Rubber Insulating Gloves

The question was, “The revised 2018 NFPA 70E allows insulating gloves without protectors to be used when reduced to 50% of class 00 and one whole class for 0 through 4. The question then becomes, “Rubber insulating gloves shall be electrically retested before reuse.”

Since it states an electrical test is required, is it necessary to have recertification by a lab test, or is there an electrical test that can be performed by the technician? Also, would the technician be allowed to continue use at a reduced value, or can he perform a roll-up test, replace protectors, and then continue use at the rated class?”

Good question. First of all, let’s see what OSHA says in 29 CFR 1910.137:

Protector gloves need not be used with Class 0 gloves under limited-use conditions when small equipment and parts manipulation necessitate unusually high finger dexterity.

Note to paragraph (c)(2)(vii)(A): Persons inspecting rubber insulating gloves used under these conditions need to take extra care in visually examining them. Employees using rubber insulating gloves under these conditions need to take extra care to avoid handling sharp objects.

Any other class of glove may be used without protector gloves, under limited-use conditions, when small equipment and parts manipulation necessitate unusually high finger dexterity, but only if the employer can demonstrate that the possibility of physical damage to the gloves is low and if the class of glove is one class higher than that required for the voltage involved.

Insulating gloves that have been used without protector gloves may not be reused until they have been tested under the provisions of paragraphs (c)(2)(viii) and (c)(2)(ix) of this section.

OSHA states that rubber insulating gloves may be used without leather protector gloves if “unusually high finger dexterity is needed.”

But take caution, as this statement should throw up some warning signs. To put this in another form, leather protector gloves are always required, unless unusually high finger dexterity is needed. How is “unusually high finger dexterity” defined? That is a choice the worker must make at the time he is performing the task.

The hitch is that if something goes wrong and he is injured, the company is responsible. No doubt there would be willful citations written. Most often in events of this type, OSHA will write citations for lack of training, improper or no PPE, and unqualified persons working on energized conductors and circuit parts. The rationale is that if the worker was qualified, he or she would be wearing the correct PPE and not place themselves in danger. If he or she had the proper training, they would be able to assess the risk involved in the task and wear the proper PPE. It’s pretty much a slam dunk for OSHA. To defend the company in court, count on costs ranging around $100,000.

In the 2018 edition of NFPA 70E we tried to add some additional information to assist workers in making this type of choice. Being hung up on the term “lab test” is missing the point. When OSHA or the 70E state that the gloves are to be tested before use, only a lab test would fulfill that requirement. The only other “test” mentioned in the ASTM standards for rubber insulating gloves is an “air test”, which is really an inspection requirement, not a true test. The other question asked is whether the technician can perform all the

[field] inspections, replace the leather protectors, and use the rubber insulating gloves at full-rated voltage? The short answer is:

“No.” Performing a field inspection does not verify the integrity of the rubber insulating glove; only an electrical test can provide that verification. The electrical tests (the “lab” test) can be performed internally if the company has the required equipment and fully follows the ASTM test procedures.

Besides the electrical retest statement, also note what article 130.7(C)(2) of the 2018 edition of the 70E states about the use of rubber insulating gloves without leather protectors:

Rubber insulating gloves shall be permitted to be used without leather protectors under the following conditions:

(1) There shall be no activity performed that risks cutting or damaging the glove.

(2) The rubber insulating gloves shall be electrically retested before reuse.

(3) The voltage rating of the rubber insulating gloves shall be reduced by 50 percent for class 00 and by one whole class for classes 0 through 4.”

It seems the 70E is very clear on the requirements for using rubber insulating gloves without the leather protectors, and item (1) should be as far as anyone would need to go. Anyone who has cut stranded wire knows the end is like a dozen Ginsu knives just waiting to puncture or cut the rubber glove. Remember to ask yourself this: What task is so important that it has to be worked in an energized state? It simply is too high a risk. The best answer is to always wear the leather protector gloves over the rubber insulation gloves!

As a side note, arc-rated gloves provide no shock protection and should never be worn where there is a possibility of making contact with an energized conductor or circuit part. Rubber insulating gloves and leather protector gloves provide a high resistance to heat when worn together.

Arc-Rated Clothing and PPE

A second question posed by a NETA member was: “Can natural fiber undergarments be worn under arc flash category 3 or 4 PPE.”

The answer is yes. 100% cotton or wool undergarments are allowed to be worn under all categories of PPE. That being said, wearing arc-rated daily workwear provides additional protection from the incident energy if something goes wrong. NFPA 70E provides the following on this subject in 130.7(C)(9)(a):

(a) Layering. Nonmelting, flammable fiber garments shall be permitted to be used as underlayers in conjunction with arc-rated garments in a layered system. If nonmelting, flammable fiber garments are used as underlayers, the system arc rating shall be sufficient to

prevent breakopen of the innermost arc-rated layer at the expected arc exposure incident energy level to prevent ignition of flammable underlayers. Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a garment or of a clothing system.

Also take note of 130.7(C)(9)(c), Underlayers:

(c)Underlayers. Meltable fibers such as acetate, nylon, polyester, polypropylene, and spandex shall not be permitted in fabric underlayers.

Exception: An incidental amount of elastic used on nonmelting fabric underwear or socks shall be permitted.

Summary
When in doubt, be conservative in your choices. When it all comes down to the actual outcome of the actions, it is the field service technician who will suffer the consequences of a bad work decision. Those consequences may be minor, but we cannot rely on luck to get us through.

Slow down and take the time to adequately assess the work site. Perform an honest JSA/JHA and communicate its findings to all other workers who may be placed at risk. Think about it: if the work is so complex or the parts so small that leather protector gloves cannot be worn, our guess is that the best choice is to de-energize and place the equipment into an electrically safe work condition.

Remove the hazard; the hazard doesn’t exist.