by , on April 9, 2015

The new dates are final for OSHA 1910.269.  There is a little reprieve if AR clothing is ordered.

According to the memo, the following Enforcement Policies will be followed and are recommended for state plans also. Companies following NESC 2007 or 2012 will likely be in compliance with clothing requirements below.

OSHA notably does not mention any move on calculation timing requirements or in faceshield requirements.

“ENFORCEMENT POLICIES

1. Through August 31, 2015, no citations will be issued under 29 CFR 1910.269(l)(8)(iv)(A) through
(l)(8)(iv)(D) or 29 CFR 1926.960(g)(4)(i) through (g)(4)(iv) for failing to have employees wear flame-resistant pants if the employees are wearing 11-ounce or heavier weight cotton pants and the employer can demonstrate that it has contacted its supplier and placed an order for the required pants and that the pants are on back order or are in the process of being shipped and delivered. For this policy to apply, the employer must be able to provide OSHA with documentation of the purchase order and the date by which it expects to receive the clothing.

2. Through August 31, 2015, no citations will be issued under 29 CFR 1910.269(1)(8)(v) or 29 CFR 1926.960(g)(5) for failing to have employees wear or use protective clothing or other protective equipment with an appropriate arc rating if the employer can demonstrate that it has contacted its supplier and placed an order for the required clothing or equipment and that the clothing or equipment is on back order or is in the process of being shipped and delivered. For this policy to apply, the employer must be able to provide OSHA with documentation of the purchase order and the date by which it expects to receive the clothing or equipment.

3. Through August 31, 2015, if a contract employer (as defined at 29 CFR 1910.269(x) and 29 CFR 1926.968) can demonstrate that it has not received information it needs from a host employer (as defined at 29 CFR 1910.269(x) and 29 CFR 1926.968) to make reasonable estimates of incident heat energy exposures in accordance with 29 CFR 1910.269(1)(8)(ii) and 29 CFR 1926.960(g)(2), then the following policies will apply:

(a) No citations will be issued to the contract employer under 29 CFR 1910.269(1)(8)(ii) or 29 CFR 1926.960(g)(2) for failing to do the required estimate of incident heat energy exposures;

(b) No citations will be issued to the contract employer under 29 CFR 1910.269(1)(8)(iv)(A) through (1)(8)(iv)(D) or 29 CFR 1926.960(g)(4)(i) through (g)(4)(iv) for failing to have employees wear flame-resistant pants, provided employees are wearing 11-ounce or heavier weight cotton pants; and

(c) No citations will be issued to the contract employer under 29 CFR 1910.269(1)(8)(v) or 29 CFR 1926.960(g)(5) for failing to have employees wear or use protective clothing or other protective equipment with an appropriate arc rating.”

Be sure to read the entire original memorandum here.


Hugh Hoagland
About author:

Hugh Hoagland is the foremost tester of clothing and PPE exposed to electrical arcs and is an arc flash expert. Read more about Hugh.


1 Comment on "OSHA 1910.269 Requirements for Arc Rated Garments Gets Pushed in Citation Timing to August 31, 2015"

doug orte - 8 December 2015 Reply

Process operators are operating closed door 480v disconnect"s in MCC. What compliant PPE should they be wearing? THANKS!

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