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Protective clothing for line-clearance tree trimmers

Summary A utility asked what apparel requirements applied to line-clearance tree trimmers who were not qualified electrical workers. OSHA said the applicable electric-power rule points to its general PPE requirements, including a hazard assessment and equipment selected to protect against identified hazards.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1998-10-29
Date issued
October 29, 1998
Status
Active
Status last verified October 9, 2026

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October 29, 1998

Mr. Dimitrious S. Mihou, CSP
OSHA Regulatory Compliance/Accident Prevention Specialist
Niagra Mohawk Power Corporation
[Recipient address omitted]
Dear Mr. Mihou:

This is in response to your letter of August 13, addressed to John B. Miles, Jr., former Director, Directorate of Compliance Programs, requesting an interpretation of our standard 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution; Electrical Protective Equipment; Final Rule.

You stated in your letter, "Paragraphs (a)(2), (b), (c), (g), (k), (p) and (r) of this standard apply to line-clearance tree-trimming operations performed by line-clearance tree-trimmers who are not qualified." Your specific question was, what are the apparel requirements for line-clearance tree-trimmers considering that 1910.269 paragraph (l)(6)(iii) does not apply to line-clearance tree-trimmers who are not qualified employees and paragraph (r), Line-Clearance tree-trimming operations, does not have any apparel requirements.

Paragraph 1910.269(g)(1) states that personal protective equipment (PPE) shall meet the requirements of 1910 Subpart I. Personal protective equipment, which may include clothing, must be provided, used and maintained as required by 1910.132. Personal protective equipment must be selected and used such that employees are protected from the hazards identified in the hazard assessment required by paragraph 1910.132(d).

Thank you for your interest in occupational safety and health. If you have any questions or concerns please contact Russelle McCollough of my staff at (202)-219-8031.

Sincerely,

Richard Fairfax, Acting Director
Directorate of Compliance Programs

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