I'm no expert, but I'm pretty sure there is no "potential" violation in the interpretation of MAD rules. If your hand goes inside of the MAD then you are inside. If not, then you are outside.
It seems maybe a little close if you are brushing up against it or worried you might accidentally reach past your MAD. But that's just, like, my opinion.
My opinion is the same as both of you. You violate MAD when you violate it by actually crossing the boundary. I am eyeball deep in trying to understand OSHA 1910.269, and I am not an OSHA subject matter expert or qualified to interpret.
So here's what is driving the question:
When an employee performs work near exposed parts energized at more than 600 volts, but not more than 72.5 kilovolts, and is not wearing rubber insulating gloves, being protected by insulating equipment covering the energized parts, performing work using live-line tools, or performing live-line barehand work under paragraph (q)(3) of this section, the employee shall work from a position where he or she cannot REACH into the minimum approach distance, established by the employer under paragraph (l)(3)(i) of this section.
So the rule exists in OSHA. However, this is section (l) - lower case letter "L". Per the paragraph below, section (l) is excluded from the list of paragraphs applying to line clearance tree trimmers who are not qualified employees.
Paragraphs (a)(2), (a)(3), (b), (c), (g), (k), (p), and (r) of this section apply to line-clearance tree trimming covered by the introductory text to paragraph (a)(1)(i)(E) of this section when performed by line-clearance tree trimmers who are not qualified employees.
My understanding is that paragraph (l) is written to apply to qualified electrical employees, i.e. linemen. The question I am getting: How could linemen have stricter rules around MAD than tree trimmers? So, that's where I'm at....Trying to make heads or tails of OSHA and just touching base with treebuzz for a sanity check.