Selecting cold-weather hand protection

March 28, 1995

Michael Lueck
Safety Manager
Airborne Express
[Recipient address omitted]
Dear Mr. Lueck:

This is in response to your letter of November 28, 1994, sent to Mr. John Miles, Director of Compliance Programs, requesting clarification of OSHA's Personal Protective Equipment standard as it pertains to employees exposed to cold weather. Specifically, you were concerned that there were no objective standards for cold weather gear, from any of the consensus standard organizations, on which to base your PPE hazard assessment. Your letter was forwarded to this office for response. Please accept our apology for the delay in this response.

The new PPE standard for hand protection, 29 CFR 1910.138, specifies the selection criteria to be used when providing hand protection. However, unlike the other revised PPE standards for eye and face, head and foot protection, the hand protection regulation does not specify criteria for the actual equipment to be provided to employees. The standard states "Employers shall base the selection of the appropriate hand protection on an evaluation of the performance characteristics of the hand protection relative to the tasks to be performed, conditions present, duration of use, and the hazards and potential hazards identified." As stated in paragraph 2 of Appendix B, Assessment and selection, "It should be the responsibility of the safety officer to exercise common sense and appropriate expertise to accomplish these tasks."

Employers should use manufactures' data on the effectiveness of any given product to protect against cold, as well as employee feedback, in selecting hand protection.

Thank you for your interest in Occupational Safety and Health. If we can be of further assistance, please contact Russelle R. McCollough at (202)219-8031.

Sincerely,

Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]