannot reach the high side bushing while the bucket is in this location. The worker is wearing the proper insulating gloves for the energized part (secondary bushing) upon which work is being performed.

Question: Would "position protection" be achieved if:



  • the conductors and/or circuit parts on which work is not being performed are located to "such an extent" that the employee can not contact them at the maximum limit of his or her reach or extended reach, and
  • the employee is wearing the proper insulating gloves for the energized part upon which work is being performed?

Reply: Based upon the information you provided, the answer to your question is "No." Paragraph (l)(2) of §1910.269 requires employees to maintain the appropriate minimum approach distances. Although the rule does not provide an exception for "position protection," there are alternatives that do allow the employee to place parts of his or her body closer to live parts than the minimum approach distance.

Under paragraph 1910.269(l)(2)(i), one of the exceptions to the minimum approach distances in Tables R-6 and R-7 involves insulating the employee from the energized part. That exception states that the employee can come within the minimum approach distance if "the employee is insulated from the energized part (insulating gloves or insulating gloves and sleeves worn in accordance with paragraph (l)(3) of this section are considered insulation of the employee only with regard to the energized part upon which work is being performed)." This clause applies to whether or not the employee as a whole is considered insulated from a live part. The parts of the body that are covered with insulation are always considered as being insulated. Paragraph (l)(2) is written (1) to permit an employee to take the portion of his or her arm or body that is not covered by the rubber insulating glove or sleeve within the minimum approach distance of the energized part upon which the employee is working, but (2) to prohibit the employee from placing uninsulated parts of the body closer than the minimum approach distance to other energized parts.

In your particular example, the employee's rubber-gloved hand could come closer than 2 feet, 1 inch to any energized part on the transformer provided that the glove is insulated for the voltage involved (in your case, class 2 rubber insulating gloves, minimum). The table R-6 minimum approach distance, for this scenario, would be 2 feet, 1 inch, rather than 2 feet, 2 inches because the described employee exposure appears to be phase-to-ground. However, the employee would have to keep his or her chest and other insulated body parts at least 2 feet, 1 inch away from the parts energized at 7200 volts. (Note, under paragraph (l)(3), rubber sleeves are required if no insulation is placed on the other energized parts.)

Alternatively, other insulating equipment, such as rubber insulating blankets, may be used to meet the exception in §1910.269(l)(2)(ii) for energized parts that are insulted. Of course, all protective insulating equipment would have to meet all of the applicable design, in-service care, and use requirements of the Electrical Protective Equipment, §1910.137, requirements.

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 could also be affected by subsequent rule making. 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 Enforcement at (202) 693-1850].


Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]





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