|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
July 25, 1984
||GILBERT J. SAULTER|
||JOHN B. MILES, JR., Director|
Directorate of Field Operations
||Applicability of [29 CFR 1926.404(b)(1)] Ground-fault protection standards when extension cords are plugged into permanent wiring at construction sites|
||July 29, 1980, Memorandum from Bruce Hillenbrand providing a clarification of [29 CFR 1926.404(b)(1)]|
In the past we have enforced under [29 CFR 1926.404(b)(1)] that receptacle outlets which are part of the permanent wiring of the building or structure are not required to be protected by GFCI's or an assured equipment grounding conductor program. This did not mean that the employer could avoid the requirements simply by powering tools by means of extension cords from permanent receptacle outlets. Generally, extension cords are equipment used as temporary wiring (i.e., as a substitute for the fixed wiring of a building or structure) to provide power to areas remote from the permanent receptacle outlet. Therefore, we enforced that the receptacles (or cord connectors) at the ends of such extension cords were receptacle outlets which are not a part of the permanent wiring of the building or structure and a GFCI or assured equipment grounding conductor program was required to protect employees.
A recent OSHRC decision will not support the aforementioned enforcement policy without substantiation that the hazards contemplated by the standard exist at the work location, thereby exposing employees to electric shock by providing a path to ground for current. Portions of buildings or structures which have been completed and no longer expose employees to the weather or damp and wet locations, or other grounding hazards, do not require ground-fault protection or assured equipment ground conductor program when extension cords are plugged into permanent wiring at construction sites.