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February 20, 1981

MEMORANDUM FOR:     GILBERT J. SAULTER
                   REGIONAL ADMINISTRATOR

ATTENTION:          HERBERT M. KURTZ

THRU:               JOHN MILES FIELD COORDINATOR

FROM:               BRUCE HILLENBRAND
                   DEPUTY DIRECTOR, FEDERAL COMPLIANCE
                   AND STATE PROGRAMS

SUBJECT:            Citing of Reversed Polarity

Mr. John Miles informs us that you are not clear for our previous memorandum whether citations should be issued for reversed polarity and what standards to use.

Citations should be issued for reversed polarity since hazards do exist as pointed out in the two enclosures of the previous memorandum. A hazard which has the potential, under appropriate conditions, for an electrocution is a serious one.

The new OSHA electrical standard, "Design Safety Standards for Electrical Systems," has adopted as Subparagraph 1910.304(a)(2), the prohibition of reversed polarity contained in the new 1978 NEC Section 200-11; viz., "No grounded conductor may be attached to any terminal or lead so as to reverse designated polarity." The new standard, published in the Federal Register on January 16, 1981, is based on the NEC and revises 29 CFR 1910, Subpart S. It becomes effective on April 16, 1981, provided there is no legal stay.

In the interim, if the terminals and/or grounded conductor are not properly identified, then the employer could be cited for a violation of 29 CFR 1910.309(b) (i.e., if the terminals and/or grounded conductor were installed after March 15, 1972, or if their condition were affected by a "replacement, modification, repair, or rehabilitation" after March 15, 1972), predicated upon the applicable 1971 NEC Sections 200-2, 200-6, 200-7, 200-9, 200-10(a)&(b), and 210-5(a).