Standard Interpretations - Table of Contents
• Standard Number: 1910.137; 1910.137(a)(1) ; 1910.137(b)(2) ; 1910.137(b)(2)(viii); 1910.137(b)(2)(ix); 1910.137(b)(2)(xi)

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

October 23, 1995

Ms. Janet Fox
Occupational Health Department
Con Edison 30 Flatbush Avenue
Brooklyn, New York 11217

Dear Ms. Fox:

This is in response to your letter of April 4, 1995 requesting clarification of the Electrical Protective Equipment standard, 29 CFR 1910.137. In your letter, you specifically requested that the Occupational Safety and Health Administration (OSHA) clarify what the certification requirements are for ozone-resistant electrical protective equipment. Please accept our apology for the delay in responding.

Section 1910.137 does not require employers to certify ozone resistance testing. Under paragraph 1910.137(a)(1), ozone-resistant testing of electrical protective equipment is a manufacturing requirement. Paragraph 1910.137(b)(2)(xii) requires employers to certify that rubber insulating equipment has been tested as required by paragraphs 1910.137(b)(2)(viii), 1910.137(b)(2)(ix), and 1910.137(b)(2)(xi). These three paragraphs do not require rubber insulating equipment to be subject to ozone resistant tests.

The note following paragraph 1910.137(b)(2)(ix) states that standard electrical test methods a