Inside Electrical Protective Equipment Standards: What 1926.97 & 1910.137 Require

I’ve never forgotten the first time I saw an arc-flash suit after an incident. The visor was melted inward, like glass turned to taffy. The worker survived, barely, because he’d worn the gear that day.

People talk about personal protective equipment like it’s a form to check off, but it’s the only thing that kept that man from being another number on a statistic. From 2011 through 2023, the Electrical Safety Foundation International (ESFI) listed 1,940 deaths from electrical contact in U.S. workplaces. I still look at that number sometimes when someone tells me their gloves “should be fine for one more week.”

That’s the quiet part nobody writes into procedures: the fatigue, the shortcuts, the belief that voltage respects intent. I’ve watched good crews slide toward risk one small convenience at a time (gloves left untested, sleeves too close to a heater, records waiting “until Friday”). It doesn’t happen out of defiance. Rather, that's just how people are when the system isn’t built to remind them.

OSHA 1910.137 and 1926.97 talk about what safety managers need to know about electrical protective equipment, and I'm here to make these standards easier for you to digest and implement. But before we go straight to these rules, here’s the simple truth I hold to: every paragraph in those standards came from someone’s mistake. Usually fatal. The rest of us just borrow the lesson.

Key Takeaways

• OSHA 1910.137 and 1926.97 set the foundation for electrical safety PPE programs, requiring proof-tested rubber gloves, sleeves, blankets, and other insulating gear to protect against contact voltage.
• NFPA 70E builds on those rules, defining how to match arc flash gear and electrical PPE categories to the energy levels found in real tasks, from low-voltage panel work to live-line operations.
• Proper arc flash protection means combining insulating rubber PPE for shock hazards with arc-rated clothing that can withstand the thermal blast of an arc event.
• High-voltage PPE, including gloves rated up to 36 kV, sleeves, and live-line tools, must be stored, inspected, and re-tested on schedule to keep their dielectric strength.
• Under OSHA arc flash PPE requirements, documentation and testing are as critical as the gear itself; without proof of compliance, even certified equipment is considered untested.

Regulatory & Standards Framework

What Does OSHA 1926.97 Require for Construction?

OSHA 1926.97 is short, but every line was written with a muddy jobsite in mind. It sets the baseline for the rubber insulating equipment used by electricians and line crews: gloves, sleeves, blankets, line hose, and matting.

What it really says, stripped of the legal language, is simple: every piece of insulating gear must do what it claims, that is, block voltage, hold its rating, and stay intact through daily use. The standard references the ASTM specifications that define how that gear is built and labeled:

Each item must bear the manufacturer’s identification, the class or voltage rating, and any size or type markings that match its ASTM design. Those markings are proof that the product was tested to the right specification before it ever reached the site.

The rule also defines in-service care in broad strokes. Equipment must be kept clean, dry, and free of defects that could compromise insulation. If the surface is cracked, abraded, or sticky from contamination, it’s removed from service until verified safe or replaced.

What Does OSHA 1910.137 Require for General Industry?

OSHA 1910.137 was written for the plant floor, the maintenance shop, and the substation room where systems stay energized while work goes on around them. It governs the same family of rubber insulating equipment but applies them to ongoing industrial operations instead of construction projects.

The standard is divided into two main parts: (1) design and manufacture, and (2) in-service care and use. The first part references the same ASTM specifications as the construction rule. Those documents set the mechanical and electrical performance requirements, such as thickness, dielectric strength, and the voltage each class must withstand. In short, before a glove or sleeve ever reaches a maintenance cage, its compliance is measured in kilovolts.

The second part of 1910.137 is where the employer’s responsibility begins. It requires that all protective equipment:

• be visually inspected before use;
• be kept free from moisture, oil, or other contaminants that reduce insulation; and
• be removed from service if any defect or damage is observed.

That wording may sound obvious, but in practice it covers a thousand small failures: a glove folded in a tool bag, a sleeve brushed with grease, a blanket used as a pad under a panel.

Another quiet but important requirement comes from the ASTM in-service care standards referenced by OSHA, which address storage. These standards specify that rubber goods must be protected from light, heat, ozone, humidity, and mechanical stress such as folding. That requirement carries most of the real-world burden. On any given day, I see gloves drying on conduit or left under truck heaters. OSHA's expectation is simpler: if you're not using it, store it the way it was tested (clean, shaped, and isolated from anything that degrades rubber)

The regulation also calls out proof testing as a condition of use. It doesn’t stop to explain the schedule here (I’ll clarify that later in the interpretation letters), but it establishes the rule that no insulating gear can be issued, re-issued, or reused without verification of dielectric integrity. The idea is that ownership comes with testing, not after it.

How Does OSHA Interpret Testing Intervals?

The rule for testing electrical protective equipment sounds straightforward until you ask what “regular intervals” really means. That question comes up in almost every audit I’ve been part of, and OSHA answered it clearly in an interpretation letter.

Here’s the short version:

• Gloves: test before first issue and every six months after.
• Sleeves, blankets, line hose, and covers: test before first issue and every 12 months after.
• Retest immediately after repair, after use without protectors, or if damage is suspected.

“First issue” is the phrase that trips people up. OSHA settled the question directly in the same interpretation letter. As Patrick J. Kapust, Acting Director of OSHA’s Directorate of Enforcement Programs, explained: “OSHA considers ‘first issue’ of rubber insulating gloves to be the date they are issued for use after the manufacturer’s seal has been broken.”

In other words, the testing clock doesn’t start when gloves are first worn, but the moment they leave their sealed packaging. That small distinction matters: a pair sitting on a shelf for months is already due for proof testing before anyone puts it on.

How I explain it to teams:

Think of it like food safety labeling. Date it when opened, not when eaten. Once the seal breaks, the clock starts.

Testing must follow the voltage ratings set in ASTM D120, and results must be traceable to the specific glove or sleeve. OSHA doesn’t require a particular log format, but during inspections, proof-test certificates or serial-numbered tags are expected. If you can’t show when it was last tested, it’s considered untested.

In practice, most programs schedule glove tests every five to five-and-a-half months to stay ahead of expiration. It’s a small buffer that prevents equipment from aging out mid-shift. It also shows OSHA that the employer isn’t waiting for reminders.

What frustrates me is how many safety managers still don't know about this interpretation. OSHA clarified this in 2020, yet I still encounter facilities running on outdated assumptions about annual testing being sufficient for rarely-used gloves. Wrong.

How Does NFPA 70E Integrate with OSHA Requirements?

We already know what OSHA requires. The question is how to apply it.

OSHA writes the rule. NFPA 70E explains the method. That’s the relationship basically. OSHA says to protect people from electrical hazards. NFPA 70E tells you how to measure, document, and prove that protection.

Most programs I’ve reviewed already use both, even if they don’t say so. Their training follows NFPA 70E language, their PPE lists match its tables, and their energized work permits trace back to its forms. They’re using it whether they notice or not.

The key overlap is in hazard evaluation. NFPA 70E arc flash requirements in Article 130 define how to perform a risk assessment: identify the task, evaluate the shock and arc-flash hazards, and decide what level of electrical safety PPE is needed. OSHA 1910.137 and 1926.97 stop before that point, as they only say the PPE must exist and be maintained. NFPA 70E fills the gap by defining how to decide which PPE applies.

It doesn’t matter which method you use as long as it’s consistent and written down. When OSHA audits a facility, documentation is what separates “guesswork” from “program.”

NFPA 70E arc flash requirements also define three approach boundaries: Limited, Restricted, and Arc Flash. These are control lines that determine what’s considered exposure and who’s allowed inside it.

What’s the Difference Between Shock and Arc-Flash Hazards?

Shock Hazards and Outcomes

Electric shock injuries happen when current flows through the body, and they’re often quieter than people expect, which might be why they keep happening. In most fatal cases, there’s no flame or explosion, just an interruption, a worker who touched something they shouldn’t have or didn’t realize was still live, and for a moment, everything stops.

What makes it deceptive is that the same job might have been done a hundred times before without a problem, and that repetition convinces people that risk can be managed by routine instead of testing or lockout.

A shock hazard exists whenever a person can make contact with an energized conductor or a surface that’s carrying potential, and it doesn’t take much for current to move through the body. Thirty milliamps is often enough to stop the heart, and that number means very little until you realize the danger isn’t voltage alone but how and where the current travels, and for how long.

Arc-Flash Hazards and Severity

On the other hand, arc flash is what happens when electricity escapes confinement. It’s the violent discharge that turns air into plasma, metal into fragments, and a routine job into a burn center case. The temperatures can reach 35,000°F, hotter than the sun’s surface. But temperature is only part of it; the blast pressure and noise are enough to rupture eardrums or throw a worker backward before they see the light.

Data from an IEEE and OSHA review by ISHN shows how deadly these events are when they do occur. Over a 34-year period, OSHA’s database recorded 4,255 fatal electric shocks, about 125 deaths per year. In the same dataset, 171 OSHA reports listed fatalities from arcs and burns, totaling 179 deaths, and of those, 120 were directly caused by arc-flash burns. Typical fatal cases involved second- and third-degree burns covering more than 40% of total body surface area.

Most of those deaths happened in confined spaces where heat and pressure had nowhere to go. A few came from test instrument failure. The study also noted that almost no fatal arc events occurred at 120/240 V single-phase or 120/208 V three-phase systems, which explains why industrial and utility work at higher voltages remains the primary focus of arc flash protection.

I still think about what happened in Boston a couple of summers ago. Two technicians went into an underground vault on Beacon Hill to service high-voltage gear. The job looked routine. It wasn’t. The equipment hadn’t been fully de-energized, and when the arc hit, one man was killed, the other badly burned.

OSHA’s investigation pulled no punches: training was incomplete, rescue prep was missing, and maintenance steps from the manufacturer were skipped. James Mulligan, OSHA’s Area Director in Braintree, Massachusetts, said after the investigation:

“Eversource could have prevented this arc flash and blast — and its tragic outcome — by ensuring effective and necessary training, procedures and work practices were provided and followed. The company knew the hazards related to this type of high-voltage equipment, yet it failed to safeguard its employees as the law requires.”

Stories like that stick with you. They strip away the talk about rules and programs and leave one fact behind: when prevention slips, arc flash gear or PPE is all that’s left between a worker and the heat. That’s what I’ll discuss next.

Electrical PPE Categories and Components

Every part of an electrical protective equipment program starts with the body. What needs protection, from what, and how much? This is your reminder that PPE works as a system and not as individual pieces.

Each layer has a purpose:

• Insulating gear (rubber gloves, sleeves, blankets) stops current from finding a path through the body.
• Arc-rated clothing (jackets, pants, hoods) resists ignition and insulates against heat.
• Face shields and helmets protect from both radiant energy and impact from fragments.
• Leather protectors shield the rubber gloves from puncture or abrasion.

Every component is assigned to a PPE category defined by NFPA 70E arc flash requirements, which links equipment type and rating to the expected incident energy from the task. The higher the category, the more energy the gear must withstand.

In the following discussions, I will break down those categories, the insulating classes used for shock protection, and how they fit together in the field.

Insulating PPE for Shock Protection

You can tell a lot about how a team treats safety just by how they treat their gloves. I’ve said that for years, and it’s still true. Some crews keep them clean, bagged, cuffs up, stored right. Others toss them on dashboards or hang them by the door where sunlight hits them half the day. Give it a month in summer heat and that rubber turns hard as cardboard. You roll the cuff and it cracks.

We depend on those gloves more than we admit. They’re the only thing between skin and current when lockout doesn’t catch everything. Rubber insulating gloves follow ASTM D120's classification system, and these markings tell you exactly what that glove was built to handle. Every class has its limit. I also keep the table below taped to the cabinet to remind everyone at all times.

The thicker the glove, the tougher it is to use tools. You try to torque a lug or thread a nut in Class 2s and you start wishing for smaller hands. That’s exactly when shortcuts creep in, gloves off for a “quick check.” Nobody means harm, but that’s how most of the shock incidents in maintenance reports start.

Arc-Rated Gear for Arc-Flash Protection

Arc-rated gear is the PPE everyone remembers after something goes wrong. Until then, it’s what people complain about: the heat, the weight, the noise when the suit moves. I get it. Those suits aren’t comfortable. But when an arc hits, comfort stops mattering, and insulation becomes the only reason someone goes home.

An arc flash doesn’t burn like fire. It’s plasma and pressure at once, temperatures climbing to 35,000°F, fast enough to blast molten metal across a room. NFPA 70E uses that reality to define categories based on the energy that might reach a worker. The idea is simple: higher risk = thicker armor.

Some manufacturers market Category 5 suits rated 75 cal/cm². NFPA 70E doesn't define a Category 5, so these suits should be selected using incident energy analysis. Under‑rating clothing can lead to second‑ or third‑degree burns; over‑rating can cause heat stress, leading workers to shed layers.

There's a fine line between enough and too much.

Combining Insulating (Shock) & Arc-Rated (Thermal) PPE

When both hazards exist (and they usually do) you need compatible protection systems. Rubber insulating gloves with leather protectors, arc-rated clothing that doesn't interfere with insulating sleeves, face shields that work with hard hats and arc hoods. The compatibility isn't always obvious.

I learned this the hard way watching a worker struggle to manipulate controls while wearing Class 2 gloves with leather protectors under an arc flash suit. The dexterity loss was so severe that he removed the leather protectors "just for a second." That second is all it takes.

NFPA 70E Section 130.7(C) requires that PPE combinations must cover both exposure types. That means:

• Rubber gloves and sleeves rated for the circuit voltage.
• Leather protectors worn over them for durability.
• Arc-rated clothing (Category 1–4) matched to the incident energy level.
• Face, head, and hearing protection that meet arc thermal performance values (ATPV).

In practice, that setup looks simple: rubber gloves inside, leather outside, arc-rated sleeves and jacket over everything. The challenge is heat. The heavier the suit, the faster fatigue builds, and that’s where shortcuts also start, so it helps to keep selection and inspection under the same program.

High-Voltage PPE Considerations

Live‑line tools and methods also matter at transmission voltages. Hot sticks, fiber-glass booms, and rubber‑sheath tools let lineworkers operate from a distance. Approach distances increase with voltage; unqualified persons must stay outside the Limited Approach Boundary.

NFPA 70E sets a 5.5‑foot Limited Approach Boundary for 15 kV and a 3.1‑foot Restricted Approach Boundary. Crossing that boundary demands rubber gloves, sleeves, and training. Live‑line work also requires equipotential grounding and dielectric aerial lifts. Mistakes at these voltages are rarely survivable, so many utilities only perform live work when turning off the power is impossible.

How to Test, Inspect, and Maintain Electrical PPE

Pre-Use Inspection

The glove inflation test takes ten seconds. Roll the cuff, trap air, squeeze gently, look and listen for leaks. It's so simple that people skip it. Then they wonder how a pinhole led to electrocution.

Check for embedded contaminants, cuts, ozone checking (those small cracks that look like dried mud), and chemical swelling. The criteria for removal aren't subjective because any of these defects means the glove is done. No exceptions. Doesn’t matter if the hole is "tiny" or the crack is "superficial."

Periodic Proof-Testing Intervals

Daily checks don't replace periodic testing. As I briefly mentioned before, OSHA lays out specific intervals for each type of rubber equipment, and it helps to see them side by side:

📍REMINDER: Mark your gear with the next test date as soon as you put it in service. Six months passes faster than you think, and OSHA expects you to prove you've stayed on schedule.

Storage, Handling, and Aging

Rubber goods hate ozone, sunlight, and heat.

Store gloves and sleeves in canvas bags or cabinets away from fluorescent lights and motors. Don't toss heavy tools on top or fold them sharply. Even unused equipment ages; some manufacturers recommend retiring gloves after twelve months from manufacture if they haven't been tested. Write the in‑service and test dates on each glove. Hard hats should be replaced every five years or after an impact.

Face shields degrade with ultraviolet exposure; follow the manufacturer's replacement intervals.

I’ve had people tell me their gloves “look fine” until I show them a comparison. In the left image below, you’ll see what a year in sunlight and a truck dashboard can do; on the right, a glove stored correctly in a bag.

How to Select and Implement Electrical PPE

No two jobs are identical, but there is a logical order to selection. I use the following steps, which align with NFPA 70E arc flash requirements’ risk assessment process:

1. Define the task and de‑energize if possible

The safest job is on dead equipment. Coordinate outages with production and resist pressure to work live. Energized work should be justified by equipment that truly cannot be shut down or by life‑safety loads.

2. Conduct a risk assessment

Identify both shock and arc‑flash hazards. Determine nominal voltage, available fault current, clearing time and working distance. Either calculate incident energy or use the PPE category tables above, but check that available fault current and clearing time don't exceed table limits.

3. Select categories of electrical PPE

Use the risk assessment to choose garments with arc ratings equal to or greater than the incident energy, plus rubber gloves and sleeves for the voltage. Pay attention to glove class, suit ratings and whether a hood is needed. If in doubt, choose a higher category or shut down the circuit.

4. Verify test dates and conditions

Look at the stamps on gloves, sleeves and blankets to make sure you're within the six‑month and twelve‑month windows. I write test dates large on my gear bag so I can see them before dawn. Keep written or digital records; OSHA can ask to see them.

5. Fit and train

PPE only works if it fits. Provide multiple sizes. Train workers to don and doff gear, perform pre‑use inspections and recognize when to replace equipment. I've seen someone cut finger holes in their gloves to use a smartphone, which is a clear sign they didn't understand why the gloves existed.

In an NFPA webinar, arc flash survivor Jason Brozen reflected on an incident that left him with third‑degree burns. Speaking in a video posted by a PPE manufacturer, he said:

“We should not have done that energized; there was no reason to do that energized, we could’ve come back at 3 o’clock in the afternoon, shut that gear down, did what we needed to do, and got out of there.”

His words echo what the standards already tell us: the safest way to do electrical work is with the power off. That’s not always possible, but it’s often more possible than we think.

How to Improve Electrical Safety PPE Training and Adoption

Reading standards isn't enough. Workers need to feel and internalize why electrical PPE matters. In 2010, OSHA fined the U.S. Postal Service $272,000 for failing to provide arc‑flash training. Assistant Secretary of Labor for OSHA David Michaels said that the Postal Service "knew that proper and effective training was needed for the safety of its workers but did not provide it.”

His words emphasized that training isn't optional; it's a legal and moral obligation. John Masarick of the Independent Electrical Contractors notes that their alliance with OSHA exists to share information about protecting workers from electrical and arc flash hazards. As David Michaels put it:

"Our continued alliance will help ensure that employers and workers in this industry receive information and training that are needed to keeping their workplaces safe and healthful.”

Those statements come from people who have spent their careers enforcing or teaching these standards. I take them seriously. And here are things I've found useful:

• Solve comfort problems: Organize fit clinics where workers try on different suit weights, glove styles and hoods. Collect feedback. Provide cooling vests or fan‑equipped hoods for high‑heat environments. Heat stress is a real barrier; I once fainted in a 40 cal suit on a humid afternoon.
• Require hazard analysis: Many injuries occur because workers skip the arc‑flash analysis or rely on outdated labels. Demand documentation of hazard calculations and review them during job briefings. Five extra minutes can keep you out of a burn unit.
• Create peer mentoring: Pair new workers with seasoned electricians who can share near‑misses and practical rituals, like writing test dates on bags. People learn quicker watching someone who’s done it for years.
• Empower refusal: Encourage workers to stop a job if PPE is missing, expired or ill‑fitting. Back them up when they exercise that right. Production pressure should never override safety.

Common OSHA Violations and How to Correct Them

OSHA's electrical safety PPE rules are clear, yet many employers stumble over the same issues. In my experience, the same handful of missteps show up again and again. To see the pattern, I've laid them out in a table:

The same gaps show up in OSHA inspections year after year. In one investigation, OSHA Toledo Area Director Todd Jensen said it plainly:

“Each year, hundreds of workers are hurt or worse by electrical-related injuries when employers fail to provide required personal protective equipment and follow safety procedures. Employee safety and health should be every employer’s most important bottom line.”

He’s right. Electrical rules exist because someone already paid for them in blood. Skip a lock, skip a test, someone gets burned. It’s that direct.

At one shipyard, two electricians opened a 480-volt portable box after a painter said he’d felt a shock. Their meter showed 15 to 20 volts. The reading looked harmless, so they kept going. The ground connection was loose, and one of them tried to extend the wire without shutting the circuit down. When his wrench hit the lug, the current went through his arm before anyone could react. His partner pulled the conductor away, but it was already too late. Later tests showed 462 volts on the box cover.

The problem wasn’t the meter or the wire but the moment they decided to trust a number instead of the rule. Bad ground, bad reading, same story I’ve seen too many times. You can’t measure your way out of that kind of hazard; either you shut it down or you take the hit.

What Risk Factors Affect Electrical Workers?

Electrical fatalities and injuries cluster in predictable ways. Bureau of Labor Statistics data show that electricians suffered 70 fatal work injuries in 2020, slightly more than the 68 recorded in 2019. In the private sector, there were 7,270 nonfatal cases with days away from work, a rate of 128.2 per 10,000 full‑time equivalents.

CPWR researchers documented 105 electrocution deaths among electricians from 2011–2015, more than in any other construction occupation. Power‑line installers face a death rate of 29.7 per 100,000 FTE. Nearly forty times the average. Meanwhile, about 70% of all electrical fatalities occur in non‑electrical occupations.

Environment and personal behavior also add context.

High humidity, sweat, and cramped spaces lower skin resistance. Improvised tools like a metal tape measure near bus bars create unintended paths. Fatigue and stress lead to lapses in judgment. Complacency builds when you've performed a task a hundred times without incident. Tight schedules invite skipping the glove inflation test.

Employers must address these factors through scheduling, supervision, and adequate staffing. Sometimes that means assigning two people to a job one person could do alone, just to guarantee a spotter who can say, "Wait, where's your glove?"

FAQs

What workplace issue does NFPA 70E address?

NFPA 70E covers electrical safety for workers who might be exposed to live parts or energized equipment. It’s about preventing injuries from shock, electrocution, arc flash, and arc blast. The standard explains how to identify hazards, maintain safe equipment, and use electrical safety PPE the right way.

What is the difference between arc flash and electrical PPE?

Arc flash gear protects against heat, flames, and blast pressure from an arc flash. Electrical PPE is broader and includes gear that guards against electric shock, such as rubber gloves, sleeves, and high voltage PPE. Arc flash gear shields the body from burns, while shock PPE keeps current from passing through it. Both are required under OSHA arc flash PPE requirements.

What is PPE Level 4 electrical?

Level 4 is the top category in NFPA 70E. It calls for a full arc-rated suit with a minimum rating of 40 cal/cm², a hood or face shield with a balaclava, voltage-rated gloves, leather protectors, and insulating boots. It’s used where arc flash energy is so high that unprotected skin could be fatally burned in less than a second.

What to wear under an arc flash suit?

Wear only natural fibers like cotton or wool under an arc flash suit. Never wear polyester, nylon, or other synthetics; they melt when heated. Some workers add arc-rated base layers for more protection, especially in jobs involving high voltage PPE.

What is the correct order for wearing PPE?

Put PPE on from the inside out:

• Non-melting inner clothing or arc-rated base layer
• Voltage-rated gloves with leather protectors
• Arc flash gear or other electrical safety PPE
• Face and head protection, such as a hood or shield
• Safety boots, with pant legs covering the tops

Each layer works together to protect against both electrical shock and arc flash heat.

TRADESAFE provides premium industrial safety equipment, such as Lockout Tagout Devices, Eyewash Stations, Absorbents, and more; precision-engineered and trusted by professionals to offer unmatched performance in ensuring workplace safety.