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OSHA 1910.269AppG

Reference documents appendix

Subpart R

16 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.269AppG, does OSHA consider following a listed national consensus standard to automatically mean I'm in compliance with 1910.269?

No. Appendix G to 1910.269 lists national consensus standards as helpful references but does not automatically make compliance with those standards equal compliance with 1910.269. Employers may follow the referenced standards to meet the performance-based requirements of 1910.269, but "Except as specifically noted in 1910.269, however, the Occupational Safety and Health Administration will not necessarily deem compliance with the national consensus standards to be compliance with the provisions of 1910.269" (Appendix G to 1910.269).

  • Use the consensus standards for detailed specs and practices, but confirm they meet the specific duty in 1910.269. See 29 CFR part 1910 for the enforceable standards.

Under 1910.269AppG, can I rely on ASTM F1506-10a for selecting arc-rated clothing for electrical work covered by 1910.269?

Yes. Appendix G lists ASTM F1506-10a as a national consensus standard for arc- and flame-resistant textile materials and it can be used as guidance when selecting arc-rated clothing for work covered by 1910.269, but following it does not automatically satisfy 1910.269. Appendix G is intended to provide detailed specifications employers may follow, while noting that compliance with these standards is not automatically deemed compliance with the regulation (Appendix G to 1910.269).

  • Use ASTM F1506-10a to choose appropriate fabrics and test methods; then document how that selection meets the hazard assessment and PPE requirements in 29 CFR part 1910.

Under 1910.269AppG, does OSHA list standards for insulating rubber gloves and how should I use them?

Yes. Appendix G lists insulating rubber glove standards such as ASTM D120-09 and ASTM F496-08, and you should use them as practical specifications and care/testing guidance while ensuring your practices meet 1910.269 requirements. Appendix G provides these consensus standards to help employers comply with the performance-based aspects of 1910.269, but Appendix G also warns that compliance with the standards is not automatically compliance with the regulation (Appendix G to 1910.269).

  • Follow ASTM D120-09 for glove specifications and ASTM F496-08 for in-service care/testing and keep records demonstrating how those measures satisfy your duties under 29 CFR part 1910.

Under 1910.269AppG, can IEEE Std 1048-2003 be used as guidance for protective grounding of power lines?

Yes. Appendix G lists IEEE Std 1048-2003 as a helpful guide for protective grounding of power lines and equipment; employers may use this IEEE guidance to develop grounding procedures that meet 1910.269’s performance requirements. Appendix G presents such consensus documents as tools to provide the detailed methods that support compliance, but it does not automatically equate following IEEE 1048 with full compliance with 1910.269 (Appendix G to 1910.269).

  • Use IEEE Std 1048-2003 for practical grounding techniques and then document how those techniques implement applicable duties in 29 CFR part 1910.

Under 1910.269AppG, are NFPA 70E and IEEE 1584 acceptable guidance for doing arc‑flash hazard analysis?

Yes. Appendix G includes NFPA 70E-2012 and IEEE Stds 1584-2002 (and amendments) as referenced guides for arc-flash hazard calculations and electrical safety practices; they are acceptable sources of industry methods employers can use to perform arc-flash hazard analysis for work under 1910.269. However, Appendix G clarifies that following these consensus standards does not automatically demonstrate compliance with 1910.269 unless the employer’s methods satisfy the regulation’s requirements (Appendix G to 1910.269).

  • Use NFPA 70E and IEEE 1584 to perform calculations and set work practices, then verify the outputs meet your obligations under 29 CFR part 1910.

Under 1910.269AppG, can I use ANSI Z133-2012 for safe tree-trimming practices when work involves electrical lines?

Yes. Appendix G lists ANSI Z133-2012 as a reference for arboricultural operations; employers performing tree work near electrical lines can use ANSI Z133-2012 for detailed safe work practices and equipment specs, but using it does not automatically mean you meet all of 1910.269’s requirements. Appendix G suggests these consensus standards for detailed guidance while reminding employers that only the regulatory text is enforceable unless otherwise specified (Appendix G to 1910.269).

  • When working near energized lines, combine ANSI Z133 guidance with the specific duties in 29 CFR part 1910 and document how the standards address the hazards.

Under 29 CFR 1910, is OSHA currently enforcing the COVID-19 Healthcare ETS recordkeeping and reporting requirements?

No. OSHA has stated it will not enforce the COVID-19 Healthcare ETS recordkeeping and reporting requirements effective immediately and until further notice, so employers will not be cited for failing to maintain the COVID-19 log or report COVID-19 fatalities and hospitalizations under the Healthcare ETS. See the OSHA memorandum on the Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements and refer to general recordkeeping obligations under 29 CFR part 1910 and 29 CFR part 1904 for other recordkeeping rules.

  • OSHA will continue to enforce ordinary recordkeeping and reporting under 29 CFR part 1904 even while the Healthcare ETS recordkeeping/reporting is stayed.

Subject: asbestos remediation — Under OSHA guidance, which asbestos standard applies to property remediation work involving asbestos‑containing building materials?

Property remediation work involving asbestos-containing building materials is covered by OSHA’s construction asbestos standard, 29 CFR 1926.1101, not the general industry asbestos standard. OSHA explained that remediation activities involving ACBM are construction in nature and fall under the construction standard in its interpretation on Asbestos remediation protocols.

  • Employers doing remediation should follow the requirements in 29 CFR 1926.1101 as explained in the OSHA interpretation and consult state-plan requirements where applicable.

Subject: lockout/tagout testing — Under 29 CFR 1910.147, if a service task requires machine energization for testing or positioning, what steps must an employer follow?

When re-energizing a machine only to test or position components, the employer must follow the sequence in 1910.147(f)(1): clear tools and materials, remove employees from hazardous areas, remove lockout/tagout devices as specified, energize the machine with effective employee protection during testing/positioning, and then de-energize and reapply energy control devices if more servicing is needed. OSHA explained these required steps in its interpretation on the Minor servicing exception clarification.

  • Ensure the testing/positioning sequence is written in procedures and that workers are protected from hazardous energy during re-energized operations.

Subject: stair measurement — Under 29 CFR 1910.25(c)(4), how should stair width be measured in relation to handrails?

Measure stair width between vertical barriers; handrails are not considered vertical barriers so they do not reduce the required minimum width. OSHA clarified that the minimum 22-inch width for standard stairs is measured between vertical barriers (walls, rails, guardrails) and that handrails are not counted as such in the interpretation on Stair width measurement guidance. Refer to 29 CFR part 1910 for the stair requirements.

  • Document your measurement method and the determination that handrails do not limit the 22-inch minimum between vertical barriers.

Subject: rim wheel servicing — Under 29 CFR 1910.177, do European Commercial Metric (C-type) light truck tires fall under the servicing requirements for rim wheels?

Possibly—OSHA stated that servicing of C-type light truck tires may be treated similarly to "LT" tires and that failure to comply with portions of 1910.177 for pickup truck and van servicing using C-type tires may be considered a de minimis condition if the methods and equipment are substantially similar. OSHA’s interpretation on the Scope of rim wheel servicing explains this fact-specific approach.

  • Evaluate whether your installation, servicing methods, and equipment are substantially similar to LT tires; document the comparison and be aware state-plan requirements could differ.

Subject: HVAC and oxygen‑deficient atmosphere — Under OSHA guidance, does the OSHA definition of "oxygen-deficient atmosphere" in 29 CFR 1910.134 apply to civilian employees working at DoD Air Force facilities?

Yes for civilian employees: OSHA standards, including the definition of "oxygen-deficient atmosphere" in 29 CFR 1910.134, apply to civilian employees at DoD facilities when they are working on non‑uniquely military equipment or operations; military personnel and uniquely military systems are excluded. OSHA explains this distinction and the application of the respiratory standard in the interpretation on Oxygen-deficient atmospheres in HVAC. See 29 CFR part 1910 for the respiratory protection requirements.

  • Treat oxygen concentrations below 19.5% as IDLH for covered civilian employees unless Table II conditions apply and are documented per the respiratory protection standard.

Subject: PSM and stored refrigerant — Under OSHA’s PSM guidance, does storing pre‑charged air conditioners in a warehouse count toward the 10,000‑pound threshold for 29 CFR 1910.119?

Yes. Storage and on-site movement of pre-charged units that, when aggregated at one location, meet or exceed the threshold quantity for a Category 1 flammable gas bring the process within the scope of the PSM standard. OSHA addressed this in its interpretation on PSM flammable gas aggregation and concluded such warehouse storage is a PSM-covered process when the aggregate refrigerant exceeds 10,000 pounds.

  • If you store pre-charged equipment containing Category 1 flammable gas that aggregates to or above the threshold, implement PSM program elements required under applicable OSHA standards and document your hazard assessment.

Subject: head protection — Under 29 CFR 1910.135 and crane standards, are crane operators required to wear protective helmets when lifting loads?

If there is a potential for head injury from falling objects while operating or working near cranes, employers must ensure affected employees wear protective helmets; OSHA confirmed this obligation in the interpretation on Head protection for crane operators. The employer must assess the workplace for overhead hazards as required by 29 CFR part 1910 and provide helmets meeting the incorporated consensus standards (ANSI Z89.1 series) when hazards are present.

  • Require helmets when overhead hazards exist and ensure the helmets meet recognized ANSI standards.

Subject: fall protection on low‑slope roofs — Under OSHA guidance, do employees need fall protection when stepping from a portable ladder onto a low‑slope roof and walking to work 25 feet from the edge?

No. OSHA does not specifically require fall protection simply because an employee steps off a portable ladder onto a low-slope roof and walks directly to a work area 25 feet from the edge; OSHA’s interpretation on Fall protection on low slope roofs clarifies that fall protection is required when work is performed less than 6 feet from the roof edge and may be required for work 15 feet or more from the edge depending on whether the work is infrequent and temporary under 29 CFR 1910.28(b)(13)(iii). See 29 CFR part 1910 for fall protection rules.

  • Evaluate whether the actual work is infrequent/temporary or reaches distances that trigger fall protection duties, and document your determination.

Subject: mobile ladder stand platforms — Under OSHA guidance, what are the key design requirements for mobile ladder stand platforms used to access CNC tables?

Mobile ladder stand platforms must meet specific design requirements: a step width of at least 16 inches; steps uniformly spaced with a rise not over 10 inches and a depth not less than 7 inches; platform handrail and midrail requirements vary by platform height; and guardrail strength must meet the 200-pound test for top rails. OSHA summarized these requirements in the interpretation on Mobile ladder stand requirements and these provisions are found in the ladder and fall protection sections of 29 CFR part 1910.

  • Design checklist: step width ≥16 in, rise ≤10 in, tread depth ≥7 in, slope ≤60°, rail/guarding based on platform height, and guardrails must resist 200 lb applied force. Document compliance with the cited ladder provisions.