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.

January 25, 2019

Mr. Ruben Larez
[Live Line Safety]
P.O. Box 70
Manvel, Texas 77578

Dear Mr. Larez:

Thank you for your two letters to the Occupational Safety and Health Administration (OSHA) regarding 29 CFR 1910.137(c)(2)(viii). Your letters request clarification of the testing intervals for rubber insulating gloves found in 29 CFR 1910.137, Table I-5. [This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any question not delineated within your original correspondence.] Your paraphrased question and the response are below.

Question: A pair of rubber insulating gloves are tested and then issued for service for the first time. Six months later they are re-tested. After the gloves have been tested again, do the gloves have up to 12 months to be placed back into service? Or do the gloves have to be tested every six months after the first issue?

Response: Under 29 CFR 1910.137(c)(2)(viii) and Table I-5, once rubber insulating gloves have been issued for service for the first time, they must be tested every six months. Please note, that even if the gloves have been tested within six months, they must also be tested upon indication that the insulating value is suspect, after repair, and after use without protectors.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

 

Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs

[Corrected 7/8/2019]