In the 2014 OSHA update to 29 CFR 1910.269 and 1926 Subpart V, major changes were made regarding apparel and minimum approach distance (MAD) calculations. And yet I believe the agency missed an opportunity related to distribution voltages and gloving of energized conductors and equipment. For all intents and purposes, other than the MAD updates, few changes occurred in 29 CFR 1910.269(l) regarding working position. A new requirement removed any implied obligation that an employer is accountable for ensuring employees do not approach or take any conductive objects within the MADs found in tables 6 to 10 of 1910.269. The standard now clearly and without any doubt requires an employer to calculate and provide MADs to all employees and contractors working on energized systems.
Paragraph 1910.269(l)(3)(i) now states that the “employer shall establish minimum approach distances no less than the distances computed by Table R-3 for ac systems or Table R-8 for dc systems.” And the updated standard also now requires an engineering analysis on voltages greater than 72.5 kV to allow for transient overvoltages that occur due to system operations, breakers, capacitors or lightning. Ironically, the MAD found in the 2002 National Electrical Safety Code for 25-kV systems was 31 inches, 12 years before it was changed in OSHA’s update to 1910.269.