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 2, 2015

Mr. Steve Balius, CUSP, CLCP
Manager of Safety and Risk Management
SECO Energy
293 South US Highway 301
Sumterville, FL 33585

Dear Mr. Balius:

Thank you for your March 24, 2015 correspondence to the Occupational Safety and Health Administration (OSHA), Directorate of Enforcement Programs. You requested an interpretation of the requirements for arc-rated protection in 29 CFR 1910.269(l)(8)(v). This letter constitutes OSHA's interpretation only of the requirements discussed herein, and may not be applicable to any situation not delineated in your original correspondence.

Question: An employee works on a multi-phase overhead system in open air. All lines, except the line to be worked on, are covered with insulating cover. The employer has estimated that in the event of an arc, the employee would be exposed to incident heat energy of 7.7 cal/cm2. Does the employee need to wear an arc-rated faceshield?

Response: Paragraph (l)(8)(ii) of 29 CFR 1910.269 provides that for each employee exposed to hazards from electric arcs, the employer must make a reasonable estimate of the incident heat energy to which the employee would be exposed. And 29 CFR 1910.269(l)(8)(v) requires the employer to ensure that each employee exposed to hazards from electric arcs wears protective clothing and other protective equipment with an arc rating greater than or equal to the employer’s heat energy estimate whenever that estimate exceeds 2.0 cal/cm2. Generally the protective equipment must cover the employee’s entire body. However, under 29 CFR 1910.269(l)(8)(v)(C), arc-rated protection is not necessary for the employee’s head when the employee is wearing head protection meeting 29 CFR 1910.135 and the estimated incident energy is less than 9 cal/cm2 for exposures involving single-phase arcs in open air or 5 cal/cm2 for other exposures.

The exposures in your scenario, in which the lines not being worked on are covered with insulating cover, involve single-phase arcs in open air. Thus, assuming 7.7 cal/cm2 is a reasonable estimate of the employee’s incident heat energy exposure (see 29 CFR 1910.269, Appendix E, Section III.A (Estimating Available Heat Energy)), the use of an arc-rated faceshield is not required if the employee is wearing head protection meeting 29 CFR 1910.135.[1]

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 https://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

 

 

Thomas Galassi, Director
Directorate of Enforcement Programs

 

[1] Although you inquired only about OSHA”s general industry standard for electric power generation, transmission, and distribution (29 CFR 1910.269), the guidance provided in this letter also applies to 29 CFR 1926.960(g) in OSHA’s construction standards for electric power transmission and distribution (29 CFR Part 1926, Subpart V).