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.

September 1, 2006

Ms. Mary Thompson
Regulatory Compliance Manager
Alabama Rural Electric Association of Cooperatives
P.O. Box 244014
Montgomery, AL 36124

Dear Ms. Thompson:

Thank you for your August 1, 2006, letter to the Occupational Safety and Health Administration (OSHA). You have questions regarding OSHA's Electric power generation, transmission, and distribution standard, 29 CFR §1910.269 and the requirements for personal protective equipment when working with and around underground lines and pad-mount transformers. Your paraphrased inquiry and our response follow.

Question: What personal protective equipment (PPE) is required to be in compliance with the requirements for working within the minimum approach distances (MADs) of underground pad-mount transformers? Are both insulating gloves and insulating sleeves required?

Response: The requirements for working within the MADs of underground lines and transformers are the same as when working within the MADs of overhead lines. Paragraph 1910.269(l) addresses working on or near exposed energized parts; it is not limited to overhead lines. This paragraph does not differentiate based on nature of the component (line versus equipment), nor does it differentiate on the basis of the location of the energized part (overhead versus underground). Therefore, the requirements found in 1910.269(l) apply regardless of the location or nature of the exposed energized part(s), including those that require electrical protective equipment.

Regarding your question on the use of gloves and sleeves, 1910.269(l)(2)(i) allows for employees to work within the MADs of energized parts if they are wearing insulating gloves and insulating sleeves in accordance with 1910.269(l)(3). Paragraph 1910.269(l)(3) requires that, if employees are insulated from the energized parts through the use of insulating gloves, then insulating sleeves are also required with two exceptions. There are two conditions noted in 1910.269(l)(3)(i) and 1910.269(l)(3)(ii) that would allow an employee to use insulating gloves without the use of insulating sleeves: 1) if exposed energized parts on which work is not being performed are insulated from the employee; and 2) if such insulation is placed from a position not exposing the employee's upper arm to contact with other energized parts.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions regarding the enforcement of OSHA regulations, please feel free to contact the Office of General Industry Enforcement at (202) 693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs