An Army engineer battalion asked OSHA to clarify glove testing intervals, since the military's Unified Facilities Criteria (UFC 3-560-01) mirrors OSHA's electrical PPE requirements. Their example: gloves tested January 1, 2016 but not issued until October 1, 2016 'must be removed from service by January 1, 2017...two months from the issue date but 12 months from the test date.' They asked whether gloves in service really must be retested on the 12-month clock even if issued only three months earlier, and what 'first issue' means.
OSHA confirmed the intervals in Table I-5 of 29 CFR 1910.137: rubber insulating gloves must be tested before first issue and every six months thereafter, and also upon indication that the insulating value is suspect, after repair, and after use without protectors. Separately, if gloves were electrically tested but not issued for service, they cannot be placed into service unless they were tested within the previous 12 months. OSHA added that best practice involves testing as frequently as monthly during regular use.
On the definition of 'first issue,' OSHA said gloves are first issued when new gloves are 'removed from their original, manufacturer's packaging.' Even if gloves are then tested and returned to storage rather than handed to a worker, they are considered issued for purposes of the use and testing requirements. Safety managers tracking glove inventories should therefore date-track from unpackaging and testing, not just from when a worker actually receives the gloves.